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Dodd-Frank Act Progress Report: Spring 2012

    Client Alerts
  • April 25, 2012

The Dodd-Frank Act, which was signed into law on July 21, 2010, requires regulators from 21 agencies to issue 393 final rules. Through April 2, 2012, 100 rules are finalized and regulators missed deadlines for 155 rules. Regarding these missed deadlines, regulators have proposed rules for all but 21 rules.


Second Verse… Same as the First

The SEC has not updated its anticipated timeline with respect to the following executive compensation-related proposed rules, which are due in the second half of 2012:

  • Disclosure of “pay vs. performance,” CEO-employee pay ratios and hedging by employees and directors
  • Executive compensation “clawbacks”

Similarly, final adoption of the following previously proposed rules remain slated for the first half of 2012:

  • Exchange listing standards regarding compensation committee independence and factors affecting compensation adviser independence
  • Disclosure regarding compensation consultant conflicts of interest
  • Disclosure related to “conflict minerals”
  • Enhanced disclosure by resource extraction issuers

Making the Grade

The Center for Capital Markets Competitiveness (CCMC), a division of the nation’s largest lobby, the U.S. Chamber of Commerce, recently released its annual report card, which evaluates the progress being made by regulators and policymakers to achieve modern, well-regulated, fair, transparent and vibrant capital markets. Not surprisingly, the CCMC gave relatively low marks for the progress made thus far. Commentary regarding their assessment is available in this report card.


Additional Articles from the Spring 2012 Public Company Forum:


Doug's Note: The JOBS Act

"Don't Pay Me, or Else!": Extorted or Culturally Compelled Payments to Foreign Officials

What’s New With Stock Buybacks?

Say on Pay: We Got an “A+.” Should We Still Worry?

What’s Market? Are Non-Binding Auditor Ratification Votes “Required?”