What Silicon Valley Bank’s collapse means for private equity

What Silicon Valley Bank’s collapse and bailout mean for private equity, and how regulators can prevent a future crisis

Silicon Valley Bank collapsed on March 10, 2023 following a dramatic bank run. Regulators had to step in to contain the crisis, shutting it down and naming the Federal Deposit Insurance Corporation (FDIC) as the receiver. This was the second largest bank failure in American history.^[1]

The collapse of SVB was proximately caused by the bank run following interest rate hikes from the Federal Reserve, risky behaviors by both the bank and some of its depositors, and the rollback of regulations that could have prevented many of these risky behaviors and their accompanying systemic risks in the first place. We will explore in greater detail why the bank collapsed, how and why the bank was bailed out, and how private equity firms may be impacted. We’ll close with forward-looking policy recommendations that could prevent and deter the risky behaviors that produced this crisis, as well as address the risks of private equity’s potential growing influence in private lending in the wake of SVB’s closure.

Why did SVB collapse?

Silicon Valley Bank (SVB) was the 16^th largest bank in the United States,^[2] with approximately $209 billion in total assets and $175.4 billion in deposits as of December 2022.^[3] SVB’s footprint within the private equity, venture capital and startup world was substantial; by its own assessment, approximately 50% of all US venture capital (VC)-backed tech and life sciences banked with SVB, and about 44% of US VC-backed companies with an initial public offering (IPO) in 2022 were SVB clients.

According to VICE, SVB’s “rising dominance” was due to how it marketed and catered toward the venture class and founders:

“In SVB, Silicon Valley founders and VCs had found a rare partner who was willing to provide credit cards and venture debt to startups with no revenue, and otherwise accept the risk inherent in banking startups. More than that though, SVB made a business out of supporting—critics might say coddling—the venture class and founders themselves, helping them to buy homes when they couldn’t get a mortgage elsewhere.”^[4]

A whopping 94% of the domestic deposits held at SVB were above the $250,000 threshold that FDIC insures. For comparison, 47% of deposits are not federally insured for most large banks.^[5] The hyper-concentration of startups banking with SVB with uninsured deposits further compounded the systemic risks associated with the bank’s collapse.

As David Dayen pointed out in The American Prospect, SVB had failed to manage interest rate risks related to its disproportionate amount of assets in long-term government and mortgage securities.^[6] The bank had poor risk management more generally: both Fed officials and BlackRock consultants had flagged issues and poor risk controls at least a year prior.^[7] Dayen suggests that many depositors also had poor risk management or “were bribed by the bank into neglecting it.”^[8]

Even though bank executives and the government had knowledge of major issues brewing at the bank, neither took action to proactively prevent the crisis that ultimately transpired.^[9] In fact, SVB and other banks had lobbied successfully in years prior to roll back Dodd-Frank regulations for banks with assets under $250 million. This lobbying culminated into a deregulatory bill (Senate Bill 2155) that 50 Republicans and 17 Democrats in the Senate supported and former President Trump signed into law in 2018.^[10]

Many commentators and journalists have pointed out that SVB lobbied to be treated as a bank that did not pose systemic risks; yet the federal government invoked the systemic risks posed by SVB’s collapse when it took action to bail out all depositors (even those above the $250,000 threshold) to contain the crisis and prevent a larger banking collapse.^[11]

The “bailout”

The FDIC and federal government moved quickly to address the collapse of SVB (and a separate bank, Signature Bank, that was close behind). After taking control of SVB,^[12] the FDIC transferred all of its deposits, and a substantial amount of its assets, to a newly created, full-service FDIC-operated ‘bridge bank’ dubbed the Silicon Valley Bridge Bank.^[13]

Although the significant majority of SVB deposits were above the $250,000 FDIC-insured threshold, the FDIC announced that all of SVB’s depositors would be made whole.^[14] This decision was supported by many policymakers who warned of potential instability to the financial system if depositors could not recoup funds beyond the insurance threshold.^[15] However, other stakeholders like SVB’s shareholders, senior management and certain unsecured debtholders would not be protected from losses.^[16]

Though SVB’s collapse and bailout remind many of the 2008 Global Financial Crisis, this situation is a bit different in that the funds used to guarantee SVB’s deposits come from assessments paid to the FDIC by banks. In fact, the Biden administration has refused to call the FDIC’s actions a “bailout,” arguing that the difference between now and 2008 is that the FDIC is not using taxpayer funds to guarantee SVB’s deposits^[17] (compared to $245 billion of taxpayer money in 2008).^[18]

Experts disagree on whether the guarantee will still be passed onto consumers through their lending institutions,^[19] but only time will tell. The bailout certainly helped stabilize the situation and protect depositors, including private equity and venture capital firms, but much remains in motion in terms of the longer-term fallout from SVB’s collapse.

