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Objective 0.1

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Objective 0.1—Complete all Dodd-Frank Act rule development requirements within the statutory deadlines.

Implementing the new responsibilities given the CFTC by the Dodd-Frank Act is a significant priority and critical focus of the Commission during the first year of this Strategic Plan. Congress requires the Commission to complete more than 60 rules within 360 days; having deadlines of 90, 180, or 270 days. The workload attendant to the rulemaking process, together with studies and other actions to be taken, is unprecedented for the CFTC.

The CFTC began working on the draft rules that Congress assigned to it in July 2010. Developing, vetting, finalizing, and implementing this many rules take an enormous effort. These rules lower risk, promote market transparency, and further protect the U.S. public.

The Commission began preparing for the task of writing rules for the swaps marketplace by identifying 30 areas of rulemaking to implement the Dodd-Frank Act (Appendix C in the Strategic Plan lists the 30 areas – see It was found that some of these areas only required one rule, while others required more. Teams have been assigned to each rule grouping. Where proposed and interim final rules have been issued, the Commission is affording as much opportunity as practicable for public comment both through written submissions and public meetings. The Commission will fully consider the comments and continue to offer this opportunity as additional proposed rules are developed. The CFTC has and will continue to work with the SEC and other regulators to maximize consistency and minimize overlap or duplication. All information will be considered in developing the best possible final rule.

PERFORMANCE MEASURE Complete all Dodd-Frank Act rules within statutory time frames. Percentage of rules complete.
Lead Program Office: Chairman's Office
Data Source: Unified Calendar
Verification: Federal Register, Volume 76 (2011)
FY 2011
FY 2011
FY 2012
FY 2013
FY 2014
FY 2015
18% 100% 100% N/A N/A N/A

Performance Analysis & Review

The performance target for FY 2011 was not met. The Dodd-Frank Act set a timeframe of 360 days (or less in a few instances) for completion of the rules, but the Commission was unable to accomplish this for several reasons. Primarily, the delay was a matter of capacity for rule consideration. With all rules, the CFTC has taken and will take a thoughtful and balanced approach – the clock will not be the driver. The Commission actively seeks and takes into full consideration public comments regarding the costs, benefits, and economic effects of proposed rules. Other activities and events contributing to the delay include:

Despite the above limitations, the Commission was able to accomplish the following Dodd-Frank Act related rulemaking tasks through September 30, 2011:

As of this writing, the CFTC anticipates completion of the vast majority of the rules by March 2012 and essentially all rules by July 2012 - within 24 months of enactment of the Dodd-Frank Act. The Commission was able to accomplish the following tasks during the first quarter of FY 2012:


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