They will undoubtedly be
replaced by people who are not as strongly invested in the value of Dodd
Frank, and who will direct their agency's rulemaking accordingly.
Not sure I would assume this is a realistic statement. I suspect they would be stronger and better.
> Date: Thu, 30 Aug 2012 17:31:24 -0400
> From: [log in to unmask]
> Subject: Re: Re Dodd Frank
> To: [log in to unmask]
>
> Dodd Frank itself does not contain much in the way of substantive
> requirements in the way of recordkeeping. That's only the tip of the
> iceberg, however.
>
> Something more than 30 federal agencies are empowered or required to
> engage in rulemaking under Dodd Frank.These administrative rules and
> regulations are where the real recordkeeping and information goverance
> requirements are going to be found, and that process is barely started.
> Some of the agencies are new entities created by Dodd Frank, so they'll
> be a while getting themselves up and running before they even start the
> process. But even under the best of circumstances, the administrative
> procedures that must be followed are slow -- rules must be drafted,
> public comment must be received and responded to, and revisions made
> prior to adoption. And of course, the bureaucratic process is itself
> inherently slow, and will further be slowed by political maneuvering by
> an assortment of parties. So, the first rules are just being adopted by
> agencies, and others will trickle out over a period of several years,
> subject to extensive tinkering thereafter as their effects are observed
> and needed corrections made.
>
> Exactly what and how much ultimately happens will depend a great deal on
> who wins the presidential election in November. The heads of these
> agencies serve at the pleasure of the sitting President, and most of the
> current agency heads, appointed with a view to strong enforcement of
> Frank Dodd, will be gone if Romney wins. They will undoubtedly be
> replaced by people who are not as strongly invested in the value of Dodd
> Frank, and who will direct their agency's rulemaking accordingly.
>
> The bottom line for now is that this is very like the early stages of
> Sarbanes Oxley. Contemplating your direction with respect to governance
> and compliance requires you to read the tea leaves and attempt to
> anticipate what they are likely to want, and to build an information
> governance structure that's responsive to compliance demands, yet
> flexible enough to accomodate anything they might throw at you that you
> didn't anticipate.
>
>
> --
> Best regards,
>
> John
> John Montaņa
> Montaņa & Associates
> 29 Parsons Road
> Landenberg Pennsylvania 19350
> 610-255-1588
> 484-653-8422 mobile
> [log in to unmask]
> www.montana-associates.com
> twitter: @johncmontana
>
>
>
>
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