Exploring the Implications of Regulations on Banking: The Rise of Shadow Banks

By: Alexis Cohen
Volume X – Issue II – Spring 2025

I. INTRODUCTION

In 2021, Vista Equity Partners, a private equity firm that invests in software and technology businesses, acquired Pluralsight—a cloud-based platform that provides learning solutions for IT professionals—for $3.5bn. Of the purchase price, $1.2bn was financed by private credit lenders through recurring revenue term loans, and another $300mm came from public loans. Annual recurring revenue (ARR) term loans are debt financing for subscription-based platforms or businesses with a predictable, recurring revenue stream. Following Vista Equity Partners' leveraged buyout (LBO) of this business, Pluralsight transitioned from a growth to a mature company. One of the byproducts of being further along the company lifespan—which is, admittedly, hard to predict—was slower revenue growth. Nevertheless, Pluralsight was able to maintain its EBITDA margins due to cost-cutting measures. Since the capital restructuring from the acquisition, Pluralsight has plunged into financial distress as a direct result of high leverage amidst a deteriorating macroeconomic credit environment despite operating an otherwise stable business.

The financial strain on Pluralsight was accelerated by an immense rise in interest rates. When the Secured overnight financing rate (SOFR) increased from 0.5% to 5.5%—which almost universally affects the cost of any debt issuances—between 2021 and 2024, Pluralsight's interest coverage ratio (EBIT / Interest Expense) plunged below one from the drastically heightened interest expenses. Their situation looked dire not only from an income statement perspective but also from a cash flow perspective; Pluralsight burned $70mm of cash in 2023. Even though certain financials had relatively improved since the buyout, the slight turnaround proved insufficient to service the $1.2bn in debt obligations issued at a time of lower interest rates. In 2023, after Vista Equity Partners infused $75mm of equity into Pluralsight, Pluralsight then effectuated an intellectual property (IP) transfer from ParentCO into a non-guarantor restricted subsidiary. Transferring IP into a different subsidiary would allow for the use of these assets as a form of collateral to back loans—this is typically at the expense of existing debtholders and is an act of last resort. This transfer was the first significantly-sized liability management transaction (LMT) done within the private market. As private lenders’ loans were no longer guaranteed, Pluralsight was able to raise $170mm from the existing lenders, though this, too, was insufficient. Private credit lenders, including Blue Owl, Ares Management, Oaktree Capital, and Blackrock then agreed to take 85% ownership of Pluralsight and agreed to convert their debt into new equity, reducing the total debt outstanding by around $1.2bn. Vista Equity Partners wrote down their entire equity investment.

The company in question, Pluralsight, primarily capitalized by private credit loans in which the creditors were notable alternative investment managers, subsequently failed to service their debt obligations. This series of events is notable as it represents one of the first significant restructurings involving nonbank debt, highlighting the evolving dynamics between private equity sponsors and private credit lenders. One would likely then question: why is lending not taking place safely through the traditional banking system? Here lies the rise and extensive growth of what is known as the shadow banking system. [1]

II. BACKGROUND

To answer the question of how we have come to a time where traditional banks are not the sole venue for lending, we must first understand the increase in regulations on these banks and the emergence of shadow banking.

Why have banks become very tightly regulated? The answer starts with the 2008 financial crisis – the Great Recession. In the late 1990s, consumers took advantage of the cheaper credit to purchase a range of products, such as using a mortgage to acquire a property, which culminated in the creation (and explosion) of the housing bubble. A housing bubble is when much speculation drives rapid growth in home prices to a point above their intrinsic value. [2] Part of the blame could be attributed to banks that provided subprime customers with mortgage loans. These loans would be targeted at consumers with poor credit who were unlikely to repay the loans and banks would market the loans in a misleading manner.

Additionally, securitization grew, in which banks pooled subprime mortgages into one security (i.e., the mortgage-backed security (MBS) that would be sold to institutional investors such as pension and hedge funds. An appeal was that pooling these assets meant that unsystematic risk was decreased as a result of diversification.

