Similarly, systemic risks and too-big-to-fail problems can increase if large, highly leveraged firms may operate outside the perimeter of statutory microprudential oversight, as was the case prior to 2008 with the large, free-standing investment banks in the United States.
37 Cf., Federal Trade Commission, “Mary Engle Letter to Search Engine Providers (PDF),” n.4, June 24, 2013. 38 Cf., Federal Trade Commission, “The FTC’s Endorsement Guides: What People Are Asking ,” September 2017,  “.com Disclosures: How to Make Effective Disclosures in Digital Advertising (PDF),” March 2013.