Ten key points from Trump’s first 100 days

In the 100 days since his election, President Trump and members of his cabinet have continued public calls for a rollback of Dodd-Frank and related regulations enacted since the financial crisis, while offering few concrete actions or proposals. Initially, Wall Street (and specifically bank stocks) rallied heavily in anticipation of business-friendly deregulation and tax reform, but bank executives have since tempered their expectations and, at least among the big banks, quieted calls for broad reform.

As we anticipated last November, the Trump Administration largely departed from the anti-bank populism espoused during the campaign and quickly moved on to more traditional Republican goals to (a) reduce the “excess” regulatory burden on financial institutions and the financial system and (b) spur economic growth by improving the ability of banks to lend more freely. However, it remains to be seen how and when this talk will translate into real action.

In choosing relatively moderate nominees with industry experience for financial services agency positions thus far, the Trump Administration is sending a signal that there will be changes to financial regulations, but the core framework of Dodd-Frank is here to stay (for now).

1. Executive orders will yield few results.

2. Dodd-Frank will not be repealed.

3. Lack of consensus will slow change.

4. Appointments process will delay the impact of new regulators.

5. Tarullo is gone but may not be forgotten.

6. SEC and CFTC will lag behind banking agencies due to vacancies and funding.

7. The Administration will wait out Cordray.

8. The DOL’s fiduciary rule will live on…in spirit.

9. FSOC will become a catalyst for deregulation.

10. Midterms will put the brakes on further action.