Private Equity’s exposure to Silicon Valley Bank

Much ink has been spilled about what Silicon Valley Bank’s collapse means for venture capital and startups. Here, we’ll take a closer look at what it means for private equity firms and funds who banked with SVB and/or may go on to fill some of the gaps created by its collapse.

Shortly after SVB’s collapse, Fortune reported that “SVB, which was the financial institution of choice by an estimated 50% of all startups, also custodied assets for some 1,074 private equity and venture capital funds in recent years.” The article linked to Castle Hall Diligence’s dataset compiled from public annual SEC filings, which provides an approximation of the exposure private equity (PE) and venture capital (VC) firms had to the bank before it collapsed.^[20]

According to Fortune, these data demonstrate that SVB was a major lender to private equity and venture capital funds and raise the question as to whether PE and VC’s hyper-concentrated exposure to the bank was a liability that SVB did not account for in its risk management.^[21] Had SVB not been bailed out by the federal government, private equity and venture capital firms, as well as other types of depositors, could have taken major losses.

On the day of the bank collapse, researcher Dr. Eileen Appelbaum pointed out on Twitter that one of the ways PE firms used SVB was for subscription line loans that can be used to inflate a fund’s internal rate of return (IRR).

Subscription lines of credit, or “credit facilities,” are used by private equity funds to make investments without having to call capital from a fund’s limited partners or apply for a new loan each time. Credit facilities are agreements that allow firms to borrow funds as needed, usually without having to state a particular purpose for the use of the funds, under flexible terms generally not applicable to ordinary loans.^[22]

For example, some defining features of a credit facility include variable interest rates, draw down and repayment flexibility, and loan covenants related to the collateral (usually a portfolio company’s assets). This flexibility allows general partners to acquire companies with borrowed funds, which can result in an inflated IRR due to profit realization that appears to be earlier in the life of an investment.^[23] According to the Institutional Limited Partners Association, PE firms’ use of credit facilities potentially pose issues for limited partners related to artificially inflated returns, carried interest clawbacks, expenses and liquidity risks, among others.^[24]

Due to the risky nature of credit facilities, lenders in such situations usually have an established business relationship with the borrowers, and such borrowers are usually return clients. SVB was such a lender, and subsequent to its collapse various insiders explained how given its status as a credit facility for small and mid-market private equity firms, those firms had to scramble to find financing for investments for which they had not intended to call capital.^[25]

Potential Impacts of SVB’s collapse for Private Equity

Perhaps one of the most immediate impacts of SVB’s collapse for private equity is the newly created lending gap. PE firms that used SVB for subscription line loans and other types of financing will need to find alternative lenders.

According to Buyouts, SVB’s global fund banking loan portfolio totaled about $41 billion as of December 2022. The vast majority of the PE and VC loan portfolio was tied up in capital call lines of credit.”^[26] As such, PE firms as well as their limited partners were anticipating disruptions to their capital call financing and searching for new lenders even prior to the bank’s official collapse.^[27]

But some PE firms have also seen SVB’s collapse as an opportunity to expand their private credit businesses, or even acquire SVB’s lending side of its business.^[28]Bloomberg reported that as of March 13, Apollo, Blackstone, Carlyle, and KKR were all “eyeing a slice” of SVB’s $74 billion loan book.^[29] However, the FDIC ultimately approved the sale of SVB’s assets (including its loan book) and liabilities to First Citizens Bank, a mid-sized regional bank based out of North Carolina.^[30] It remains to be seen whether former SVB clients will elect to take out new loans with First Citizens, or if they will transition to using larger banks or alternative lenders. With SVB out of the picture, nonbank lenders, like PE firms, can potentially descend onto the private equity and venture debt market.^[31]

Although large PE firms were unable to purchase SVB’s loan book assets, these firms may still benefit from new clients created through the vacuum generated by SVB’s collapse. Large firms like Blackstone, KKR, and Apollo, according to Bloomberg, “have become a force in capital markets, often carrying enough weight to make or break multibillion-dollar acquisitions.”^[32] Some critics have argued that private credit lenders can and do artificially inflate valuations for their benefit.^[33]

