Number of pages in statutes as a working proxy for legal complexity, see Dodd-Frankenstein

The General Counsel of Polycom, Sayed Darwish, spoke at Consero’s conference last month. One of his charts gave the number of pages in various historic statutes regarding financial services. The Federal Reserve Act of 1913 took a mere 31 pages; Glass-Steagall of 1933 had 37 pages; the Interstate Banking Efficiency Act of 1994 weighed in at 61 pages while Sarbanes-Oxley was only slightly longer at 66; Gramm-Leach-Bliley in 1995 doubled to 145 pages. But then came the table-crusher, the blue whale of financial legislation: Dodd-Frank dropped on lawyers last year a Leviathan of 2,319 pages.

One statute, seven times as long as the total of the preceding five historic statutes. And wait ‘til you see the school of regulations that will swim along behind! Legal department attorneys throughout the land groan as they labor to make sense out of the massive legislation. What strategic plan of a law department could have allowed for that?

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