Another issue arose as banks, securities brokers, and insurance firms merged to become financial institutions of immense systematic importance in the marketplace. Their purchase of derivative investments, such as MBSs, grew when the SEC lessened net capital requirements. The first shots were fired in 2004-2006 when the Federal Reserve raised the Federal Funds rate from 1.25 to 5.25 percent, causing defaults by subprime borrowers with floating-rate debt. As rates increased, housing prices started to fall in 2005. By 2007, the decrease in the value of MBSs led to significant financial losses at hedge funds and banks, leading to a need for liquidations or mergers with stronger funds. Since it was unclear as to the amount of subprime debt composed in an MBS, there was difficulty in assessing banks' portfolios holding MBSs. The second banks began doubting each others' solvency, the overnight market for borrowing froze. The Fed attempted to intervene by purchasing securities, which reduced the federal funds rate. However, the Fed’s actions were unsuccessful, causing them to explicitly cut the fed funds rate three times. Many events continued to occur during this period but when Lehman Brothers, an investment bank, filed the largest bankruptcy in U.S. history, financial markets on an international scale entered a steep downward correction. [3]

Following the financial crisis, Congress passed the Wall Street Reform and Consumer Act (DoddFrank Act). The Dodd-Frank Act was intended to regulate banking to ensure the mistakes made leading up to the crisis would be averted in the future. The Act also created the Consumer Financial Protection Bureau to regulate subprime mortgage loans and other types of consumer credit. Financial stability is one of the main goals of the Dodd-Frank Act, which created the Financial Stability Oversight Council and Orderly Liquidation Authority to ensure stability among major financial firms—those deemed “too big to fail.” [4] This Council has the authority to break up firms deemed as having a major systemic risk— [although this is rare]. A more commonly used power is that the Council can raise banks' reserve requirements. An additional component of the Act is the Consumer Financial Protection Bureau, which prevents unsafe mortgage lending while ensuring consumers understand the risks posed by lending. The bureau also ensures that other lending platforms provide clear and sufficient information to consumers.

Another aspect of the Act is the Volcker Rule, restricting banks’ investments, speculative trading, and altogether banning proprietary trading. Essentially, banks cannot interact with firms, such as hedge funds or private equity, that can be deemed as too big of a risk. The Dodd-Frank Act also set up the Securities and Exchange Commission's (SEC) Office of Credit Ratings due to accusations against credit rating agencies claiming that they provided inaccurate ratings on debt instruments.

Another means for regulating banking arose in 2009 in the form of an international regulatory accord known as "Basel III." A group of 28 countries’ central banks—Basel Committee on Banking Supervision—joined Basel III in response to the financial crisis. This accord is a contextually evolving framework that builds upon previous accords, Basel I and Basel II. Basel III extensively grew the regulatory framework for the traditional banking system by raising minimum capital requirements from 2% to 4.5% of common equity, and inserting a 2.5% buffer capital requirement. Basel III includes a nonrisk-based leverage ratio, acting as a backstop to risk-based capital requirements. This leverage ratio must be in excess of 3%, with insured bank holding companies at 5% and "Systemically Important Financial Institutions" at 6%. Liquidity requirements include a liquidity coverage ratio which requires banks to have highly liquid assets that can handle 30-day stressed situations. [5] Another liquidity requirement is the Net Stable Funding Ratio, requiring banks to have stable funding above the amount required for a year of prolonged stress. [6] These are just a few examples of the many banking standards that have come under Basel III.

The term “shadow bank” came from economist Paul A. McCulley in 2007, describing it as “nonbank financial institutions that engaged in what economists call maturity transformation.” [7] The use of “shadow” in this phrase represents how such banks are not under the same regulation as traditional banks, cannot borrow from the Federal Reserve, and their funds are not covered by insurance in the way such traditional bank depositors are. Maturity transformation includes raising short-term funds to buy assets with long-term maturities. The Federal Reserve Bank of New York defines shadow banking as “financial intermediaries that conduct maturity, credit, and liquidity transformation without explicit access to central bank liquidity or public sector credit guarantees.” [8] Shadow banks encompass entities such as hedge funds, money market funds (MMFs), securitization vehicles, repurchase agreement markets, and many other alternatives—they act similarly to the traditional banking system in the sense that they perform credit and liquidity transformation. However, they do not have to adhere to the same level of regulatory oversight necessary for traditional lenders such as banks. Contrastingly, traditional banking involves the acceptance of deposits and lending longer-term loans, with tight regulations to prevent the risks of bank runs, panics, and crises. [9]

Regulatory frameworks established by Basel III and the Dodd-Frank Act were targeted at ensuring financial stability across the traditional banking system. However, shadow banks are not part of the entities these restrictions cover, pushing many to look toward nonbank financial intermediaries as an alternative to the highly regulated banking system. As traditional banks have faced greater stress testing and regulations since the 2008 financial crisis, they have had to substantially de-risk their balance sheets by diminishing their exposure to non-investment-grade debt securities; since shadow banks are not subject to this stress testing and regulatory oversight, they have taken over many of the activities that have been deemed too risky for traditional banks.

