Moreover, if and as other firms outside that perimeter grow so as to pose similar risks – whether because of the migration of risky activities from the regulated sector or for other reasons – it will be important to apply prudential standards and consolidated supervision in a timely fashion. Still, the tool of designating firms is a limited one.
The structure established by Congress itself suggests that the standard for designation should be quite high. Congress could, for example, have made every financial firm with more than $ billion in assets subject to prudential standards and consolidated supervision, but it chose not to do so.