Since the law's one-year anniversary July 21, the register has recorded only 39 rulemaking SEC votes, or about 5.3 a month, the data show.

Much of the recent activity has taken place behind closed doors, adding to the appearance of a slowdown. Since Oct. 26, the agency has adopted only nine rules and did so without holding a single public meeting, conducting the votes by paper ballot.

Schapiro offered several explanations for the SEC's slower pace, including the complexity and high volume of public comments on recent rules, and the fact that a new commissioner joined the five-person panel last November.

Rule Rejected

The most important factor cited both by Schapiro and agency observers, however, is legal. Last July, the U.S. Court of Appeals rejected an SEC rule that would have made it easier for shareholders to insert board candidates onto public-company ballots, saying the agency failed to adequately assess the costs.

The rejection of the so-called proxy access rule made all future SEC rules vulnerable to a similar challenge, forcing Schapiro and her agency to redouble efforts to study cost- benefit effects.

"We are clearly taking more time on cost-benefit analysis," Schapiro said.

The court decision was "like sticking a two-by-four in the spokes" of SEC rulemaking, said Lynn E. Turner, a former chief accountant at the agency who is now managing director of Litinomics Inc., an economic and legal consulting firm. "I think it's going to get worse, not better."

Congress may exacerbate the problem, he noted: A House committee recently approved a bill that would demand a more rigorous cost-benefit justification for each rule.

Two Votes