1. Introduction:

The concept of “too big to fail” (TBTF) is an integral part of the discussion about rules for banks and money safety. TBTF means that some big, linked money groups are so important their collapse would hurt the whole economy.[1] This makes it necessary for governments to step in and help them out. This concept became famous after the global financial crisis in 2007-2008. This happened when major banks failed and caused problems all over the world economy. ^[2] In response, governments had to help them with huge amounts of cash for never-before-seen rescue plans. Getting how TBTF works is important to understand the details of today’s money systems and the problems in controlling them.[3]

This assignment focuses on how the TBTF concept has grown over time. It also studies how it changes what banks do and considers arguments for or against some very important banks. It also suggests ways to handle the TBTF issue, pointing out how regulators need a fine line between keeping banks steady and creating bad risks from bailouts. The assignment also aims to give a complete focus on what TBTF means. It also gives details about how it affects future bank rules and makes financial systems stronger in the future.

2. Understanding the TBTF Concept:

   • Definition and Explanation of TBTF:

The term TBTF is a very important concept in managing money rules. It discusses huge and connected financial companies whose failure would be bad for the whole economy because they’re just so large.[4] This concept goes beyond just how big these groups are. It includes their important jobs in the money world too. Their failure could cause big risks throughout the system, resulting in many problems with money matters[5].

TBTF relies on the idea of broad risk.[6] The idea means that when banks are close together, a small bank’s problems can get bigger very fast. This could cause other banks to also have issues and create ripple effects throughout the money system. The fall of Lehman Brothers in 2008, and its worldwide effects show how this risk to the system plays out[7]. Also, TBTF is not only found in regular banks. It also relates to big money groups that aren’t banks, like insurance companies and investment businesses.[8] Their activities are important for keeping the financial system stable. The US government’s help during the 2008 money crisis, especially saving a big insurance company named AIG shows how much it is wider[9].

Analytically, the TBTF concept deals with a big problem in policy. It is when we won’t let large, connected banks fail because it could be bad for the economy and may need government help. This brings up important questions about moral risk, money control, and what it may mean for market punishment.

• Evolution of the Concept in Banking and Finance:

TBTF started in the mid-1900s, mainly because of banking issues that happened in America during the 1980s. But the idea already existed in a simple form earlier. This was during the really bad times of the 1930s called The Great Depression when big bank failures greatly affected our economy. In 1933, the creation of Federal Deposit Insurance Corporation[10] (FDIC) was a first step to stabilize big banks and keep our economy safe[11].

A big change in the concept of TBTF happened in 1984 when Continental Illinois, a large American bank, got help from others. This event showed that the government is ready to step in and stop big banks from failing. The main reason was to stop a big problem in the finance system that could come from failing huge banks connected[12].

The global financial crisis made the idea of TBTF. The fall of Lehman Brothers and the problems it caused worldwide proved how important big money groups are to a working system. The problem made people give a lot of money to banks and other businesses like AIG. ^[13] This was done so that they would not close down because it could ruin the worldwide banking system. ^[14] This time was important for the TBTF idea because it changed to include financial places that weren’t banks. There needed to be stronger control and watching over these companies.

After the 2008 crisis, new rules were brought in to fix the too-big-to-fail issue. The Dodd-Frank Act in the United States, for instance, tried to lessen big risks with tighter control on major financial companies. ^[15]Just like that, the worldwide rules for banking supervision called Basel III made stronger demands on money and liquidity. This was done so large banks could stay safe during financial surprises without needing help from bailouts.[16]

In recent years, the concept of TBTF has continued changing. Now people are focusing more on handling major dangers using policies that watch over money systems closely. These rules try to control and lessen dangers for the whole money system instead of just focusing on single banks. ^[17] However, the problem is still with knowing and controlling very big financial companies’ SIFIs and dealing with risky behavior linked to the TBTF rule. Financial markets are getting more complicated and making fintech expand. ^[18] This has added new issues in the TBTF debate, asking if old rules can handle these changing problems effectively.