The shadow banking system does not follow the strict set of regulations imposed on the traditional banking system. Traditional banks are under strict regulations by government entities such as the Federal Reserve and FDIC; moreover, they have strict capital and liquidity requirements. Correspondingly, we can assume that the likelihood of distress in financial crises is higher for shadow banks. By keeping shadow banks outside of the regulations imposed on traditional banks, shadow banks engage in “regulatory arbitrage,” such as high-risk lending and securitization. [10]

Unlike traditional banks, shadow banks do not have protections from deposit insurance and cannot use emergency federal reserve funding. The growth of shadow banking has not only been facilitated by the increase in regulations on the traditional banking system, but also by strategic partnerships with insurance firms. For example, Apollo Global Management, an alternative investment firm, has partnered with Athene Holding Ltd, a retirement services company. This partnership allows Apollo to utilize Athene’s insurance premiums to invest in higher-yield and longer-term investments. By leveraging Athene’s balance sheet, Apollo gains access to long-term capital that operates outside regulatory oversight despite offering services comparable to traditional banks.

III. THE CASE FOR REGULATING SHADOW BANKS

Shadow banks can engage in regulatory arbitrage by avoiding the traditional banking regulations, imposing regulatory concerns. Private equity firms and hedge funds, in particular, depend on “governance-based exemption from investment company laws” and are unaffiliated with banking entities. These entities pose minimal regulatory concerns due to market checks, investors with incentives to minimize risk, and disconnection from banks. Regulations are less necessary due to the strong private governance over these entities. [11]

Worries are much greater for unregistered asset-based investment vehicles, which include mortgage real estate investment trusts, collateralized loan obligations, and credit funds. There are no restrictions regarding the investors under asset-based exemptions. Unregistered bank-sponsored investment companies—bank-sponsored securitization programs and collateralized loan obligations— pose the largest regulatory concern. Since these entities have indirect access to the federal safety net through bank commitments to provide credit and liquidity backing, they can transfer the loss to creditors and the safety net rather than assume the risk.

The fragile nature of the banking business model and its importance to the performance of the real economy necessitates the federal government’s role in ensuring the stability of the financial system. Taxpayers, through the Federal Deposit Insurance Corporation (FDIC), insure a share of bank deposits to limit the chances of depositor runs, and the Federal Reserve’s discount window provides solvent banks with emergency liquidity when needed.

Further legal challenges are posed by the minimal transparency across the shadow banking system. Since many transactions within this system occur off the balance sheet or with great complexity, systemic risk cannot simply be reviewed or addressed. To understand the risks posed by shadow banking, we may look toward the private investment firm 777 partners.

Following Apollo’s model, 777 Partners, an alternative investment manager, created two entities named 777 Re Ltd. in Bermuda and 777 Asset Management LLC. 2019. These entities would shift U.S.- based insurance assets into the control of a Bermuda domicile, which has fewer life insurance rules and solvency requirements. As a result, 777 Partners could hold aggressive investments on their balance sheet that U.S.-based insurers could not. 777 Re Ltd. is an example of a reinsurer currently under fire for possibly being unable to repay its annuity obligations.

Unlike traditional banks which are backed by the FDIC, insurance companies have no government backstop to ensure policyholders are repaid in the event of financial loss. When 777 Re was founded, it partnered with Advantage Capital Holdings (which owns other life insurers) to reinsure annuity contracts. On top of the cash flow 777 Re has received from reinsurance, it has continued to get cash from annuitants that pay regular premiums. In the life-and-annuity business, insurers have a lot of time before payments are required, allowing for a long investment runway to beat the required rate of return to successfully fulfill redeemed policies. This led to insurance regulation in the states, which created significant rules on disclosure, reserves, and investment decisions.

