# Lily Gordon and Lee Seltzer argue in Liberty Street Economics that bank structures shape financial analysis

[Canonical reading](https://escapemeridian.com/readings/lily-gordon-and-lee-seltzer-argue-in-liberty-street-economics-ba44470c)

Published March 31, 2026, Lily Gordon and Lee Seltzer use a fictional financial holding company to explain how a banking organization can contain different kinds of entities with different regulatory filings. They argue that organizational structure affects both what institutions do and what researchers observe in the data. The authors warn that identifying banking activities only with bank holding companies can lead researchers to underestimate activities performed by some financial holding companies. They also explain that a change in designation can alter reporting variables without reflecting a change in behavior. Such misclassification and reporting shifts can mislead banking analysis, the authors say, and they encourage researchers to use the National Information Center database to check holding-company structures. Their conclusion is that understanding these organizational choices is essential for researchers involved in banking analysis. It remains unknown from this account how reliably analysts can distinguish reporting changes caused by reclassification from changes in an institution’s actual behavior.

Headline and summary by Escape Meridian, prepared by Luna from the attributed source. A source check is not independent confirmation of the source’s claims.

## Original source

Federal Reserve Bank of New York · Article

Original source date: Mar 31, 2026 (2026-03-31T13:00:00.000Z).

Date basis: Date supplied by the publisher’s feed.

Added to Escape Meridian: 2026-11-07T16:13:23.415Z. First observed: 2026-10-30T16:23:58.358Z. Retrieved: 2026-10-30T16:25:58.148Z.

- [Behind the ATM: Exploring the Structure of Bank Holding Companies](https://libertystreeteconomics.newyorkfed.org/2026/03/behind-the-atm-exploring-the-structure-of-bank-holding-companies/)

## Limits

Text as retrieved on October 30, 2026; originally published March 31, 2026. The organizational example is explicitly stylized, and the authors say their summary of regulatory forms is not exhaustive.


## Open question

How can analysts distinguish reporting changes caused by organizational reclassification from changes in an institution’s actual behavior?


## Source-stated

Gordon and Seltzer argue that organizational structures affect both financial institutions’ activities and how they appear in data, so overlooking structure can mislead banking analysis.

> The organizational structure of financial organizations is critical for researchers and other analysts to understand, as it shapes both what banks do and what we observe in the data.

- [Supporting source](https://libertystreeteconomics.newyorkfed.org/2026/03/behind-the-atm-exploring-the-structure-of-bank-holding-companies/)

## Source-stated

The authors warn that classifying banking activities only by bank holding company status may cause researchers to underestimate the banking activities of some top-tier financial holding companies.

> If the researcher identifies banking activities as only those related to BHCs, they may inadvertently underestimate the amount of banking activities performed by Central Point Corporation and other economically relevant institutions.

- [Supporting source](https://libertystreeteconomics.newyorkfed.org/2026/03/behind-the-atm-exploring-the-structure-of-bank-holding-companies/)

## Source-stated

The authors say reclassification can cause reporting changes that analysts may mistake for changes in behavior, and recommend checking structures in the National Information Center database.

> Without accounting for organizational transitions, these reporting shifts can be misinterpreted as behavioral effects. We would encourage researchers to use the National Information Center database to confirm the structure of holding companies in their data

- [Supporting source](https://libertystreeteconomics.newyorkfed.org/2026/03/behind-the-atm-exploring-the-structure-of-bank-holding-companies/)

## Source and contributor context

Federal Reserve Bank of New York · Publisher

The publisher is identified here. No individual author has been inferred.


## Source media

Media retrieval status: unchecked.


## Terms and references

Reference context selected by Escape Meridian; separate from source evidence. Entity mentions do not establish authorship, involvement or endorsement.


## Editorial provenance

Version 1. Publication ID: d30a720d-dcdb-1126-4ddf-01f3cb78f5f3.

Prepared by openai/gpt-6-luna; grounding review by anthropic/claude-opus-5.5.

Source check: uncertain by anthropic/claude-opus-5.5 on 2026-11-07T16:08:29.031Z. This checks fidelity to the source, not whether its claims are independently true.

Editorial selection: accept; reasons: bridge\_admitted\_by\_model.

Observation: 6d0bbfa73a881c73fc792f2ee85fbe25a36b391112a3a20cdb6d9814cd9b1dd4. Source text hash: 743b68a541260ec815392604e02b85ac0f5fa6675276253350ee150fcedcea1f.


## Revision and source-check history

### Version 1 — 2026-11-07T16:13:23.415Z

Published March 31, 2026, Lily Gordon and Lee Seltzer use a fictional financial holding company to explain how a banking organization can contain different kinds of entities with different regulatory filings. They argue that organizational structure affects both what institutions do and what researchers observe in the data. The authors warn that identifying banking activities only with bank holding companies can lead researchers to underestimate activities performed by some financial holding companies. They also explain that a change in designation can alter reporting variables without reflecting a change in behavior. Such misclassification and reporting shifts can mislead banking analysis, the authors say, and they encourage researchers to use the National Information Center database to check holding-company structures. Their conclusion is that understanding these organizational choices is essential for researchers involved in banking analysis. It remains unknown from this account how reliably analysts can distinguish reporting changes caused by reclassification from changes in an institution’s actual behavior.

## Original source

Federal Reserve Bank of New York · Article

Original source date: Mar 31, 2026 (2026-03-31T13:00:00.000Z).

Date basis: Date supplied by the publisher’s feed.