3. TBTF in Banking Regulation:

   • Role of Regulation in Addressing TBTF:

Regulatory strategies to solve the TBTF problem in banking have changed. They now use more detailed ways that are not just about money and cash availability. These plans are made to deal directly with the difficulties that come from big, connected money industries.^[19]

An important part of control when discussing TBTF is using supervision based on the level of danger. This method is about looking at how risky each bank is and then paying closer attention to those who need it the most.[20] For big banks, this means careful watching all the time because they are important to everyone’s money system. This way helps watchers find and solve risks before they get bigger problems.[21] Regulatory bodies have also targeted the structure of big banks. Rules like the Volcker Rule in the Dodd-Frank Act try to control risky actions such as making bets with company money. This helped cause problems in 2008’s financial mess. Regulators try to decrease the risk of big losses in important institutions by stopping some high-risk actions[22].

Since big money companies all over the world are involved, we need countries to work together on dealing with TBTF. The Financial Stability Board (FSB) is very important in this by making sure worldwide money matters stay steady. ^[23] It works with national money leaders and global rule-setters to make strong financial rules, watch protection plans, and other policies in the finance world. ^[24] Looking at strength, it’s done by those in charge like the Federal Reserve who make rules. They look to see how banks can handle tough economic situations. ^[25] These tests are vital for big banks, making sure they have enough money saved to manage financial difficulties. This not only makes the banks stronger but also gives people belief in their safety.

• Analysis of Current Regulatory Frameworks:

The rules that focus on stopping the TBTF problem have changed a lot since the 2008 financial mess. They now aim at making major money institutions strong and lessening system-wide risks.

The Basel III framework is a main part of the rules made after the crisis. It creates greater money needs, especially for big banks that could cause problems (SIBs), to handle losses and decrease the chances of collapse. Basel III also brought in the Countercyclical Capital Buffer and the Capital Conservation Buffer. These need banks to keep extra money when credit growth is high[26].In the United States, there’s a big law called the Dodd-Frank Wall Street Reform and Consumer Protection Act. It helps deal with money problems caused by financial crises. ^[27] It has the Volcker Rule which stops banks from making some risky investments and sets rules for ending big financial firms in an orderly way.[28] The action also made the Financial Stability Oversight Council (FSOC) find out threats to money stability and watch over the biggest and most connected finance companies.[29]

In the European Union, they set up a Banking Union framework to make sure banks are safer and better run. ^[30]It includes the Single Supervisory Mechanism (SSM) and the Single Resolution Mechanism (SRM), focusing on the supervision and resolution of banks especially those called systemically important. The SRM has a Single Resolution Fund (SRF), paid for by banks.[31] This fund helps fix failing banks quickly and properly. The Financial Stability Board (FSB), teaming up with the Basel Committee, created a way to find and watch big international banks that are very important. G-SIBs have to deal with big loss rules and closer watching because they’re really important for the system.[32]

• Critique of the Effectiveness of Existing Regulations:

Rules that already exist have improved solving the TBTF problem, but they are not perfect and can face criticisms. The rules have become more complicated, especially with things like Basel III and the Dodd-Frank Act. This has worried people.^[33]Critics say that these complicated rules may cause trouble in following them, especially for smaller groups. Moreover, the complicated rules can create openings that smart banks might use.[34] This could damage how well these regulations work. There is a risk that big money companies move their work to places with fewer rules. This could make problems even bigger in the whole financial system. ^[35] Banking is a worldwide thing, which makes it hard to enforce rules the same way in different areas. This causes unevenness and can be taken advantage.[36]

Even though people try to lessen dangers from big money places, the size and linking of these companies still threaten safety in finance. ^[37] Some say that rules don’t fully solve the basic problem. Big institutions are still so huge they could fail and cause major harm to global money matters.[38] People still expect the government to save big banks if things go wrong. This is a bad habit because it might encourage these companies to take more risks, thinking they won’t get hurt when this happens. ^[39] People who talk about the rules say they have not dealt with this problem enough. They point to big banks still growing and taking risks mostly because of money issues.[40]

There is still doubt over whether today’s rules can handle future money problems, especially ones that might come from non-normal things like tech companies dealing with cash or big changes in the world economy. ^[41] They keep wondering about this much! Financial markets always changing, so rules need to keep moving too. Sometimes they have trouble with new dangers some think current set-ups cannot handle well.

