The scope of the Dodd-Frank financial reform law, at roughly 2,300 pages (compared with 66 pages for Sarbanes-Oxley), was lofty and comprehensive in its ambitions. It touches on many areas of finance and affects companies beyond the financial services industry. It is a piece of legislation that all companies must examine, as it deals with not only Wall Street reform but also Sarbanes-Oxley 404(b), proxy access, executive compensations, consumer protection and credit rating agencies.  

Perhaps the most striking aspect of the law is what is hasn't yet done. 

Much of the real work of crafting specific rules and regulations was left to government agencies, who are swamped with Dodd-Frank rule-making directives. The law firm Davis Polk & Wardwell has told clients the law will require 243 new rules by 11 different federal agencies. We've noted the SEC will bear the brunt of this, as it will be responsible for about 100 new rules. The new Bureau of Consumer Financial Protection, which still does not have a leader, the new Financial Stability Oversight Council, the CFTC, the OCC and the FDIC all will have rules to make. In some cases, joint rules are required. So, the SEC has certainly been busy. 

The stuff will really hit the fan over the next year and a half as corporations gear up to continue their fight at the bureaucratic level. Certainly, the lobbyists were able to exert a lot of last-minute changes to the law. 

Beyond the regulatory action, we'll also likely see some court action. A great example of this is the proxy access rules. "Lawsuits are virtually certain," Joseph Grundfest, a Stanford Law School professor and former SEC commissioner tells Reuters. "The list of plaintiffs include many trade associations and corporations that would be affected by the rules or have to comply," he notes.

We could see suits, for example, on grounds that new rules might infringe state limits on shareholder nominees. There are many other legal rationales. Frankly, all of this opens other opportunities for lobbyists, as they will likely seek to influence judges with their analysis and concerns. 

With so much on tap--and the likelihood of suits--it may be a long, long time before some rules are firmly established. This sort of plays into the hands of those who are paid to influence the government. Perhaps we should call it the Lobbyists Full Employment Act. - Jim