U.S. "commercial banking" tradition). Berle supported separating commercial banking from other activities, but disagreed with the Winthrop Aldrich position, contained in Glass–Steagall's Section 21, that this should also apply to "private bankers". Berle suggested that required a "separate study". Fate of 1933 Banking Act as "traditional bank regulation" Helen Garten describes the 1933 Banking Act as exemplifying the form and function of "traditional bank regulation" based on limiting bank activities and protecting banks from competition. The Act established the traditional bank regulation of separating commercial from investment banking, limiting deposit interest rate competition through rate limitations, and restricting competition for deposits based on financial strength by insuring depositors. It also ratified the existing policy of limited branch banking, thereby limiting competition among banks geographically. The resulting "government-enforced cartel in banking" allowed commercial banks to earn "high profits and avoid undue risk" until nonbanking companies found ways to offer substitutes for bank loans and deposits. Supporters of this traditional banking regulation argue that the 1933 Banking Act (and other restrictive banking legislation) produced a period of unparalleled financial stability. David Moss argues this stability may have induced a false belief in the inherent stability of the financial system. Moss argues this false belief encouraged legislative and regulatory relaxations of traditional restrictions and that this led to financial instability. Earlier critics of the 1933 Banking Act, and of other restrictive banking regulation, argued it has not prevented the return of financial instability beginning in the mid-1960s. Hyman Minsky, a supporter of traditional banking regulation, described the 1966 return of financial instability (and its increasingly intense return in 1970, 1974, and 1980) as the inevitable result of private financial markets, previously repressed by memories of the Great Depression. Minsky proposed further controls of finance to limit the creation of "liquidity" and to "promote smaller and simpler organizations weighted more toward direct financing". Commentators argued traditional banking regulation contained the "seeds of its own destruction" by "distorting competition" and "creating gaps between cost and price". In particular, by establishing "cartel profits" traditional bank regulation led nonbank competitors to develop products that could compete with bank deposits and loans to gain part of such profits. Instead of financial stability inducing deregulation and financial instability after 1980, as later suggested by David Moss and Elizabeth Warren, Thomas Huertas and other critics of traditional bank regulation argued Regulation Q limits on interest rates (mandated by the 1933