4. Impact on Banking Behavior:

   • Influence of TBTF on Risk-Taking and Decision-Making in Banks:

The fact that some banks are TBTF greatly affects how they take risks and make decisions. This thing can affect the balance and solidity of money systems. One of the biggest effects of TBTF is that it makes banks more likely to take risks. Banks thought to be TBTF often think they have an unofficial safety net from the government. ^[42] Thinking like this can cause moral risk, when these banks do more dangerous things because they know that the government might save them if anything goes wrong. Studies, like the ones by De Jonghe and Öztekin, have shown that big TBTF banks often take higher risks. They do this by having riskier types of assets.[43]

The TBTF status also impacts the level of competition in banking. Big banks called TBTF often get money more easily and pay less to borrow it. This is because people lending them cash think the government will help if things go wrong. This advantage can change decisions, making big TBTF banks grow fast. ^[44] Sometimes they might not think properly about good or bad investments and loans before doing them. These actions not only raise safety chances in the banking system but also lead to unfair competition.[45] The TBTF concept can also affect how banks are run. The help given to these places might make them lazy about managing risk and following rules. ^[46] Top bosses and board leaders might not have the same pressure from markets as those in smaller, non-important banks. This could cause them to make decisions about running companies that focus more on quick profits rather than long-term safety.[47]

To deal with the bad habits of risk-taking and others from TBTF, watchers have put in hard control rules plus more money demand for big banks. These steps try to stop too much risk-taking. But they also need big banks that can’t fail TBTF to change how they run their business and make decisions so it fits with new rules, changing the way their work is done.

• Case Studies of Banks’ Behavior Influenced by TBTF Status:

Some major banks, that is too big to collapse, have been doing things differently. Many studies show this. This situation can make people act differently and pick options because they trust that the government will assist them when tough times arrive.

• JPMorgan Chase and the London Whale Incident:

One famous example is when JPMorgan Chase made big trading losses in 2012. Their London office made risky moves and it cost the bank over $6 billion. ^[48] The case showed that big too-big-to-fail banks might do risky work partly thinking the government will help if things go bad.[49]

• Citigroup’s Expansion and Subsequent Bailout:

Citigroup’s actions before the 2008 financial crisis also show this. Citigroup pushed hard to invest more money in mortgage-backed securities and other confusing financial tools. When the housing market fell apart, Citigroup had big problems and was eventually saved by the US government. ^[50] This example shows how banking companies with too-big-to-fail status can have the confidence to take on lots of risks. They do so assuming that they will be saved because they are important to all people.[51]

• Barclays and Aggressive Expansion:

A big English bank called Barclays grew fast before a crisis in 2008. Part of the reason was because people thought it was too important for UK money issues to let it fail. ^[52] This caused a chain of dangerous investments and business plans. Even though Barclays didn’t get a direct bailout, its actions showed the risky behavior linked with the TBTF concept.[53]

5. Critical Analysis: Are Some Banks Too Big to Fail?

   • Examination of Arguments for and Against the Notion of TBTF:

The concept of TBTF has started a strong argument, with important reasons that both backup and question if it is right.

• Arguments Supporting TBTF:

Systemic Stability: Supporters say that when a big bank with many ties fails, it can cause huge problems in the economy which we saw happen during the 2008 money trouble. For example, when Lehman Brothers went under it caused a worldwide money disaster. This proves why we also need to stop such falls[54].

Economic Continuity: Advocates of TBTF argue that some banks are very important for the daily working of the money system. They give very needed help to many people and companies, so they must keep running smoothly for the money flow[55].

• Arguments Against TBTF:

Moral Hazard: A main point against TBTF is that it makes room for bad behavior. If people in charge of banks think their place will be helped out, they might act more dangerously because they know the government will take on any bad effects. This weakens how the market keeps control and can cause wrong or risky money handling[56].

Market Distortions: Critics say that TBTF makes the game unfair. Big banks may get lower-cost money and better chances because lenders think these places have government support, this could cause market problems and less competition[57].

Taxpayer Burden: Critics point out that it is not right for taxpayers to have to rescue banks when they’re doing badly. Using public money to save private businesses brings up moral and economic worries, especially if the help is not joined with strict rule changes[58].

