As Congress considers systemic-risk resolutions, two recent cases show exactly how to wind down big banking organizations without a bailout.

Some have argued that this means no systemic resolution authority is required. However, a close examination of the two cases — CIT and Capmark — shows how different they are from other large, complex banking organizations. Unless or until other banks are disentangled from their nonbanking affiliates, no large bank holding company could go into bankruptcy and leave an operating, viable insured depository.

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