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3 posts on "boundaries of the firm"
July 17, 2026

Nonbank Subsidiaries and the Hidden Fragility of Internal Capital Markets Reallocation

AI generated image of a glass square vessel with glass squares and pyramid inside with the words Bank Holding Company on the large vessel and insurer, fintech and broker-dealer on the small glass items inside it.

This post concludes a three-part series on how bank regulation interacts with the organizational structure of banking firms. The first post documented the equity-rich nonbank subsidiaries inside bank holding companies (BHCs); the second post showed that BHCs met Basel III by reallocating capital internally, moving equity from nonbank affiliates to bank subsidiaries rather than raising new external capital. Here we ask what that reallocation meant for financial stability. The series draws on the authors’ recent Staff Report, “Regulatory Arbitrage Within the Firm.”

July 16, 2026

How Basel III Changes Where Capital Sits: Nonbank Subsidiaries as Equity Reservoirs

AI generated image of a glass square vessel with glass squares and pyramid inside with the words Bank Holding Company on the large vessel and insurer, fintech and broker-dealer on the small glass items inside it.AI generated image of a glass square vessel with glass squares and pyramid inside with the words Bank Holding Company on the large vessel and insurer, fintech and broker-dealer on the small glass items inside it.

This post is the second in a three-part series on how bank regulation interacts with the organizational structure of banking firms. The first post documented that nonbank subsidiaries inside bank holding companies (BHCs) are large, equity-rich “reservoirs,” and that bank-level capital diverged sharply from consolidated capital after Basel III took effect in 2015. This post asks why, and traces the answer through the internal plumbing of the holding company. The series draws on the authors’ recent Staff Report, “Regulatory Arbitrage Within the Firm.”

July 15, 2026

Capitalizing on Nonbanks: Regulatory Arbitrage Within Bank Holding Companies

AI generated image of a glass square vessel with glass squares and pyramid inside with the words Bank Holding Company on the large vessel and insurer, fintech and broker-dealer on the small glass items inside it.

This post is the first in a three-part series on how bank regulation interacts with the organizational structure of banking firms. The series draws on the authors’ recent Staff Report, “Regulatory Arbitrage Within the Firm.”

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