Federal regulators have missed the statutory deadlines on 145 of the 237 rule-making requirements in the 2010 Dodd-Frank financial regulation bill, according to a top financial-regulation analyst.

After a bill becomes law, it’s up to executive agencies to write rules implementing the legislation. Dodd-Frank was more than 2000 pages, and the legislative language was a wonderful mix of complex, vague, and open-ended. The result is a huge burden on the SEC, the Fed, and other federal agencies. And they’re not meeting those burdens.

The September “Dodd-Frank Progress Report” finds this state of play [emphasis added]:

  • As of September 4, 2012, a total of 237 Dodd-Frank rulemaking requirement deadlines have passed. This is 59.5% of the 398 total rulemaking requirements, and 84.6% of the 280 rulemaking requirements with specified deadlines.
  • Of these 237 passed deadlines, 145 (61.2%) have been missed and 92 (38.8%) have been met with finalized rules. Regulators have not yet released proposals for 31 of the 145 missed rules.
  • Of the 398 total rulemaking requirements, 131 (32.9%) have been met with finalized rules and rules have been proposed that would meet 135 (33.9%) more. Rules have not yet been proposed to meet 132 (33.2%) rulemaking requirements.

The SEC, according to Davis Polk, has missed 51 of its 81 passed deadlines.