Submission Under Consultation Process by the European Commission on the Structural Reform of the Banking Sector

This is a response to the European Commission proposed regulation to address Too Big To Fail (TBTF). TBTF is a function of interconnections and size, not just being a bank but also doing "bank-like" activities. Limiting the discussion to just banks will not result in an effective policy solution. Also the frame of analysis does not take into account systemic questions, Too Big To Fail not being the important question. Shadow banking and hedge funds can be outside the parameters for TBTF but they can be Too Systemic To Fail. This set of discussions does not take that into account. We discuss how interconnected banks have become over the last decade and the need for this set of regulations to be more wide ranging. This was part of the European Commission consultation