http://ewallstreeter.com/chris-whalen-recommends-chapter-bankruptcy-for-bank-of-america-default-and-liquidation-under-dodd-frank-9640/#

1:14pm - September 1, 2011

Chris Whalen - Institutional Risk Analytics A not so fictional FSOC memo for Bank of America Default and Liquidation under Dodd-Frank Under the provisions of the Dodd-Frank legislation, the FSOC may appoint the FDIC as receiver if the Secretary determines any covered company "is in default or in danger of default," but the FSOC does not need to act if there are alternatives. It is clear from both the provisions of Dodd-Frank and the Congressional record that a private solution ought be the first choice. In view of the fact that the subsidiary banks of BAC are still book solvent and that the primary issue facing BAC arises from the legacy liabilities of the parent, and not of the subsidiary banks and broker dealer, our recommendation is a commercial Chapter 11 reorganization under the federal bankruptcy code, with the full acquiescence and cooperation of the FDIC