As the first anniversary of this historic legislation approaches and as the economic recovery struggles to gain momentum, it’s important to consider the unintended consequences of some of the well-intentioned reforms — particularly those that could slow, or even undermine, the recovery. With more information and a new perspective, we must continue to work toward our shared goal: strengthening our financial system so it can effectively play its critical role in providing credit to American companies and consumers, supporting the recovery and fueling job creation.

A particularly concerning aspect of financial regulatory reform is the sheer pace at which regulators are implementing the hundreds of rules set out in Dodd-Frank. Following the peak of the financial crisis in 2008, Congress took barely a year to investigate, deliberate and enact the most sweeping reform to the financial system in eight decades. As a result of the new law, regulators are instructed to write hundreds of regulations this year.

This short period of time is insufficient for drafting and implementing thoughtful regulation that would consider all of the potential associated costs to the economy.

Some in Washington have already raised concerns with respect to the risks associated with such a swift pace of implementation. Commissioner Scott O’Malia of the U.S. Commodity Futures Trading Commission recently argued that the relentless pace of reform “does not allow market participants enough time to fully evaluate the impact of the new rules.” He also calculated that if the new rules required from the CFTC were studied consecutively rather than simultaneously, it would take the agency nearly seven years to properly implement Dodd-Frank.

Full comprehension of the cumulative impact of all of the Dodd-Frank rules requires market participants to be able to clearly understand how each rule relates to others (for example, the numerous reforms proposed with respect to the derivatives markets), as well as the phase-in and sequencing of each of the rules. This is the type of clarity that’s lacking.

Another concern hampering economic activity is that some of the reform proposals are inconsistent across agencies and across jurisdictions. At a recent House Financial Services Committee hearing, Rep. Barney Frank (D-Mass.), who co-sponsored the act, echoed the worries noted by other members of the committee and cited concerns about the unintended consequences of regulatory reform, specifically the potential for inconsistent extraterritorial application of Dodd-Frank rules regarding swap transactions.

While regulators and lawmakers have begun to revisit this issue, uncertainty remains around the final derivatives rule set and the impact those rules would have on the competitiveness of U.S. businesses in a global economy.

There has also been much discussion regarding the implementation of heightened capital requirements for financial firms. There’s no question that minimum capital levels, when calibrated appropriately, are a key means of improving the safety and soundness of the financial system without unnecessarily stifling economic growth and innovation. On this front, it’s critical to note that since the crisis, U.S. banks have improved the quality and nearly doubled the quantity of their capital from pre-crisis levels, and the 19 largest U.S. banks have passed rigorous stress tests carried out by the Federal Reserve.

Nonetheless, further increases in capital requirements above and beyond those already mandated by Basel III are on the way. Dodd-Frank requires heightened standards for “systemically significant” financial institutions and the Basel Committee on Banking Supervision is near finalization of a capital surcharge for globally active, systemically important banks of as much as 350 basis points.

We believe regulators must weigh capital requirements in the context of other measures to strengthen the financial system and not view higher capital requirements as a “cure-all” for averting financial risks. Additional capital requirements in the context of these broader reforms will add additional costs to the economy, while not clearly providing a tangible benefit to taxpayers in the form of a meaningful further reduction in the probability of failure of a financial institution.

The rapid pace of implementation, international inconsistency of rules and the lack of cogent analysis of the cumulative impact of reforms have the potential to overwhelm financial institutions and may impair an already anemic recovery.

We all share a vested interest in strengthening our financial system and fueling job creation and economic recovery in America. As we continue to pursue these goals, we must take careful stock of the comprehensive impact of regulatory reform, as any mistakes we make now could stifle economic growth and have negative consequences for our economy for years to come. The financial services industry looks forward to continuing its work with legislators and regulators to appropriately and thoughtfully implement these new reforms.

Rob Nichols is president and CEO of the Financial Services Forum, a nonpartisan financial and economic policy organization comprising the CEOs of 20 of the largest financial services institutions in the U.S.