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public trust institution. The other doubt is, whether prudential regulations, safety net with<br />

deposit guarantee system could cope with that combination of activities?<br />

Distinction of aforementioned types of banks can’t ignore of regional traditions or appropriate<br />

jurisdictions. In many legal frameworks commercial and investment banking have been legally<br />

separated. For the others the combination of the both is allowed. The approach to this problem<br />

has been changing over the years. The most purposeful is to trace the processes that took place<br />

in the US, Germany and the UK.<br />

Historical co-existence of commercial and investment banking<br />

The case of United States<br />

American history of banking is the most spectacular view of opposing forces and ideas<br />

participating in the discussion on separation between commercial and investment banks. With<br />

the beginning of the XX century, America had a workable banking system with one national<br />

currency but still without central bank. Exposed to continuous tensions, both financial and<br />

political, economy struggled with the “crisis of the big banks”. The big banks, with J. Morgan at<br />

the forefront, grew in power and were playing a central role in the consolidation of American<br />

business into giant trusts. In 1913 Senate Committee recommended that banks should be<br />

confined to commercial banking, but it did not lead to splitting them u However, it led to the<br />

establishment of the Federal Reserve System in 1913. During the boom years of the 1920s, it<br />

seemed that the era of universal banking had arrived and is going to last for long. However the<br />

financial crisis of the early 1930s put the process into reverse. Public anger was inevitably<br />

directed at bankers. During the national debate economists asked why the Wall Street Crash of<br />

1929 came into the worst depression in modern history. Some of them blamed small local<br />

banks, defaulting massively. Similar views were held by the advocates of the large banks. On<br />

the other hand, the advocates of the small banks argued, that they were not the cause of the<br />

problem, but its victims. They maintained that large, federal banks, involved in securities<br />

activities, should be blamed for blowing up the stock-market bubble and setting off the crisis.<br />

Amidst animated discussions, in 1933, Carter Glass together with Henry Steagall introduced a<br />

Glass–Steagall Act. It forced banks to close down or spin off their securities businesses and<br />

established the Federal Deposit Insurance Corporation (FDIC) [Bulkley, 1932]. Banks had to<br />

choose whether they wished to accept deposits or deal in securities (they could no longer do<br />

both). From 1933 to the late 1970s, the Glass–Steagall Act remained largely unchallenged. In<br />

1980s banks started to push for its repeal. Profits from traditional lending of commercial banks<br />

started to decline as creditworthy corporations funded themselves in the commercial paper<br />

market. Meanwhile the investment banks, expanding their range of services, desired cheaper<br />

funding sources. Access to investment banking activities provided commercial banks with new,<br />

non-interest income as an alternative to seeking capital-intensive interest income from<br />

commercial business. In 1988 the first crack in Glass-Steagall appeared. Eventually in 1999 the<br />

Clinton administration in the USA legalized universal banks. Gramm-Leach-Bliley-Act repealed<br />

key provisions of the Glass-Steagall Act. Domination of investment banking came to the end.<br />

After the recent global financial crisis, however, financial regulation has become prominent<br />

once again. The Frank-Dodd-Act implemented the Volcker Rule in 2010.<br />

The case of Germany<br />

In Germany universal banking has grown up organically and seldom been challenged. From the<br />

beginning of 19 th century German private banks were helping to finance business start-ups<br />

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