Following the 2008 financial crisis, insurers have essentially been forced to invest primarily in investment-grade bonds. As a direct result of overregulation, insurance companies were sold to private equity firms that could offer offshore access to Bermuda entities. 777 Re was able to spend annuitants' money on various ego-driven investments where the achievability of positive returns was not immediately clear. To make matters worse, 777 Re did not file audited financial statements for two years despite it being a mandatory requirement. This led to the Bermuda Monetary Authority putting them under administrative watch. Soon after, A.M. Best, a rating agency, downgraded 777 Re’s rating to a C-minus from an A-minus due to their misuse of 777 Asset Management to invest in risky securities. Since Bermuda’s disclosure rules do not require public list filings of investments, there is a lack of clarity as to what is backing the promises made by these firms. [12] What this case highlights is that the growth in offshore reinsure practices is posing a severe risk by utilizing their lack of transparency to engage in risky investments. Consumers are going unprotected as shadow banks continue to operate outside of the traditional banks’ regulatory framework. Not only is there inherent systemic risk posed by these practices due to transparency issues, but there is a complete lack of protection for policyholders. Traditional banks are backed by the FDIC to protect depositors, while insurance companies lack any safeguards to address insolvency

IV. THE CASE FOR DEREGULATING TRADITIONAL BANKING

The regulations posed by Basel III, even though intended to ensure safety and confidence in the financial system, have significant unintended consequences. Specifically, the higher capital requirements could be the reason the regulated credit market is decreasing as a proportion of the total credit market, with expectations of the private credit assets under management to reach $3.5 trillion by 2028. Based on data from a new firm-lender matched credit data from South Korea, it was found that Basel III correlated with a decline in bank credit of 25% and a similar increase in credit from shadow banks. [13]

Since there is a greater demand for loans than what traditional banks can supply, shadow banks can act as an unregulated alternative. Even though there is often an argument for strengthening the regulations on shadow banking, the alternative method of deregulating traditional banks may be found more beneficial.

Rather than permitting shadow banks to continue to expand into an unregulated environment destined for inevitable risk, it would be more ideal to facilitate a market allowing traditional banks to stay competitive. Supporting traditional banks to engage in activities ranging from securitization to private credit would ensure that riskier actions are taking place under some type of oversight, like the Federal Reserve or FDIC. Shadow banks rely on short-term funding such as repos or commercial paper, which faces risk in the face of a financial crisis. On the other hand, traditional banks have access to the liquidity of the Federal Reserve, which would act as a more stable funding mechanism. Higher capital requirements on banks may reduce the loan risks for traditional banks, yet grow the risk of loans for shadow banks. Tightening traditional banks' regulations can increase the risk posed upon the financial system.

However, it is important to note that deregulating banks up to a certain point would reverse the safety measures following the 2008 financial crisis. Banks would engage in more risky lending and investing, potentially leading to a severe financial crisis.

Additionally, deregulating traditional banks at the same time as leaving shadow banks unregulated poses additional risks. Analyzing the period before the increase in banking regulations, one of the many factors driving the 2008 financial crisis includes the market for repurchase agreements—shortterm collateralized loans. Rather than using U.S. Treasury securities as collateral as the traditional repo market does, shadow banks relied on asset-backed securities (ABS) as the collateral. Specifically, shadow banks relied on a type of ABS that pools mortgages known as mortgage-backed securities (MBS). This posed a new concern to the financial system. [14]

As housing prices began to fall in 2007, panic spread that homeowners would default on mortgages, negatively impacting the MBS value. This ignited concern among lenders regarding repos collateralized by MBS, as well as concerns over the reliability of MBS as a safe collateral. ABS are made safely by diversification and over-collateralization, such as pooling mortgages. This over-collateralization depends on market conditions, like housing prices. In 2007, investors' expectations of rising house prices were met with the opposite—consecutive falling prices. Investors' concerns grew over the potential for rising defaults. Concerns grew when the ABX index, which shows the risk of default on subprime MBS, started rising, indicating that SPVs did not have sufficient collateral to ensure payments to investors were made. Repo lenders then demanded more collateral but stopped renewing their loans, freezing the repo market.

Given the unclear nature of the riskiness of MBS, investors withdrew funds from shadow banks, even if they held safe MBS, igniting a liquidity crisis. The initial panic, starting with repo lenders who ran on repo borrowers, had grown into a systemic banking crisis. The collapse of Lehman Brothers in 2008 signifies the risk shadow banking poses in the broader market. Lehman Brothers used much repo funding and securitized mortgage products, making it more vulnerable when liquidity became dry, leading to insolvency. Since shadow banks, unlike traditional banks, do not have access to emergency liquidity support from the Federal Reserve, the systemic market risk multiplied.

As discussed earlier, the increasing regulations on traditional banks following the 2008 financial crisis resulted in the expansion of the private credit market and passive, low-cost investing. We can see this issue become more prevalent through insurers bought out by private equity firms who then invest in private credit. There has been a greater attraction to annuities – insurance contracts where investors make purchases in return for monthly payments. Annuities profit from the spread driven by nonbank lending market debt origination, where insurers have more access. Unlike traditional banks who allocate capital in investments, shadow banks pool retirement savings into leveraged private credit. This leads to systemic risk driven by debt backed strategies rather than long term investments.

