It’s been nearly four years since Dodd-Frank was passed into law and all of the rulemaking requirement deadlines are now behind us, but nearly half of those deadlines have been missed, and many of them don’t even have proposals on the table.

Of the 398 total rulemaking requirements, 280 came with specific deadlines, all of which are now behind us, according to Davis Polk’s April 2014 Dodd-Frank Progress Report. Of those 280 deadlines, 152 (54.3%) have finalized rules and 128 (45.7%) have been missed and are still waiting for final rules, and 44 don’t even have proposals from the relevant regulators yet.

Dodd-Frank rule progress 0414

Consumer protection, CFTC rules ahead of the pack

Breaking it down by sector, consumer protection rules that came with specific deadlines have mostly been finalized, though there a number of rules without deadlines that still need to be developed. Asset-backed securities offerings, derivatives, and mortgage reforms all have high percentages of missed deadlines.

dodd frank rulemaking by category 0414

Among regulators, the Consumer Futures Trading Commission has made the most progress on implementing Dodd-Frank, with 50 out of 60 rules finalized, and only 2 that are past the deadline without any proposal. The Securities and Exchange Commission has finalized just 42 out of 95 required rules, with 8 past deadline and without a proposal, while bank regulators as a group have finalized 69 out of 135 required rules and still have to make proposals on 11 rules that are past deadline.

Other agencies waiting for details to be worked out

With the economy going strong, it might not seem like a rush to get Dodd-Frank into place and working as intended, but as long as financial institutions don’t know what the final form of the rules will be there is a pall of regulatory risk that they have to take into account while planning strategy. Also, until we have all the details about how Dodd-Frank is going to work in practice it’s impossible to have a serious debate about whether or not it will be enough when the next crisis hits.

The US Government Accountability Office had exactly this problem last fall when it tried to determine if new regulations would prevent the need for bailouts down the road, and it concluded simply that the Federal Reserve should set a timeframe for finishing implementing reforms so that other policymakers (such as itself) can study the issue in earnest. That hasn’t happened yet, and with an election season fast approaching hammering out such procedures probably won’t be at the top of anyone’s agenda.