Regulatory Challenges: There are also doubts about rules being able to control banks that are too big to fail. Even with changes made by Basel III and Dodd-Frank, people who disagree wonder if these steps are enough to stop near accidents from happening again. ^[59] Or do they just make rules harder without really touching the main problem?[60]

• Discussion of Recent Banking Failures/Successes in the Context of TBTF:

Bank failures and successes now give us important information about the continuing place of TBTF theory.

• Bank Failures:

Example of a Mid-Sized Bank Failure: The bankruptcy of Banco Popular in Spain in 2017 is a good example. It was an important bank, but not big enough to make people say it was “too big to fail.” ^[61] The European leaders helped Santander buy it instead of a bailout. This shows they had a careful way of dealing with bank problems based on how big and important the bank is.[62]

Impact of Failures on Smaller Banks: Even though small bank failures are less likely to cause TBTF actions, they still have big impacts. ^[63] Some small banks in the United States going out of business shows that they might not be big enough for government help, but their failure can still affect local economies a lot.[64]

• Bank Successes:

Resilience of Large Banks: On the good side, big global banks like JPMorgan Chase and Bank of America have done well after 2008. ^[65] This shows they are strong in hard times. Even though they faced tough rules after the crisis, these big banks not only stayed alive but also grew more. This shows that too-big-to-fail institutions can adjust and run better under stronger oversight.[66]

Success Despite Size: The big banks’ success after the financial crisis shows that not being able to fail may make them safe, but it doesn’t guarantee their achievement. ^[67] These groups have had to deal with hard rules and public attention. This shows that being big alone doesn’t make someone successful or fail.[68]

These recent examples show that although the TBTF rule still affects laws and economies, its use does not always stay the same. Big banks being strict and different reactions to bank failures show how complicated the TBTF problem is in today’s money world.

6. Addressing the TBTF Problem:

   • Proposals for Regulatory Reforms:

Fixing rules is important to deal with the TBTF issue. This will make large money companies more stable and able to bounce back while also reducing big risks for overall financial systems.

Higher Capital and Liquidity Requirements for SIFIs: One suggestion is to make big financial institutions have more money and access to funds. This method means using more money controls, set to match the size and risk level of each bank. These rules aim to make sure that big banks have enough money to handle losses and lower the chances of failing[69].

Implementation of ‘Living Wills’: Another rule change is needing big banks to make and frequently update “living wills.” These are plans that explain how a bank could shut down in an orderly way if it fails, without using taxpayer money bailouts. This method tries to give a simple way to fix big banks[70].

Enhanced Supervision and Stress Testing: Stronger oversight, including regular and deep stress tests, is suggested to constantly watch the health of big banks. These tests check how well the banks can handle harsh money situations. They make sure they have strong ways to manage risk in place[71].

• Alternative Approaches to Mitigate TBTF Risks:

Besides changing the rules, some other ways have been proposed to reduce the dangers linked with big banks that are too important to fail.

Breaking Up Large Banks: A big change is to split huge banks into smaller parts. The reason is that if smaller banks fail, they will be less dangerous to the money system. This way aims to directly deal with the size part of the TBTF problem[72].

Market-Based Solutions: Promoting market ideas, like Contingent Convertible Bonds (CoCos) is another way. These CoCos change into stock when a bank’s money drops below some amount. These tools can help soak up losses and put money back into the bank when times are tough[73].

Implementing a Financial Transaction Tax: The idea of a tax on buying and selling stocks, bonds, and other financial things is suggested. This may stop too much short-term guessing work or fast trading that could risk the whole system[74].

Creating a Resolution Fund: Creating a resolution fund, paid by banks themselves, can help to smoothly close down failing banks. This money pool would grow slowly by charging banks, especially the big ones that are seen as important to the system[75].

• Evaluation of Potential Effectiveness and Challenges of Proposals:

The ideas to solve the TBTF issue can work well but have many problems. This shows how hard it is to change all rules for money matters completely.

