Did the Dodd-Frank Act End ‘Too Big to Fail’?
One goal of the Dodd-Frank Act of 2010 was to end “too big to fail.” Toward that goal, the Act required systemically important financial institutions to submit detailed plans for an orderly resolution (“living wills”) and authorized the FDIC to create an alternative resolution procedure. In response, the FDIC has developed a “single point of entry” (SPOE) strategy, under which healthy parent companies bear the losses of their failing subsidiaries. Since SPOE makes the parent company responsible for subsidiaries’ losses, we would expect parents to become riskier, relative to their subsidiaries, compared to before the announcement of the SPOE strategy in December 2013. Do bond raters and investors share this view?