More broadly, a greater reliance on private lenders over traditional banks in our economy is cause for concern, given that private lenders are not as closely regulated as banks—David Scigliuzzo of Bloomberg describes private credit as “one of the most opaque corners of Wall Street.”^[34]

Clearly, regulations were insufficient to save SVB from itself, but as a bank it was subjected to more transparency requirements and regulations than the private credit arm of a PE firm is. The federal government ultimately stepped in to protect depositors who suffered the consequences of SVB’s poor risk management. There are no such protections for pension funds or other institutional investors whose funds are being deployed by private credit arms of PE firms in potentially risky ways.

Private equity is increasingly investing in the private credit business,^[35] and SVB’s collapse and widespread distrust of banks could amplify this trend further. As private equity’s incursion into private credit deepens, there is the potential for major losses for institutional and retail investors should there be a string of borrower defaults.

As large PE firms work to corner a greater share of the private credit market, this could also generate more high-profile disputes in restructuring transactions for distressed companies. Larger, better resourced private creditors have the potential to outcompete and even harm smaller, less well-capitalized lenders through questionably legal debt restructurings.^[36] This could eventually lead to increased consolidation in the private lending sector, and therefore outsized power and influence for the biggest private lenders.

In summary, private equity firms have certainly been impacted by SVB’s collapse. At the minimum, funds experienced disruptions around subscription line financing and access to deposits. But ultimately funds and firms with assets in the bank, regardless of size, have been bailed out. It appears PE might see more opportunities than losses from SVB’s collapse, especially for private equity firms hoping to build out their private lending businesses. While much uncertainty remains around whether a larger banking crisis is contained, for now it appears private equity firms and funds have emerged relatively unscathed.

Conclusion and policy recommendations

SVB’s collapse and the associated guaranteed bailout for all depositors demonstrate that systemic risk has been permitted and arguably even encouraged through policymakers’ collective failure to sufficiently regulate our banking system. In such a risk-prone system, big-time players like private equity firms can emerge unscathed, even if originally exposed to risks through excessive use of leverage and relationships with banks like SVB. They can also even gain new customers for their private credit businesses.

A bailout that is accompanied by no new banking regulations to prevent this situation from happening again may incentivize more of the same risky behaviors on the part of the banks, investors, and companies that led to this crisis in the first place.

Recent history shows us that when financial crises occur, Wall Street is rescued immediately in the name of protecting everyone. But as we’ve seen in the past decade or so, bailouts for the financial sector have exacerbated the upward redistribution of wealth that has led to increasing economic inequality.^[37] And yet, bailouts are arguably needed to prevent an even worse outcome.

Our government has taken a reactive approach to the failures of our financial system that often necessitates bailouts for large financial institutions that knowingly took risks they failed to manage. However, there is opportunity for policymakers to take a proactive approach that involves robust regulations, as well as the resources to enforce those regulations.

First, we need a return to strong banking regulations. At the very least, our legislators need to re-regulate the banking industry after the deregulation that occurred in 2018 that directly contributed to this crisis.

As previously mentioned, the Republican-controlled Congress in 2018 repealed key provisions of Dodd-Frank through Senate Bill 2155.^[38] Among other things, this bill increased the asset threshold at which company-run stress tests are required from $10 billion to $250 billion, a change that SVB lobbied for in a 2015 Senate Banking, Housing and Urban Affairs Committee hearing.^[39]

SVB’s total assets were $209 billion at the time of its collapse, well below the new regulatory floor for banks that are “too big to fail,” but more than four times the amount of the previous threshold.^[40] Although it is too early to capture all the issues that led to SVB’s collapse with absolute certainty, the fact that it was able to avoid regulatory scrutiny due to the weakening of Dodd-Frank should alert policymakers to the possibility that such changes led to this outcome.

Restoring the parts of Dodd-Frank gutted under the Trump administration could help prevent future collapses like SVB’s. However, policymakers should also look towards restoring the 1933 Glass-Steagall Act. Implemented during the Great Depression, it was successful in preventing bank failures and large-scale financial crises. However, financial industry lobbying overtime led to its hollowing out and major consolidation in the banking industry, which some have argued has contributed to greater volatility and propensity for crisis within our banking system.^[41]

Policymakers should also review the growing role of private lenders not subject to such regulation. As this is an unregulated and opaque space, policymakers should consider ramping up transparency requirements and regulations for private lenders to avert new types of crises.

