Although the industry's track record with Dodd-Frank implementation is hardly noteworthy, its war game to test regulators' new powers to seize and dismantle a megabank is not only fascinating, it's exemplary.

The Clearing House Association, a trade group made up of the 18 largest banks, spent 10 months and $2 million to plan a simulation of a large bank failure, a bold and massive undertaking.

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