id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-18348	Herzig, David J	Review of Current Scholarship on the Fiscal Cliff	2015	15	.pdf	application/pdf	6829	380	58	In their recent article, Saule Omarova and Adam Feibelman, discuss a “three- peak” structure changing the scope of regulators in the industry.49 However, under this model, the agencies would not split up tasks vertically based on subject matter of regulation, as Yadav proposes.50 Instead, the agencies’ scope would be determined horizontally, based on different markets.51 One agency would regulate and supervise the wide variety of retail financial service providers and markets.52 A smaller, more nimble agency would regulate the wholesale financial services providers and markets in complex financial instruments.53 These two agencies would aim at ensuring safety and soundness of financial institutions and 40. The institutional or function approach would split up agencies to regulate based on the function of the institution, which is basically the current structure in the United States.57 An integrated regulatory structure would give regulatory and supervisory power to one single super agency.58 Lastly, a twin-peak approach would divide responsibilities between a prudential regulator of the safety and soundness of financial institutions, and a market conduct regulator.59 Omarova and Feibelman ultimately decide that regardless of the specific structure, first the government needs to decide what and whom should be regulated as well as why and how regulation should occur.60	cache/inlawrev-18348.pdf	txt/inlawrev-18348.txt