The U.S. Government Accountability Office (GAO) recently analyzed 30 different rules and regulations as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), which became effective between July 2015 and July 2016, to determine the impact of the rules on financial market stability.
Dodd-Frank requires or authorizes various federal agencies to issue hundreds of rules to implement reforms intended to strengthen the financial services industry. A congressional provision allows GAO to study the financial regulations annually.
For the study, GAO examined the paperwork burden imposed by 12 of the rules for which the agency determined an analysis was required. In some instances, it was determined that no new collection of information was required. While independent regulatory agencies are not subject to executive orders requiring federal agencies to conduct detailed cost-benefit analyses in accordance with the Office of Management and Budget (OMB), many stated they followed the guidance “in spirit.”
GAO decided to renew five of the act’s nine major rules, which are rules likely to result in an annual impact on the economy of $100 million or more and found that regulators addressed most of the key elements of OMB guidance in their regulatory examination.
Regulators reported to GAO that they coordinated on 19 of the 30 rules reviewed, since the rulemaking process did not require regulators to coordinate on the remaining 11 rules. The GAO study, in particular, focused on coordination efforts involving three rulemaking initiatives, including the Commodity Futures and Trade Commission’s, the prudential regulators’ rules on margin requirements for over-the-counter swaps, and the Bureau of Consumer Financial Protection’s rule on integrated mortgage disclosures.
GAO made note in its report that the full imply of Dodd-Frank has yet to be determined because some of its rules have not been finalized and an inefficient time has passed to evaluate other ones.
GAO made no new recommendations in its report but said it would continue to monitor the implementation of five prior recommendations intended to improve financial regulators cost-benefit analysis and interagency coordination.