• Effectiveness of Higher Capital and Liquidity Requirements:

Reduced Risk of Failure: Making big banks and money companies have more cash can help prevent failure by making sure they have enough backup funds to handle losses.[76]

Enhanced Market Confidence: These needs can also improve trust in big banks’ stability, possibly making it less likely for bank runs and financial scares to happen.[77]

Challenges:

Increased Operational Costs: If banks have to keep more money, it could make them spend more. This might lead to less lending and affect how much the economy grows.[78]

Complex Implementation: Making sure that rules and actions are followed the same way in different areas is hard because many big international companies have huge operations all over the world.[79]

• Effectiveness of ‘Living Wills’:

Clarity in Crisis Management: “Living wills” give a clear plan for dealing with failing banks. This can make it easier to handle crises and reduce overall risks in the system.[80]

Prevention of Bailouts: By showing a way to end things in an orderly manner, these plans can stop the need for money from taxpayers who pay off troubles.[81]

Challenges:

Practical Viability: People have not yet proved if living wills work well in a real crisis. There are worries about their usefulness when it comes to complicated money problems happening fast.[82]

Regulatory Burden: Making and keeping up with living wills put a lot of control rules on banks. This needs lots of resources to do it.[83]

• Effectiveness of Breaking Up Large Banks:

Direct Address of Size Issue: This method goes straight to the size problem of TBTF and could help lower overall risks in the system.[84]

Increased Competition: Using smaller banks can make the banking industry more competitive, which will be good for customers.[85]

Challenges:

Economic Disruption: The act of splitting up big banks might cause trouble to the money system and wider economy.[86]

Loss of Economies of Scale: There is a chance that small banks could miss out on the cost savings and efficiency of larger ones.[87]

7. Conclusion:

The “Too Big to Fail” problem is a hard thing in finance, trying to find the right mix of secureness without danger and market changes. The growth of TBTF in rules for banks, led by past problems and changes in these rules shows the need for always making better adjustments in how we put controls on them. Ideas like needing more money, having plans for when banks fail, and splitting up big banks can help lessen the risks of TBTF. But these suggestions also bring their problems such as being hard to put into action and maybe affecting the economy. If these actions work in a tough situation like today’s world, it’s important to keep checking and improving them. As money matters change, we also need to adapt how to manage and lessen the dangers linked with big, joined-up financial companies.

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Aurelija Stankute, “Discuss the concept of “too big to fail” within the financial sector. What are the arguments in favour of this concept, and what are possible negative consequences?”, Department of Economics, University of Essex,   06.05.2011

[1] Julie Young, “Too Big to Fail: Definition, History, and Reforms”, Investopedia, 13 November 2023. (Accessed on 25 0n November 2023) https://www.investopedia.com/terms/t/too-big-to-fail.asp

[2]Aurelija Stankute, “Discuss the concept of “too big to fail” within the financial sector. What are the arguments in favour of this concept, and what are possible negative consequences?”, Department of Economics, University of Essex,   06.05.2011

[3] Ibid

[4] George G. Kaufman, “TOO BIG TO FAIL IN BANKING: WHAT DOES IT MEAN?” LSE FINANCIAL MARKETS GROUP SPECIAL PAPER SERIES, June 2013, ISSN 1359-9151-222

[5]Gary H. Stern and Ron J. Feldman, Too Big to Fail: The Hazards of Bank Bailouts (Rowman & Littlefield, 2004).

[6] ibid

[7]Ben S. Bernanke, “The Crisis and the Policy Response,” Stamp Lecture, London School of Economics, January 13, 2009.

[8] ibid

[9]Sujit Kapadia et al., “Liquidity Risk, Cash Flow Constraints, and Systemic Feedbacks,” in Quantifying Systemic Risk (University of Chicago Press, 2012), 29-61.

[10]Federal Deposit Insurance Corporation, 1933

[11]Federal Deposit Insurance Corporation. “The First Fifty Years: A History of the FDIC 1933-1983.” FDIC, 1984.

[12]Imad A. Moosa and Imad A. Moosa, “The Too Big to Fail Doctrine,” in The Myth of Too Big to Fail (2010), 1-18.

[13]Alan S. Blinder and Mark Zandi, How the Great Recession Was Brought to an End (West Chester, PA: Moody’s Economy.com, 2010).

[14] ibid

[15]Basel Committee on Banking Supervision. “Basel III: A Global Regulatory Framework for More Resilient Banks and Banking Systems.” Bank for International Settlements, December 2010.

[16] ibid

[17]Anat R. Admati, “Comment for the Treasury Select Committee Capital Inquiry” (2017).

[18] ibid

[19]Michael Taylor, “Redrawing the Regulatory Map: A Proposal for Reform,” Journal of Financial Regulation and Compliance 5, no. 1 (1997): 49-58.

