While the changes in the status of the formerly free-standing investment banks have removed one important set of firms that fell outside the boundary of prudential regulation, there will surely be other such systemically important firms in the future.
Moreover, it is important to foreclose the possibility that firms might move into BHC status during periods of financial stress and reverse that status in order to escape regulation in calmer times. Second, there should be a resolution regime for systemically important non-bank institutions to complement the current regime for banks under the Federal Deposit Insurance Act.