Dodd-Frank Act push-out

Banks are now focused on the decisions that they need to make and determining the best course of action to be in compliance with “push-out” in 2015.


Rethinking compliance management

For banks

In the world of banking supervision and regulation, there is a familiar, longstanding cadence to the issuance of new guidance: regulators issue new guidance; banks parse and interpret it, set a strategy for compliance, begin operationalizing it, and press forward with the knowledge that most new guidance is simply a set of expectations rather than hard-and-fast requirements. In today’s environment, the assumption that guidance is just an expectation, not required, is no longer acceptable.

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Over the past few years, a new wrinkle has emerged, hinging on one small word: "should." Historically, regulatory guidance was delivered in the context of "should." As in, banks should do x, y, or z. Recent developments make it clear "should" is increasingly being interpreted as "shall," at least for larger organizations. This environment is creating a new challenge for bank leaders and boards, which must come to terms with the new reality of compliance. Which “shoulds” are really sometimes “shalls?”

This paper explores many of the important tools and considerations being used by industry leaders as they respond to more stringent and forceful regulatory scrutiny.

Meet the authors

Tom Rollauer

Tom Rollauer

Director | Center for Regulatory Strategies

Tom is the executive director of Deloitte’s Center...More

Irena Gecas-McCarthy

Irena Gecas-McCarthy

Principal | Banking & Securities

Irena is a principal in Deloitte & Touche LLP’s US...More

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David Wright

Managing Director | Banking and Securities


Alok Sinha

Banking & Securities Advisory Leader