Almost two-and-a-half years after the enactment of the Dodd-Frank Act, the various federal agencies charged with implementation have made measurable progress and have, in the last several months, taken on the major regulatory actions in earnest. 2013 accordingly may prove to be a watershed year for financial reform. Before the year gets underway, the industry and the regulators should stop to consider how the implementation of Dodd-Frank has evolved.