Policy recommendations include:

• Restoring the Dodd-Frank “too big to fail” asset threshold to $50 billion, from its current threshold of $250 billion. Capturing middle-market lending activity is essential to preventing more precarity in the financial system. Since banks like SVP provide credit facilities and other sophisticated lending agreements like their larger borrowers, disruptions in their lending activity can potentially send shockwaves through other sectors (such as companies in a private equity fund’s portfolio) and thus should be more strictly monitored.
• Restoring the separation of commercial and investment banking activity under Glass-Steagall. Reestablishing clear legal distinctions between commercial and investment banks could reduce the occurrence of risky investment practices at the former. However, it is unclear that restoring this part of Glass-Steagall alone would have prevented SVB’s failure.[42]
• Increasing funding for the relevant regulatory bodies. To effectively monitor and troubleshoot issues in the financial system, regulatory agencies need to be funded and staffed to levels that are adequate to provide for a more robust regulatory environment.
• Establishing a percentage of deposits above which commercial banks are prohibited from accepting uninsured deposits. Part of the systemic risk that SVB’s high percentage (88% at the time of the collapse)[43] of uninsured deposits presented was the likelihood of bank runs by uninsured depositors crippling the bank’s solvency. Requiring a limit (such as a mandatory ratio of insured deposits to uninsured deposits) on such uninsured deposits could possibly mitigate the negative financial consequences of low consumer confidence in uninsured depositors. Additionally, policymakers could consider authorizing a special assessment on uninsured deposits to help fund the FDIC’s ability to cover the risks associated with those deposits.
• Subject private lenders to greater transparency requirements and regulations to ensure their lending practices cannot produce a new set of financial crises. Part of the difficulty in identifying regulatory gaps in private lending is that private firms are subject to much less regulatory transparency than their banking counterparts. Therefore, as private firms continue to enter the private credit market, policymakers should ensure such firms are subject to the same disclosures that allow for sound regulation of ordinary financial institutions.

[1] Pound, Jesse. “Silicon Valley Bank Is Shut down by Regulators in Biggest Bank Failure since Global Financial Crisis.” CNBC, March 10, 2023. https://www.cnbc.com/2023/03/10/silicon-valley-bank-is-shut-down-by-regulators-fdic-to-protect-insured-deposits.html.

[2] Primack, Dan. “Silicon Valley Bank’s Political Blame Game.” Axios, March 21, 2023. https://www.axios.com/2023/03/21/silicon-valley-bank-failure-dems-republicans.

[3] Pound, Jesse. “Silicon Valley Bank Is Shut down by Regulators in Biggest Bank Failure since Global Financial Crisis.” CNBC, March 10, 2023. https://www.cnbc.com/2023/03/10/silicon-valley-bank-is-shut-down-by-regulators-fdic-to-protect-insured-deposits.html.

[4] Strachan, Maxwell. “How Silicon Valley Bank Made a Business Out of Making VCs Happy.” Vice, March 16, 2023. https://www.vice.com/en/article/pkayyg/how-silicon-valley-bank-made-a-business-out-of-making-vcs-happy.

[5] Watson, Kathryn, and Sarah Ewall-Wice. “What to Know about Bank Deposits and the FDIC Deposit Insurance Fund.” Cbsnews.Com, March 16, 2023. https://www.cbsnews.com/news/silicon-valley-bank-signature-bank-deposits-fdic-deposit-insurance-fund-president-joe-biden/.

[6] Dayen, David. “The Silicon Valley Bank Bailout Didn’t Need to Happen.” The American Prospect, March 13, 2023. https://prospect.org/economy/2023-03-13-silicon-valley-bank-bailout-deregulation/.

[7] Dayen, David. “The Fed’s Silicon Valley Bank Cover-Up Won’t Work.” The American Prospect, March 21, 2023. https://prospect.org/economy/2023-03-21-fed-supervision-silicon-valley-bank/.

[8] Dayen, David. “The Silicon Valley Bank Bailout Didn’t Need to Happen.” The American Prospect, March 13, 2023. https://prospect.org/economy/2023-03-13-silicon-valley-bank-bailout-deregulation/.

[9] Dayen, David. “The Fed’s Silicon Valley Bank Cover-Up Won’t Work.” The American Prospect, March 21, 2023. https://prospect.org/economy/2023-03-21-fed-supervision-silicon-valley-bank/.