[20] ibid

[21] ibid

[22]U.S. Securities and Exchange Commission. “Volcker Rule.” SEC, 2013.

[23]Financial Stability Board. “About the FSB.” FSB, 2021.

[24]ibid

[25]Board of Governors of the Federal Reserve System. “Stress Tests and Capital Planning.” Federal Reserve, 2021.

[26]Bank for International Settlements. “Basel III: International Regulatory Framework for Banks.” BIS, 2010.

[27]U.S. Government Publishing Office. “Dodd-Frank Wall Street Reform and Consumer Protection Act.” Public Law 111-203, 2010.

[28] Ibid

[29] ibid

[30]European Commission. “Banking Union.” EC, 2020.

[31] ibid

[32]Financial Stability Board (FSB), “List of Global Systemically Important Banks (G-SIBs),” Basel: Bank for International Settlements, 2019.

[33]FSB, FS, “List of Global Systemically Important Banks (G-SIBs),” (Bank for International Settlements, 2019).

[34] ibid

[35]Tarullo, Daniel K. “Regulatory Arbitrage, Risk Management, and Systemic Risk.” Journal of Financial Regulation, vol. 1, no. 1, 2015, pp. 28-38.

[36] ibid

[37]Anat Admati and Martin Hellwig, The Bankers’ New Clothes: What’s Wrong with Banking and What to Do About It (Princeton University Press, 2014).

[38] ibid

[39]Anat Admati and Martin Hellwig, The Bankers’ New Clothes: What’s Wrong with Banking and What to Do About It (Princeton University Press, 2014).

[40] ibid

[41]Luc Laeven and Fabian Valencia, “Systemic Banking Crises Database,” IMF Economic Review 61, no. 2 (2013): 225-270.

[42]Olivier De Jonghe and Özde Öztekin, “Bank Capital Management: International Evidence,” Journal of Financial Intermediation 24, no. 2 (2015): 154-177.

[43] ibid

[44]C. Baker and J. McArthur, “Is Dodd-Frank a Failure?” Journal of Financial Regulation and Compliance 22, no. 2 (2014): 101-113.

[45] ibid

[46]Jonathan R. Macey and Maureen O’Hara, “The Corporate Governance of Banks,” Economic Policy Review 9, no. 1 (2003).

[47] ibid

[48]J.P. Morgan Chase & Co. “Review of the Chief Investment Office’s Synthetic Credit Portfolio.” Company Public Report, 2013.

[49] ibid

[50]U.S. Department of the Treasury. “Treasury Announces Restructuring Plan for Citigroup.” 2009.

[51] ibid

[52]Financial Services Authority (UK). “The Failure of the Royal Bank of Scotland.” FSA Board Report, 2011.

[53] ibid

[54]B. S. Bernanke, “The Crisis and Policy Response, Speech at the Stamp Lecture, London School of Economics,” Board of Governors of the Federal Reserve System (2009).

[55]Luc Laeven and Fabian Valencia, “Systemic Banking Crises Database,” IMF Economic Review 61.2 (2013): 225-270.

[56]Dewatripont, Mathias, and Jean Tirole. The Prudential Regulation of Banks. Vol. 6. Cambridge, MA: MIT Press, 1994.

[57] ibid

[58]Joseph E. Stiglitz, Freefall: America, Free Markets, and the Sinking of the World Economy (WW Norton & Company, 2010).

[59]Andrew G. Haldane, “Control Rights (and Wrongs),” Economic Affairs 32, no. 2 (2012): 47-58.

[60]ibid

[61]Jeffrey N. Gordon and Wolf-Georg Ringe, “Bank Resolution in the European Banking Union: A Transatlantic Perspective on What It Would Take,” Colum. L. Rev. 115 (2015): 1297.

[62] ibid

[63]Joao AC Santos, “Commercial Banks in the Securities Business: A Review,” Journal of Financial Services Research 14, no. 1 (1998): 35-60.

[64] ibid

[65]J.P. Morgan Chase & Co. “2019 Annual Report.” J.P. Morgan Chase & Co., 2020.

[66] ibid

[67]Bank of America. “2019 Annual Report.” Bank of America, 2020.

