Wall Street Bull in Lower Manhattan, New York/photo courtesy of Victoria Lipov/Shutterstock.com Sullivan & Cromwell Rodge Cohen

H. Rodgin Cohen Q: Your work in this case centered on the “Hotel California” provision of Dodd-Frank, which was designed to keep banks like Goldman Sachs and JPMorgan Chase from simply shedding their holding companies to avoid increased oversight. As the lyrics to the classic Eagles song go, “You can check out anytime you like, but you can never leave.” But Dodd-Frank does allow firms that remove their holding company to appeal their “too-big-to-fail” designation. How long had this potential escape route been on your mind? Q: How did you feel about your chances initially? Q: That sense of risk—how did the bank get over that sense, and to what extent were you able to take the temperature of federal regulators before pushing forward? Q: What went into that process of making sure the agencies wouldn't be annoyed, as you said? Q: How involved was Simmons and Zions' in-house legal team in the process? Q: How long did this process take? Q: At the end of the day, how much convincing did it take for Zions to go for this? Q: How much of the calculation was the fact that shortly after this process began, Trump won the election and brought in an administration that has a deregulatory bent? Q: Recently, Congress raised the threshold from $50 billion to $100 billion—and an even higher threshold is coming in the future. With that in mind, do you expect other banks to piggyback on the approach Zions took in this matter? Q: How did that claim—that there wouldn't be many copycats—land with the regulators? Q: What's next with FSOC and the systemically significant designation?