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Sheila Bair, never too shy to make modest proposals, thinks that JPMorgan Chase should voluntarily split itself up:
[The] bank is worth more in smaller, easier-to-manage pieces. Let's face it, making a competitive return on equity is going to become even harder for megabanks as their capital requirements go up, their trading and derivatives activities are reined in, and their cost of borrowing rises as bond investors recognize that too-big-too-fail is over.
Or, as David Merkel puts it in a different context: "complexity has a price; avoid it unless well compensated for it". And, Felix notes, setting the Volcker Rule aside, if a business requires complexity and opacity to generate profit, it should be spun out of too-big-to-fail institutions. That would be a complex task, but things only grow murkier once a firm has failed.
The FDIC continues to clarify its resolution authority and currently thinks the best method to handle the failure of a large, complex financial institution is to place the "parent company into receivership and to pass its assets, principally investments in its subsidiaries, to a newly created bridge holding company". Stephen Lubben doubts that the hundreds of billions of dollars in private debtor-in-possession financing required for a tidy resolution to work would be available during a financial crisis.