The ability for community banks and small regional players to consolidate or even eat up divested pieces of unwieldy universal banks may also be key to finding a replacement for 'too big to fail' banks. For instance, FBR Capital Markets analyst Paul Miller says that not only should Bank of America ( BAC) split or spin off its Merrill Lynch investment banking unit - bought under former CEO Ken Lewis for nearly $50 billion the day Lehman Brothers collapsed - it should also split its commercial banking operations regionally, undoing other mergers. Such an advised breakup would undo a generation of consolidation for Bank of America, which expanded it into a national commercial bank. Meanwhile, after merging with investment banks, brokerages and insurance conglomerates like Travelers, Citigroup is already well on the way of breaking up what was Weill's 'financial supermarket.' In fact, the bank is currently running off an $850 billion portfolio of unwanted assets called CitiHoldings, as it tries to shrink a balance sheet that swelled to nearly $2 trillion prior to the crisis. Even if current regulations and those soon to be implemented through the 2010 Dodd Frank Act help to restore a more sound and competitive commercial banking industry in the U.S., all is still not well for independent investment banks, which disappeared during the financial crisis, and continue to be characterized as 'systemically important financial institutions,' a regulatory moniker for 'too big to fail.' Were JPMorgan or Bank of America to separate their investment banks from their retail operations, would they operate as true standalone units or just become bank holding companies like their parent? The answer is not so clear. After the crisis, the notion of a true standalone investment bank has all but disappeared after Goldman Sachs ( GS) and Morgan Stanley ( MS) converted to BHC's in the fall of 2008 to gain access to the Federal Reserve's discount window and survive the crisis. "It is a major, major mistake for Goldman Sachs and Morgan Stanley to have bank holding company status," says Bush of NAB Research. In fact, even if Weill's comments sparked a revival of the debate on 'too big to fail,' with Congressional figures already debating his Wednesday morning comments, change may first come from abroad. UBS ( UBS), Credit Suisse ( CS) and Barclays ( BCS) may be first-movers in shuttering, divesting or spinning off their investment banking units, notes Roy Smith, a professor of management at New York University's Leonard N. Stern School of Business. Swiss regulators are already asking that UBS and Credit Suisse cut their risk assets - mostly held in investment banking units - by over half, as a means to protect their vaunted asset management businesses and the Swiss economy. Smith - a former general partner at Goldman Sachs ( GS) -- notes that British regulatory efforts like the Vickers Commission to 'ringfence' traditional bank deposits are also most to lead to a spinoff of Barclays' investment banking unit.