Friday 7 December 2012

Is Dodd Frank worth $10 billion each and every year?

Earlier today I came across the "Dodd Frank Burden Tracker" and was gobsmacked at what I read.

The tracker can be found on the website of the US House of Representatives Committee on Financial Services.

It appears that any rule published on the Federal Register muct also include an estimate of the labour (labor in the US) hours neede by affected entities to fulfill the new requirements.

This particular tracker follows the 400 rules included in Dodd Frank, of which only 224 or 56% have been written so far. According to the data on the website these 224 rules will "cost" a shade under 20 million labour hours to implement and then cost a shade over 24 million per annum to maintain compliance.

Now let's extrapolate and say that the estimate will double and round it up to 50 million hours for the full 400 rules. While not arithmetically perfect this allows for a degree of initial underestimation.

Now I am going to assume, I think reasonably, that while the site says the estimates cover the "affected entities", this does not include all the non-US entities outside of the US. This is a far larger field so the impact there will be less; as a result I will use a working approximation of another set of work equivalent to the US ie let's double 50 million hours per annum to 100 million hours per annum.

That is fine, but makes more impact as a financial number. I will guess that there will be a disproportionate number of expensive people involved eg lawyers, compliance staff, etc so let's use a working figure of US$100 per hour.

This suggests that the annual global cost of fulfilling the 400 Dodd Frank requirements will be of the order of US$10 billion.

Oh yes, I forget the other G20 countries that are also implementing different rules and regulations with the same intent of controlling and de-risking (at least to a degree) the world of OTC derivatives. We may well double that estimate again!!!

I wonder if that is considered an acceptable cost (acceptable by whom?) to bring hoped for safety to the world of financial services?

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