[10] Burns, Rebecca, David Sirota, Julia Rock, and Andrew Perez. “SVB Chief Pressed Lawmakers To Weaken Bank Risk Regs.” The Lever, March 10, 2023. https://www.levernews.com/svb-chief-pressed-lawmakers-to-weaken-bank-risk-regs/.

[11] Dayen, David. “The Fed’s Silicon Valley Bank Cover-Up Won’t Work.” The American Prospect, March 21, 2023. https://prospect.org/economy/2023-03-21-fed-supervision-silicon-valley-bank/; Kolhatkar, Sheelah. “Silicon Valley Bank and the Dangers of Magical Thinking.” The New Yorker, March 20, 2023. https://www.newyorker.com/business/currency/silicon-valley-bank-and-the-dangers-of-magical-thinking; Ongweso, Jr., Edward. “The Incredible Tantrum Venture Capitalists Threw Over Silicon Valley Bank.” Slate, March 13, 2023. https://slate.com/technology/2023/03/silicon-valley-bank-rescue-venture-capital-calacanis-sacks-ackman-tantrum.html.

[12] Federal Deposit Insurance Corporation (FDIC), “FDIC Creates a Deposit Insurance National Bank of Santa Clara to Protect Insured Depositors of Silicon Valley Bank, Santa Clara, California.” March 10, 2023, https://www.fdic.gov/news/press-releases/2023/pr23016.html.

[13] FDIC, “FDIC Acts to Protect All Depositors of the former Silicon Valley Bank, Santa Clara, California.” March 13, 2023, https://www.fdic.gov/news/press-releases/2023/pr23019.html.

[14]Id.

[15] Popli, Nick. “Silicon Valley Bank Clients Will Get Funds—Even Those That Weren’t Insured, Government Says.” Time, March 12, 2023, https://time.com/6262143/silicon-valley-bank-bailout-yellen/.

[16] FDIC, supra note 13.

[17] Gangitano, Alex. “Biden stresses that Silicon Valley Bank is not getting a bailout.” The Hill, March 13, 2023, https://thehill.com/homenews/administration/3897534-biden-stresses-that-silicon-valley-bank-is-not-getting-a-bailout/#:~:text=President%20Biden%20on%20Monday%20stressed,be%20borne%20by%20the%20taxpayers.

[18] U.S. Department of Treasury, “Bank Investment Programs.” Last accessed April 24, 2023, https://home.treasury.gov/data/troubled-assets-relief-program/bank-investment-programs.

[19] Reynolds, Nick. “Are Taxpayers on the Hook for Silicon Valley Bank Bailout?” Newsweek, March 14, 2023, https://www.newsweek.com/are-taxpayers-hook-silicon-valley-bank-bailout-1787769.

[20] Sternlicht, Alexandra, and Jessica Mathews. “More than 1,000 VC, PE, and Investment Firms Held Capital at SVB in 2022.” Fortune, March 12, 2023. https://fortune.com/2023/03/12/venture-firms-custodied-silicon-valley-bank/.

[21] Sternlicht, Alexandra, and Jessica Mathews. “More than 1,000 VC, PE, and Investment Firms Held Capital at SVB in 2022.” Fortune, March 12, 2023. https://fortune.com/2023/03/12/venture-firms-custodied-silicon-valley-bank/.

[22] Farr, Jonathan. “GPs Take ‘Credit’ for Higher IRRs.” Callan, July 29, 2021, https://www.callan.com/blog-archive/subscription-credit-facilities/.

[23] Chen, James. “What Is a Credit Facility, and How Does It Work?” Investopedia, June 3, 2023, https://www.investopedia.com/terms/c/creditfacility.asp#toc-what-is-a-credit-facility.

[24] Institutional Limited Partners Association, “Subscription Lines of Credit and Alignment of Interests: Considerations and Best Practices for

Limited and General Partners.” June, 2017, pg. 2, https://ilpa.org/wp-content/uploads/2020/06/ILPA-Subscription-Lines-of-Credit-and-Alignment-of-Interests-June-2017.pdf.

[25] Witkowsky, Chris. “SVB Collapse Disrupts Capital Call Process, Forces GPs to Scramble for New Banks.” Content. Buyouts (blog), March 10, 2023. https://www.buyoutsinsider.com/svb-collapse-disrupts-capital-call-process-forces-gps-to-scramble-for-new-banks/.

