 In this regard in 2009 and since, Gramm–Leach has been considered in part a target of the Volcker Rule within the overall Dodd–Frank Wall Street Reform and Consumer Protection Act of 2010.Leach was usually reelected without much difficulty (including an unopposed run in 1990).He remained very popular in the 1st even as his district turned increasingly Democratic, especially from the 1990s onward.