As banks have reduced their footing in middle market companies—firms with revenues between $10 million and $1.1 billion—private credit funds have provided an alternative, more flexible and tailored than traditional banks. As mentioned earlier, Apollo has taken advantage of insurance firms going on an alternative asset manager balance sheet. However, the trend has continued to grow, with private equity firms using insurance equity to earn fees and receive interest on debt. These firms have utilized a path that removes them from traditional bank oversight, profiting off their lack of regulations. [15] This risk provides an argument to deregulate traditional banks while still maintaining specific requirements and oversights to limit the amount of reliance on the private credit market that has grown substantially in the past twenty years.

V. POTENTIAL SOLUTIONS

There are clear pros and cons to both regulating shadow banks and deregulating traditional banks. In the current environment, many argue that traditional banks are under quite extreme restrictions, barring their efficiency. Rather than fully deregulating the traditional banking system, it would be overall more efficient if regulations were lightened to an optimal point.

Under current regulations, traditional banks have strict rules on their lending practices and reserves. As traditional banking regulations have tightened, the shadow bank market has grown from 61.08 billion in 2024 to an expected 88.2 billion by 2032. [16] As enterprises continue to look for short-term funding, and traditional banks turn them away, shadow banks will keep expanding. Reducing regulations on traditional banks would allow more players to enter the market, encouraging greater competition with shadow banks. Transactions would become safer by maintaining agency oversight on traditional banks but reducing the level of capital held. Specifically, by transferring such lending capabilities to traditional banks, the out-of-sight and unclear practices of shadow banks would be limited. While traditional banks would be more efficient with deregulation, certain systemically important banks should receive great supervision. Regulations over systemically important financial institutions are necessary to mitigate the risks that could arise from the traditional and shadow banking systems.

Even though an argument can be made for deregulating traditional banks, steps must be taken to ensure that the systemic risk of shadow banks is limited. The FSOC should have greater authority to subject certain entities to more supervision given certain risk attributes. The FSOC should also have the power to de-designate entities if considered non-threatening to the greater financial system. Another aspect of FSOC authority should include the ability to supervise the regulation of activities, such as determining who the ideal regulator is and to what extent the rules authorize them to regulate. [17]

Transparency of the FSOC should be greater, through public meetings and press conferences, similar to the public presentation of the FOMC. Additional measures to ensure transparency should include testifying before Congress on the country's financial stability.

Regulation should target the liquidity of deposits, potentially reforming bankruptcy laws for repurchase agreements. There should be policies focusing on solvency issues, as well as different standards for contingent capital. There should be a tightening of capital requirements for shadow banks, imposing a stricter set of rules to reduce the threats posed by risky lending. There should also be reforms to lessen asymmetric information regarding the qualities of assets backing deposits. On an international scale, it would be of great benefit to coordinate to ensure standards are understood and applied as efficiently as possible. Systemic events are essentially inevitable, and policymakers should have a set of guidelines in order to cover such events if they occur.

An additional measure must be taken to address the risks posed by the growing relationships between private equity firms, insurance companies, and asset managers. The question may arise as to how policymakers can regulate an offshore practice. However, a more significant issue is posed by the lack of disclosure of these practices alongside the minimal actions taken to catch these issues before they explode. As discussed earlier, 777 Re went two years without filing audited financial statements. The authority to catch this was in the hands of Bermuda, but clearly, there lacked any measures taken to supervise this. Even if business is moved offshore to places such as Bermuda, U.S. regulators and policymakers must scrutinize these practices. Had it not been for Josimar, an investigative journal platform, catching the lapse of filings, Bermuda regulators may not have caught the problem. Disclosure regarding the use of the offshore reinsurance market must be increased. [18] Greater disclosure may also come in the form of reporting, regularly, assessments of risks relevant to investments.

Another approach that may be taken to tackle shadow banks systemic risks is enforcing solvency requirements, ensuring reserves are fully reflective of the riskiness of investments. Similar to regulatory practices on traditional banks, insurers should be regularly stress tested, ensuring they can handle certain financial crises. There should also be greater consumer protections, ensuring policyholders are not taking on excessive risk. The FSOC should be granted the authority to oversee and regulate private equitybought insurance companies.