[68] ibid

[69]Anil Kashyap, Raghuram Rajan, and Jeremy Stein, “Rethinking Capital Regulation,” in Maintaining Stability in a Changing Financial System 43171 (2008).

[70]Randall K. Quarles, “Liquidity Regulation and the Size of the Fed’s Balance Sheet,” Remarks at “Currencies, Capital, and Central Bank Balances: A Policy Conference,” Hoover Institution Monetary Policy Conference, Stanford University, Stanford, California, 2018.

[71]Anat R. Admati, “Comment for the Treasury Select Committee Capital Inquiry” (2017).

[72] ibid

[73]Mark J. Flannery, “Stabilizing Large Financial Institutions with Contingent Capital Certificates,” Quarterly Journal of Finance 6, no. 02 (2016): 1650006.

[74] ibid

[75]European Commission. “Banking Union: Single Resolution Fund.” EC, 2020.

[76] Pablo D’Erasmo, How Do Capital Requirements Impact Banking Sector Risk-Taking and Market Shares of Big and Small Banks? Federal Reserve bank, 6 Jan 2022. https://www.philadelphiafed.org/the-economy/banking-and-financial-markets/how-do-capital-requirements-impact-banking-sector-risks-taking . (Accessed on 25 0n November 2023)

[77] ibid

[78] Financial Institutions, “The Far-Reaching Implications of New Capital Requirements for US Banks”, August 9, 2023. https://www.bcg.com/publications/2023/implications-of-new-capital-requirements-for-us-banks . (Accessed on 25 0n November 2023)

[79] Anna Pinedo, Matthew Bisanz, Andrew Olmem, Jerry Marlatt and Jeffrey Taft, “Mayer Brown Discusses Bank Regulators’ Proposed Overhaul of Capital Requirements”, Columbia Law school, 10 August 2023. https://clsbluesky.law.columbia.edu/2023/08/10/mayer-brown-discusses-bank-regulators-proposed-overhaul-of-capital-requirements/ . (Accessed on 20 0n November 2023)

[80] Anita Hawser, Living Wills Improve Banks’ Crisis And Risk Management, Global Finance, 1 December 2011.

https://gfmag.com/banking/living-wills-improve-banks-crisis-and-risk-management/ . (Accessed on 25 0n November 2023)

[81] Ron J. Feldman, Forcing Financial Institution Change Through Credible Recovery/Resolution Plans: An Alternative to Plan-Now/Implement-Later Living Wills, Federal Reserve bank, 6 May 2010.

https://www.minneapolisfed.org/article/2010/forcing-financial-institution-change-through-credible-recoveryresolution-plans-an-alternative-to-plannowimplementlater-living-wills . (Accessed on 25 0n November 2023)

[82] Myriam Denis, “Five Major U.S. Banks’ Living Wills Fail to Pass Regulatory Muster”, Berkley Law, April 22, 2016.

https://sites.law.berkeley.edu/thenetwork/2016/04/22/five-major-u-s-banks-living-wills-fail-to-pass-regulatory-muster/ . (Accessed on 25 0n November 2023)

[83] Banking Exchange staff, “Regulators to expand on ‘living wills’ for banks”, Banking exchange, 10/05/2022.

https://www.bankingexchange.com/compliance/item/9443-regulators-to-expand-on-living-wills-for-banks . (Accessed on 25 0n November 2023)

[84]Martin Neil Baily, Douglas J. Elliott, and Phillip L. Swagel, “The Big Bank Theory: Breaking Down the Breakup Arguments”, Brookings, 31 October 2014. https://www.brookings.edu/articles/the-big-bank-theory-breaking-down-the-breakup-arguments/ . (Accessed on 25 0n November 2023)

[85] ibid

[86] David C. Wheelock, “Too Big To Fail: The Pros and Cons of Breaking Up Big Banks”, Federal Reserve Bank, October 01, 2012. https://www.stlouisfed.org/publications/regional-economist/october-2012/too-big-to-fail-the-pros-and-cons-of-breaking-up-big-banks . (Accessed on 25 0n November 2023)

[87] Aaron Klein, “Four questions to ask before breaking up the banks”, Brookings, 4 April 2016. https://www.brookings.edu/articles/four-questions-to-ask-before-breaking-up-the-banks/. (Accessed on 25 0n November 2023)