On 5 May 2023 the SEC paid the largest award in its whistleblower program's history, nearly $279 million, to one person whose information led to a successful enforcement action. The money came from sanctions the SEC collected, under a program that did not exist before 2010. Dodd-Frank's section 922 created it. It is one of many parts of the act that still shape federal regulation of US finance.
What is the Dodd-Frank Act, and why was it passed?
The Dodd-Frank Act is Public Law 111-203, legislation signed on 21 July 2010. Its long title gives the purpose: "to promote the financial stability of the United States by improving accountability and transparency in the financial system". It was signed two years after the 2008 financial crisis.
Much of the act amends older laws. It added the Volcker rule to the Bank Holding Company Act, the SEC whistleblower program to the Securities Exchange Act, and remittance transfer rules to the Electronic Fund Transfer Act. It also created new bodies, chief among them the Consumer Financial Protection Bureau (CFPB) and the Financial Stability Oversight Council (FSOC).
So "Dodd-Frank compliance" means different programs at different firms. Picture three firms (illustrative): a swap dealer keeps trade communications, a bank holding company tests its trading desk against the Volcker rule, and a money transmitter gives remittance disclosures. Each meets a different part of the same act.
What are the main parts of Dodd-Frank, and who enforces them?
Table 1. An overview of the Dodd-Frank Act's key provisions and today's enforcers (as of October 2026).
| Part | What it does | Who enforces it today | What it means for a compliance team |
|---|---|---|---|
| Financial stability (FSOC) | Watches risk across the system; the Federal Reserve sets stronger standards for the largest bank holding companies (12 U.S.C. 5365) | FSOC; the Federal Reserve Board | Matters to banks above the asset thresholds |
| Volcker rule (section 619) | "Generally prohibits banking entities from engaging in proprietary trading or investing in or sponsoring hedge funds or private equity funds" (Federal Reserve) | The five agencies that wrote the rule, among them the Federal Reserve Board, the CFTC and the FDIC | Trading desk limits, fund investments, a compliance program |
| Swaps | Registration and records for swap dealers | The CFTC | Keep all oral and written communications that lead to a swap (17 CFR 23.202) |
| Whistleblowers (section 922) | Awards of 10 to 30 percent of sanctions collected over $1 million (15 U.S.C. 78u-6) | The SEC; the CFTC runs its own program | Tips can reach a regulator directly, with confidentiality and protection from retaliation |
| Consumer protection (Title X) | The CFPB; remittance transfer rules (section 1073); small business lending data (section 1071); data access (section 1033) | The CFPB | Lenders and money transmitters follow its rules |
Dodd-Frank compliance therefore runs part by part, and a firm may meet only one row. Section 922 also lengthened the filing window for whistleblower retaliation complaints under the Sarbanes-Oxley Act from 90 to 180 days (18 U.S.C. 1514A).
The act's call and voice recording duty sits in the swaps rules. The CFTC's 17 CFR 23.202 covers oral communications by telephone or voicemail as well as chat, instant messages and email.
Where does Dodd-Frank touch AML work?
US AML duties come from the Bank Secrecy Act and the other statutes, so Dodd-Frank is not an AML law. An AML team still meets it in three places:
- Whistleblower programs. The AML Act of 2020 copied the Dodd-Frank model for FinCEN (31 U.S.C. 5323), with FinCEN's proposed rule of 1 April 2026 covering tips on BSA and sanctions violations.
- Swap communications. On 27 September 2022 the CFTC ordered 11 financial institutions to pay over $710 million because staff used "personal text, WhatsApp or Signal" and the firms did not keep those messages, "and therefore could not provide them promptly to the CFTC".
- Remittance transfers. Regulation E's remittance rule (12 CFR 1005.30 onward) runs beside a money transmitter's BSA program, so disclosures, error claims and fraud detection and prevention can work from the same transfer record.
None of the three is a customer due diligence rule. The swap and remittance duties are tested from the firm's own records.
In compliance for investment firms, complead, formerly Sanction Scanner, keeps a client file that shows what was known and when, which score applied and who accepted it.
How has Dodd-Frank been rolled back since 2010?
Its rollbacks came in steps, and each narrowed the act's impact on the financial industry. The largest came on 24 May 2018 with the Economic Growth, Regulatory Relief, and Consumer Protection Act. It raised the asset line for the Federal Reserve's stronger standards from $50 billion to $250 billion, with power to apply them from $100 billion. It also amended the Volcker rule.
The sharpest official criticism came later: after Silicon Valley Bank failed, the Federal Reserve's review of 28 April 2023 found that the bank's "board of directors and management failed to manage their risks", and that the Board's tailoring approach after the 2018 act impeded effective supervision.
The CFPB's budget line moved too. Since a law of 4 July 2025, the cap on its funding from the Federal Reserve is 6.5 percent of the Federal Reserve System's 2009 operating expenses, adjusted yearly, down from 12 percent (12 U.S.C. 5497).
Is Dodd-Frank still in effect in 2026?
Yes. As of October 2026 the act is in force, narrowed by the 2018 act above. Its rule work this year sits with the CFPB:
- 1 May. The CFPB revised its section 1071 small business lending rule: effective 30 June 2026, compliance from 1 January 2028.
- Open. The section 1033 reconsideration, proposed on 22 August 2025, had no final rule by 29 October 2026.
Related terms
- Regulation. The rules regulators set for financial firms, and how they are enforced.
- Compliance. A firm's program for meeting the laws and rules that apply to it.
- Bank Secrecy Act. The base US AML law, with its SARs, CTRs and program rule.
- Anti Money Laundering Act. The name of several AML statutes, the US act of 2020 among them.
- Market manipulation. Conduct that distorts the price of a security, commodity or swap.
- Financial misselling. Selling a financial product that does not suit the customer.
How this entry was checked. As of 29 October 2026, the entry rests on Public Law 111-203 and the US Code sections it added or changed (15 U.S.C. 78u-6, 12 U.S.C. 1851, 12 U.S.C. 5365, 15 U.S.C. 1693o-1, 18 U.S.C. 1514A), 17 CFR 23.202, the SEC's release of 5 May 2023, the CFTC's orders of 27 September 2022, the Federal Reserve's Volcker rule page and its review of 28 April 2023, Public Law 115-174, 12 U.S.C. 5497, 31 U.S.C. 5323, and the Federal Register notices of 22 August 2025 and 1 May 2026. The three firms are illustrative; no political reading of the CFPB changes is offered, only dates and text. The reviewer, Ufuk Gürdaş, Compliance Specialist, compared each section number, amount and date with these texts once the author, Burçak Aydın (Finance Manager at complead), had written the entry. Last reviewed: 30 October 2026.
