Title I: Regulation of Systemically Significant Companies

Related Areas:

Financial Services Reform Legislation and Rulemaking

Title II: Orderly Liquidation Authority

Title VI: The Volcker Rule

Title IX: Asset Securitization

Title X: Consumer Financial Protection BureauTitle XIV: Mortgage Finance Reform — Ability-to-Repay and Qualified Mortgages

More Information:For an extensive summary of the Act’s 16 titles, see Dechert’s reports prepared for the American Bankers Association:

Analysis of Financial Regulatory Reform Legislation

Title I Summary

Title II Summary

Title X Summary

Read the Bank D&O Defense Manual for guidance on avoiding, or responding to, an FDIC investigation.

Bank D&O Defense Manual


Title I of the Dodd-Frank Act creates a new independent federal regulatory body, the Financial Stability Oversight Council (the “Council”), that is responsible for identifying and addressing systemic risks to U.S. financial stability.

The Council has the authority to subject nonbank financial companies that are determined to be significant to U.S. financial stability (“Significant Nonbanks”) to comprehensive financial regulation and supervision and to recommend to the Federal Reserve Board (“FRB”) enhanced prudential standards for Significant Nonbanks and bank holding companies with consolidated assets of $50 billion or more (“Large BHCs”). The Council consists of ten voting members, principally comprised of the Federal financial regulatory agencies, and five nonvoting members. The Secretary of the Treasury is the chairman of the Council. The first meeting of the Council was held on October 1, 2010.

The FRB is given new authority to impose heightened prudential requirements on Significant Nonbanks and Large BHCs, including heightened capital and liquidity requirements a “living will” requirement and prompt corrective action-type provisions.

Dechert attorneys are focused on helping clients chart their course through the new and evolving regulatory structure created by the Dodd-Frank Act. This site will track developments relating to the regulation of Significant Nonbanks and Large BHCs.