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he Special Inspector General for the Troubled Asset Relief Program (SIGTARP) on the government39。 in many cases, the amount of the deposits substantially exceeded the capital of the depositor banks. These banks generally held such sizable deposits because they cleared payments, such as checks or wire transfers, through Continental. If Continental had failed, those banks would have failed as well. Section 308 of the FDIC Improvement Act of 1991 gives the Federal Reserve Board powers to deal with this problem. The Act permits the Board to limit the credit extended by an insured depository institution to another depository institution. Limitation of interbank deposits may be feasible with respect to placements by one bank with another because the amount of credit extended is fixed for a given term. Indeed, it appears that the chainreaction risk arising from bilateral credit exposures from overnight Federal Reserve funds transactions is quite low: Losses would not exceed one percent of total mercial banking assets as long as loss rates are kept to historically observed levels. Exposures are more difficult to identify with respect to interbank clearing accounts where the amount of credit extended is a function of payment traffic. For example, Bank A may be credited by its correspondent Bank B for an ining wire transfer of $10 million. Bank A is thus a creditor of Bank B for this amount. If Bank B were to fail Bank A is seriously exposed. Without material changes in the payment system, such as forcing banks to make and receive all payments through Federal Reserve rather than correspondent accounts, it would be quite difficult to limit these types of exposures. Second, a chain reaction of bank failures can occur through settlement payment systems. If one bank fails to settle its position in a settlement system for large value payments, such as the Clearing House Interbank Payments System (CHIPS) in the United States, other banks that do not get paid may, in turn, fail. This risk was the major systemic risk concern of the Federal Reserve until CHIPS changed its settlement procedures in 2020 to essentially eliminate this risk. Third, a chain reaction of bank failures can occur through imitative runs. When one bank fails, depositors in other banks, particularly those whose deposits are uninsured, may assume that their banks may also fail and so withdraw their funds, exposing these banks to a liquidity crisis and ultimately to failure. This result es from a lack of information in the market about what specifically caused the first bank to fail.(n15) The Federal Reserve plays the classic role of lender of last resort to stem irrational imitative runs in situations such as this one. Lastly, and especially prominent in the current crisis, a chain reaction of bank failures can occur as a result of counterparty risk on derivative transactions, such as credit default swaps (CDSs). ).Here the concern is that if institution X fails to settle its derivative position with institution Y, both X and Y will fail. If Y in turn cannot settle its positions, other institutions will also fail. This risk proved potentially significant in the failure of the hedge fund LongTerm Capital Management in 1998. Concerns of this type also underlay JPMan Chase39。s action also mentioned concern over stemming runs on money market funds, which held $20 billion in AIG mercial paper. Similarly, in their recent testimony on