Section 615(a): Dodd-Frank’s Orphan?

When Senate Banking Committee chairman Chris Dodd and Massachusetts Representative Barney Frank proposed the Dodd-Frank Wall Street Reform and Consumer Protection Act on Dec. 2, 2009, the legislation was lauded as "…wide-ranging" and described as "addressing almost every aspect of the financial services industry." 1 Dodd-Frank took effect on July 21, 2011. In the months preceding its adoption, most attention focused on the Act's main provisions that granted the government new powers to identify…