On the Washington Post’s Wonkblog (7/20/13), Mike Konczal of the Roosevelt Institute marked the law’s third anniversary by asking 16 people to evaluate Dodd-Frank’s effectiveness up to now.

“The progress of the CFPB has been the most impressive” result, AFR Policy Director Marcus Stanley responded. “In 2009, very few people would have predicted that a few years later there would be a fully operational and independent consumer financial protection bureau.

“On the negative side, there are too many other areas where regulators have not acted to use the broad authority they were granted in Dodd-Frank to hold the financial system accountable,” Stanley continued. “They have not yet followed through with rules adequate to the problems revealed in the financial crisis, or in many cases with any completed rules at all. An exception has been Gary Gensler at the Commodity Futures Trading Commission. While there are flaws in the CFTC’s derivatives framework it still represents a substantial improvement over the pre-crisis lack of derivatives regulation, and it’s impressive that the smallest financial regulator has managed to actually complete one of the biggest rulemaking jobs in Dodd-Frank.”

“Things that went better than expected: just about all of the rules where an agency could act alone,” said former FDIC Chair Sheila Bair, pointing to the FDIC’s rules on resolution authority and the CFTC’s rules on centralized swaps clearing as positive examples. What has not gone so well, Bair added, are “just about all of the rules where inter-agency coordination and agreement were required: e.g. tougher bank capital standards, the Volcker Rule, risk retention for securitizers. Between agency squabbling and industry lobbying, Sisyphus could move faster than the agencies in moving these rules.”

“It has been a pleasant surprise to see how efficiently the CFTC, a tiny agency, has moved to implement derivatives regulatory reform,” the AFL-CIO’s Heather Slavkin said. “While there are certainly areas where I wish the rules were stronger, I think Chairman Gensler deserves a lot of credit for putting a regulatory framework in place that will make our financial system more safe and sound.

“At the same time, it has been shocking to witness how quickly so many people in Washington have forgotten the lessons of the crisis,” Slavkin said “Under the guise of technical amendments, some in Congress have moved to repeal key components of Dodd-Frank, such as CEO-to-worker pay ratio disclosures, and create dangerous loopholes in derivatives regulation. Other provisions important to protecting the safety and soundness of the financial system, like the Volcker Rule and the requirement that banks move certain types of derivatives trades into separately capitalized subsidiaries, remain in regulatory limbo.”