After A Decade, What Is Settled About Dodd-Frank?

In a statement that has been more honored in the breach than the observance, Justice Louis Brandeis once noted that "it is usually more important that a rule of law be settled than that it be settled right."¹ July 21, 2020 will be the 10th anniversary of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank). Enacted in President Obama's first term, its provisions called for significant rulemaking by the federal banking agencies. The first rulemakings were not immune from criticism, and after the 2016 election, Congress trimmed certain DoddFrank provisions in the Economic Growth, Regulatory Relief and Consumer Protection Act of 2018 (EGRRCPA). In addition, in a series of rulemakings that drew dissents, the federal banking agencies have, in the last few years, cut back on the reach of many of their initial Dodd-Frank regulations. With a presidential election looming, it is appropriate to ask what parts of the Dodd-Frank scheme for