The recent financial crisis demonstrated that, contrary to longstanding regulatory assumptions, nonbank financial firms -- such as investment banks and insurance companies -- can propagate systemic risk throughout the financial system. After the crisis, policymakers in the United States and abroad developed two different strategies for dealing with nonbank systemic risk. The first strategy seeks to regulate individual nonbank entities that officials designate as being potentially systemically important. The second approach targets financial activities that could create systemic risk, irrespective of the types of firms that engage in those transactions. In the last several years, domestic and international policymakers have come to view these two strategies as substitutes, largely abandoning entity-based designations in favor of activities-based approaches. This Article argues that this trend is deeply misguided because entity- and activities-based approaches are complementary tools that are each essential for effectively regulating nonbank systemic risk. Eliminating an entity-based approach to nonbank systemic risk -- either formally or through onerous procedural requirements -- would expose the financial system to the same risks that it experienced in 2008 as a result of distress at nonbanks like AIG, Bear Stearns, and Lehman Brothers. This conclusion is especially salient in the United States, where jurisdictional fragmentation undermines the capacity of financial regulators to implement an effective activities-based approach. Significant reforms to the U.S. regulatory framework are necessary, therefore, before an activities-based approach can meaningfully complement domestic entity-based systemic risk regulation.

Policymakers and program managers are continually seeking ways to improve accountability in achieving an entity's mission. A key factor in improving accountability in achieving an entity's mission is to implement an effective internal control system. An effective internal control system helps an entity adapt to shifting environments, evolving demands, changing risks, and new priorities. As programs change and entities strive to improve operational processes and implement new technology, management continually evaluates its internal control system so that it is effective and updated when necessary. Section 3512 (c) and (d) of Title 31 of the United States Code (commonly known as the Federal Managers' Financial Integrity Act (FMFIA)) requires the Comptroller General to issue standards for internal control in the federal government.

"The Fourth Edition of a leading resource in the field, this valuable practice tool brings you completely up-to-date on the evolving laws governing banks' securities activities - from regulatory changes in the financial markets and administrative reform to recent court decisions and legislative reform, including the recently enacted Sarbanes-Oxley Act of 2002 and the Gramm-Leach-Bliley Act. Here is everything you need to help build a bank's securities business while avoiding compliance pitfalls. Securities Activities of Banks, Fourth Edition provides: In-depth discussions of the securities activities now permissible for banks, bank holding companies, and financial holding companies, Clear explanations of how securities laws affect banks' securities activities, A complete review of how banks are regulated - including foreign banks and affiliates, Up-to-date analysis of the evolution of the banking laws through agency and court decisions. Detailed descriptions and analyses illuminate the full range of current bank securities activities, including investment and trading activities, brokerage activities, investment advice, underwriting, mutual funds, international securities activities, derivative instruments, deposits and loans, fiduciary activities, and more."--Publisher's website.