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The Wall Street Reform and Consumer Protection Act of 2009 (the “House bill”) and the Restoring American Financial Stability Act of 2010 (the “Senate bill”; and together with the House bill, the “Legislation”) both contain a requirement that large financial firms that do not own banks (“NonBHCs”) should be regulated as if they were bank holding companies (“BHCs”). https://www.cadwalader.com/resources/clients-friends-memos/some-concerns-with-the-regulation-of-large-non-bank-holding-companies