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In passing laws, Congress focuses on policy outcomes and pays scant attention to the difficulties that administrative agencies will face in implementing the measures. Further, Congress frequently imposes deadlines for issuance of implementing rules that are impossible for the agencies to meet. The regulatory agencies charged with implementing the Dodd-Frank financial reform legislation are currently struggling with this problem. The statutory requirements for issuance on short notice of hundreds of rules has inundated their analytical and policy formulation staffs.

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