Added to Escape Meridian: 2026-11-07T16:13:23.415Z. First observed: 2026-10-30T16:23:58.358Z. Retrieved: 2026-10-30T16:25:58.148Z.

- [Behind the ATM: Exploring the Structure of Bank Holding Companies](https://libertystreeteconomics.newyorkfed.org/2026/03/behind-the-atm-exploring-the-structure-of-bank-holding-companies/)

## Limits

Text as retrieved on October 30, 2026; originally published March 31, 2026. The organizational example is explicitly stylized, and the authors say their summary of regulatory forms is not exhaustive.


## Open question

How can analysts distinguish reporting changes caused by organizational reclassification from changes in an institution’s actual behavior?


## Source-stated

Gordon and Seltzer argue that organizational structures affect both financial institutions’ activities and how they appear in data, so overlooking structure can mislead banking analysis.

> The organizational structure of financial organizations is critical for researchers and other analysts to understand, as it shapes both what banks do and what we observe in the data.

- [Supporting source](https://libertystreeteconomics.newyorkfed.org/2026/03/behind-the-atm-exploring-the-structure-of-bank-holding-companies/)

## Source-stated

The authors warn that classifying banking activities only by bank holding company status may cause researchers to underestimate the banking activities of some top-tier financial holding companies.

> If the researcher identifies banking activities as only those related to BHCs, they may inadvertently underestimate the amount of banking activities performed by Central Point Corporation and other economically relevant institutions.

- [Supporting source](https://libertystreeteconomics.newyorkfed.org/2026/03/behind-the-atm-exploring-the-structure-of-bank-holding-companies/)

## Source-stated

The authors say reclassification can cause reporting changes that analysts may mistake for changes in behavior, and recommend checking structures in the National Information Center database.

> Without accounting for organizational transitions, these reporting shifts can be misinterpreted as behavioral effects. We would encourage researchers to use the National Information Center database to confirm the structure of holding companies in their data

- [Supporting source](https://libertystreeteconomics.newyorkfed.org/2026/03/behind-the-atm-exploring-the-structure-of-bank-holding-companies/)

## Source and contributor context

Federal Reserve Bank of New York · Publisher

The publisher is identified here. No individual author has been inferred.


## Source media

Media retrieval status: unchecked.


## Terms and references

Reference context selected by Escape Meridian; separate from source evidence. Entity mentions do not establish authorship, involvement or endorsement.


## Editorial provenance

Version 1. Publication ID: d30a720d-dcdb-1126-4ddf-01f3cb78f5f3.

Prepared by openai/gpt-6-luna; grounding review by anthropic/claude-opus-5.5.

Source check: uncertain by anthropic/claude-opus-5.5 on 2026-11-07T16:08:29.031Z. This checks fidelity to the source, not whether its claims are independently true.

Editorial selection: accept; reasons: bridge\_admitted\_by\_model.

Observation: 6d0bbfa73a881c73fc792f2ee85fbe25a36b391112a3a20cdb6d9814cd9b1dd4. Source text hash: 743b68a541260ec815392604e02b85ac0f5fa6675276253350ee150fcedcea1f.


### uncertain — 2026-11-07T16:08:29.031Z — anthropic/claude-opus-5.5

Publication: d30a720d-dcdb-1126-4ddf-01f3cb78f5f3

attribution — pass: The reading attributes the arguments to Lily Gordon and Lee Seltzer in Liberty Street Economics, the New York Fed blog, which matches the byline and citation. Their claims stay attributed to them rather than presented as established fact.

> Lily Gordon and Lee Seltzer, “Behind the ATM: Exploring the Structure of Bank Holding Companies,” Federal Reserve Bank of New York Liberty Street Economics, March 31, 2026

summary — uncertain: The summary is faithful, but its central contrast is not understandable without background, and the definitions list is empty. It never explains that a financial holding company is a special type that can do broader activities such as insurance and securities underwriting, as opposed to a bank holding company. It also leaves the National Information Center database unexplained. Smallest repair: add a plain-language gloss of BHC versus FHC, or tooltip entries for both terms.

> a special type of holding company that can engage in a broader range of financial activities beyond traditional banking, such as insurance and securities underwriting

date — uncertain: The March 31, 2026 date matches the dateline and the UTC day of originalPublished. The kind is publisher-page, and the limitations note the October 2026 retrieval. However, the page was edited after publication: an editor's note says two paragraphs were revised on April 8, and dateModified is April 27, 2026. Because the paragraph numbering is ambiguous, it is not plain that the cited passages are unchanged from the original. The reading also does not mention the revision.

> Editor’s note: The fifth and sixteenth paragraphs have been revised for technical accuracy. April 8, 2026, 5:00 p.m.

support — uncertain: Each claim matches its quoted source text, and the closing unknown about separating reclassification from real behavior change is a fair, non-leading follow-up. However, editedAfterPublication is true and the revised paragraphs are identified only by number. It is therefore not plainly established that the cited Why This Matters passages are original text rather than later edits.

> Without accounting for organizational transitions, these reporting shifts can be misinterpreted as behavioral effects.

media — pass: No media was selected and no verified candidates were supplied, so there is no media identity or relevance issue.

## Recorded references

Explicit citations in public readings and public file attachments to this reading. Shared topics are not citations. Other artifact types need an explicit reference adapter.

No public references recorded here yet.

[Reference data (JSON)](/readings/ba44470c5f11a3dcdc28d450e8c7286eb8dfaee71d4f61b55638d0214db63189/references.json)

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