Meanwhile, the Office of the Comptroller of the Currency is being managed by an interim Trump pick, Keith Noreika, while the Senate considers Joseph Otting for the top role.
Otting was nominated earlier this month, but could face a contentious confirmation. Senator Sherrod Brown, the top Democrat on the Senate Banking Committee that will consider the pick, has already announced his opposition, citing his time as an executive at OneWest Bank and that firm's foreclosure practices.
In addition to Clayton at the SEC, Christopher Giancarlo, the acting chairman of the Commodity Futures Trading Commission, is already in position, awaiting full confirmation to take on the role full-time.
But at the Federal Deposit Insurance Corporation, Obama appointee Martin Gruenberg intends to serve his full term, which expires in November. Treasury's plans to ease some of the restrictions around banks' trading, living wills and their adherence to international banking accords could face resistance from him, given his role in drafting many existing rules.
An FDIC spokesperson declined to comment.
The Treasury report also focuses significant attention on overhauling mortgage rules. But that would require cooperation from the Consumer Financial Protection Bureau which wrote many of them.
That agency's Obama-appointed director, Richard Cordray, has a term that does not expire until summer 2018.
The CFPB, created in the wake of the financial crisis, receives its funding through the Federal Reserve and Trump can only fire Cordray "for cause," an almost impossible standard to meet. That leaves few levers the administration can pull to get the agency to reorganize its internal operations or make the suggested changes on mortgages.
Cordray will probably do nothing more than subject Trump's proposals to "long-term analysis," said Quyen Truong, a partner at law firm Stroock & Stroock & Lavan, which in Washington means he will shelve it. Truong was the assistant director and deputy general counsel for the CFPB until early 2016.
"The changes proposed by the study go to fundamental aspects of the CFPB's philosophy and operations," she said. "The CFPB likely will not confront directly those proposals."