[26]Id.

[27]Id.

[28] Lee, Lisa, and Jan-Henrik Foerster. “Apollo, Blackstone and KKR Said to Circle SVB’s Loan Assets.” Bloomberg.Com, March 13, 2023. https://www.bloomberg.com/news/articles/2023-03-13/apollo-eyes-svb-assets-as-suitors-circle-73-6-billion-loan-book; Primack, Dan. “Silicon Valley Is Working with Wall Street to Buy Some SVB Assets.” Axios, March 15, 2023. https://www.axios.com/2023/03/15/silicon-valley-is-working-with-wall-street-to-buy-some-svb-assets.

[29] Lee, Lisa, and Jan-Henrik Foerster. “Apollo, Blackstone and KKR Said to Circle SVB’s Loan Assets.” Bloomberg.Com, March 13, 2023. https://www.bloomberg.com/news/articles/2023-03-13/apollo-eyes-svb-assets-as-suitors-circle-73-6-billion-loan-book.

[30] The Associated Press. “The FDIC Says First Citizens Bank Will Acquire Silicon Valley Bank.” NPR, March 27, 2023, sec. Business. https://www.npr.org/2023/03/27/1166180710/first-citizens-bank-to-acquire-silicon-valley-bank.

[31] Shi, Madeline, and Jessica Hamlin. “Nonbank Lenders Pounce on Venture Debt Market after SVB Collapse | PitchBook.” PitchBook (blog), March 14, 2023. https://pitchbook.com/news/articles/venture-debt-lenders-silicon-valley-bank.

[32] Scigliuzzo, David. “Private Credit Muscles Out Banks, With Worrisome Consequences.” Bloomberg.Com, January 13, 2023. https://www.bloomberg.com/news/articles/2023-01-13/what-is-private-credit-industry-poses-regulatory-risks.

[33]Id.

[34]Id.

[35]Id.

[36] Proskauer. “Liability Management – Vaccine or Pandemic? Private Credit Restructuring Year in Review – Insights – Proskauer Rose LLP.” Accessed March 21, 2023. https://www.proskauer.com/report/private-credit-restructuring-year-in-review.

[37] Landy, Benjamin. “A Tale of Two Recoveries: Wealth Inequality After the Great Recession.” The Century Foundation, August 28, 2013. https://tcf.org/content/commentary/a-tale-of-two-recoveries-wealth-inequality-after-the-great-recession/; Puzzanghera, Jim. “A Decade after the Financial Crisis, Many Americans Are Still Struggling to Recover.” Los Angeles Times, September 9, 2018, sec. Business. https://www.latimes.com/business/la-fi-financial-crisis-middle-class-20180909-htmlstory.html.

[38] S.2155 – 115th Congress (2017-2018): Economic Growth, Regulatory Relief, and Consumer Protection Act, S.2155, 115th Cong. (2018), https://www.congress.gov/bill/115th-congress/senate-bill/2155.

[39]Id.

[40] Schwartz, Brian. “Silicon Valley Bank ex-CEO backed Big Tech lobbying groups that targeted Dodd-Frank, sought corporate tax cuts.” CNBC, March 16, 2023, https://www.cnbc.com/2023/03/16/silicon-valley-bank-ex-ceo-greg-becker-backed-big-tech-lobbying-groups.html.

[41] Chouliara, Despina. “The Financial Services Modernization Act of 1999,” April 25, 2020. https://predatorylending.duke.edu/policy/legislative-memos/the-financial-services-modernization-act-of-1999/; “Mr. Weill Goes To Washington – The Long Demise Of Glass-Steagall | The Wall Street Fix | FRONTLINE | PBS.” Accessed March 27, 2023. https://www.pbs.org/wgbh/pages/frontline/shows/wallstreet/weill/demise.html.

[42] Nicholson, Jonathan. “Janet Yellen Leaves The Door Open On Reviving Depression-Era Bank Law.” Huffington Post, March 16, 2023, https://www.huffpost.com/entry/yellen-glass-steagall_n_64136877e4b0bc5cb64f3ecb.

[43] Barr, Alistair. “Silicon Valley Bank is a particularly scary failure. Here’s why.” Business Insider, March 10, 2023, https://www.businessinsider.com/silicon-valley-bank-svb-particularly-scary-bank-failure-why-2023-3#:~:text=At%20the%20end%20of%202022,didn’t%20have%20FDIC%20insurance.