VI. CONCLUSION

As shadow banks have proliferated financial systems, we have seen how tougher regulations on traditional banks may not be as optimal as once believed. Shadow banking had already grown in popularity in the early 2000s in the United States, but nonbanks accelerated in growth due to the shifting regulatory landscape following the 2008 financial crisis. Despite the common belief that traditional banks were the basis of this financial crisis, evidence has shown that shadow banks played a role in an unsafe financial environment.

Even though many have argued that shadow banks must receive greater regulations, it would likely be optimal to lower the capital requirements of traditional banks. Empowering shadow banks to continue growing as traditional banks can no longer support the demands of different enterprises will only further threaten financial stability. If traditional banks are provided more room to lend in greater amounts, hold lower reserves, and engage in a wider variety of transactions, shadow banks will no longer have the ability to dominate the financial system.

Endnotes

[1] Pari Passu Newsletter, “Pluralsight, the Restructuring Deal of 2024 (Special 100th Edition),” Pari Passu, 2024, https://restructuringnewsletter.com/p/pp-pluralsight-the-restructuring.

[2] John Duca, “Subprime Mortgage Crisis,” Federal Reserve History (Federal Reserve History, November 22, 2013), https://www.federalreservehistory.org/essays/subprime-mortgage-crisis.

[3] Investopedia, “The Great Recession,” Investopedia, December 18, 2023, https://www.investopedia.com/terms/g/great-recession.asp

[4] David H. Carpenter et al., “The Dodd-Frank Wall Street Reform and Consumer Protection Act: Background and Summary,” Congress.gov, 2025, https://www.congress.gov/crs-product/R41350.

[5] “Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-Weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market Risk Capital Rule,” Federal Register, September 10, 2013, https://www.federalregister.gov/documents/2013/09/10/2013-20536/regulatorycapital-rules-regulatory-capital-implementation-of-basel-iii-capital-adequacy-transition.

[6] BIS, “Basel III: International Regulatory Framework for Banks,” Bis.org (BIS, December 7, 2017), https://www.bis.org/bcbs/basel3.htm.

[7] Laura Kodres, “What Is Shadow Banking? - back to Basics - Finance & Development, June 2013,” Imf.org, 2013, https://www.imf.org/external/pubs/ft/fandd/2013/06/basics.htm

[8] Zoltan Pozsar et al., “The Traditional Banking System Has Three Actors: Savers, Borrowers, and Banks,” 2012, https://www.newyorkfed.org/medialibrary/media/research/staff_reports/sr458.pdf.

[9] Ann C. Logue, “Britannica Money,” www.britannica.com, November 13, 2023, https://www.britannica.com/money/shadow-banking-system.

[10] Emmanuel Farhi and Jean Tirole, “Shadow Banking and the Four Pillars of Traditional Financial Intermediation,” The Review of Economic Studies, October 13, 2020, https://doi.org/10.1093/restud/rdaa059.

[11] Patrick Corrigan et al., “Shining a Light on Shadow Banks,” accessed April 17, 2025, https://jcl.law.uiowa.edu/sites/jcl.law.uiowa.edu/files/2023-11/Corrigan_Final.pdf.

[12] Jen Frost, “The Reinsurer under Fire over Owner’s Football Team Bid,” Insurancebusinessmag.com (Insurance Business, March 14, 2024), https://www.insurancebusinessmag.com/us/news/breaking-news/the-reinsurer-underfire-over-owners-football-team-bid-481236.aspx?utm_source=chatgpt.com.

[13] Hyunju Lee et al., “Summer Workshop on Money, Banking, Payments and Finance,” SAET in Ischia, 2022, https://uh.edu/~rpaluszy/banking.pdf.

[14] Daniel Sanches, “Shadow Banking and the Crisis of 2007-08,” Business Review 2014, no. 19 (December 14, 2014), https://doi.org/10.17771/pucrio.escrita.23736.

[15] Hunter Hopcroft, “From Investment to Savings: When Finance Feeds on Itself - American Affairs Journal,” American Affairs Journal, February 20, 2025, https://americanaffairsjournal.org/2025/02/from-investment-tosavings-when-finance-feeds-on-itself/.

[16] “Shadow Banking Market Size from 2024 to 2031,” www.businessresearchinsights.com, n.d., https://www.businessresearchinsights.com/market-reports/shadow-banking-market-104081

[17] Gregg Gelzinis, “Strengthening the Regulation and Oversight of Shadow Banks,” Center for American Progress, July 18, 2019, https://www.americanprogress.org/article/strengthening-regulation-oversight-shadow-banks/.

[18] Frost, “The Reinsurer under Fire over Owner’s Football Team Bid”

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