For one who has been a participant in and an observer of the deregulation wars for almost 20 years, it is almost amusing to watch the course of the debate about whether deregulation should occur through subsidiaries of a bank holding company or through subsidiaries of the bank itself.

In the fall of 1981 the Treasury Department proposed that bank holding companies be permitted to engage through subsidiaries in insurance and securities underwriting. The proposal, first made by Secretary Donald Regan in testimony before the Senate Banking Committee, was a fairly radical idea at the time, since the big issue then before Congress was whether banks- which were permitted by the Glass-Steagall Act to engage in underwriting and dealing in municipal general obligation bonds-should also be permitted to underwrite and deal in municipal revenue bonds. It might seem a minor distinction now, but it kept a lot of smart people employed.

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