As the July 21 one-year anniversary of the Dodd-Frank Act approaches, regulators are unlikely to celebrate their rulemaking accomplishments on the landmark legislation. That's because most of the work to flesh out the specific regulations remains to be done. In recent months regulators that are responsible for creating the rules to carry out Dodd-Frank, such as the Securities and Exchange Commission, have announced more delays than finished rules, keeping compliance executives guessing on the details of the final rules.

A report published by law firm Davis Polk & Wardwell last week confirms the continued delays. According to the firm's Dodd-Frank Progress Report, as of June 1 regulators had missed more deadlines (28) than they had made with finalized rules (24). And things look to get a lot worse later this month. There are a total of 122 rulemaking deadlines that fall between July 16 and July 21, under the Dodd-Frank Statutory Deadlines for Required Rulemakings. As of last month, rulemakers have finalized measures fulfilling just 14 of those requirements and have proposed six other rules to satisfy additional requirements. “While this represents progress, it remains clear that regulators will not be able to meet the large number of rulemaking deadlines in July,” said the firm in the progress report. Most of the required rulemaking due in the third quarter this year are related to over-the-counter (OTC) derivatives regulation.

Based on the rulemaking progress by agency as of July 1, the report indicates that banking regulators have missed a total of 9 rulemaking requirements, the SEC missed 8, and the Commodity Futures Trading Commission and other agencies missed 4 and 6 requirements respectively. The firm predicts many other agencies to miss deadlines in an increasing number of instances.

In June, the CFTC and the SEC issued temporary relief to defer many Title VII requirements on OTC derivatives ahead of the July 16 effective date. Of the articles contained in Title VII governing Wall Street Transparency and Accountability, Subtitle B concerns the regulatory regime for security-based-swaps.

Davis Polk says the move is an indication by both agencies that they will defer provisions that rely on key definitions until they complete further rulemaking. As indicated by CFTC, the relief granted will last no later than December 31 this year, making that date the new focal point for rulemaking, the report says.