NewCo's next steps are up to its board of directors (see box) and the management the board hires.
IRS rules governing tax losses effectively mean NewCo will have to remain in the financial-services field. The company could buy or build an operating business — presumably a profitable one, to make use of the losses.
"It could become a bank again," Scott said. "It could be an investment company. Within the world of finance and insurance, it's going to be wide open."
The immediate focus, said equity committee attorney Edgar Sargent, will be on building a company that's successful on its own — perhaps by buying a small business, growing it for a few years, then seeking outside financing to pursue bigger deals.
However, the tax losses likely will loom large in NewCo's longer-term plans — if for no other reason than that they're potentially so valuable.
"That is a very attractive corporation for any profitable bank or other company in a related business," said Scott Schumacher, a professor of tax law at the University of Washington Law School. "I wouldn't be surprised if they got acquired."