Too Big to Fail & Systemic Risk (Including Systemic Risk)

The Wall Street financial crisis and government intervention of 2008 affirmed that the nation’s largest megabanks are “too big to fail”—so big and interconnected that the government will not allow them to fail.

As ICBA details in its “End Too-Big-To-Fail” study, too-big-to-fail distorts free markets, incentivizes risky behavior, leaves taxpayers on the hook, and creates unfair competitive advantages for the largest banks. Meanwhile, community banks face oppressive regulatory burdens as a direct result of megabank misdeeds.

A less concentrated and more diverse financial system would decrease systemic risk, improve competition and innovation, and increase the availability of consumer credit. ICBA and the nation’s community banks are dedicated to ending too-big-to-fail.

Articles & Press Releases

Title Publication Date
Fine: New Film Shows Community Bank Small Enough to Jail, Strong Enough to Resist NewsWatch Today Article 05/17/17
ICBA: FDIC’s Hoenig Right on Consolidation Dangers NewsWatch Today Article 05/14/17
Fine: Too-Big-To-Fail Problem Remains NewsWatch Today Article 04/12/17
ICBA, Coalition Seek Transparency in Fintech Charter NewsWatch Today Article 01/18/17
ICBA Backs Minneapolis Fed Proposal to Ease Community Bank Burden NewsWatch Today Article 01/18/17
ICBA Statement on Minneapolis Fed Plan to End Too-Big-To-Fail Press Release 11/16/16
ICBA Statement on Wells Fargo Fine for Illegal Sales Practices Press Release 09/09/16
ICBA Statement on Remarks from JPMorgan Chase’s Jamie Dimon Press Release 05/11/16
ICBA Statement to Federal Regulators: “No Bank Should be Too Big to Fail nor Too Big to Jail” Press Release 06/01/15
ICBA Statement on Bill to Break Up Too-Big-To-Fail Megabanks Press Release 05/06/15
ICBA Supports Capital Surcharge on Megabanks Press Release 12/09/14
2014 Year in Review: Community Banks Are Winners in Washington CEO Alert 12/02/14
ICBA Commends FDIC and Federal Reserve for Ensuring Living Wills Are More Than Just a ‘Paper Exercise’ Press Release 08/06/14
New GAO Report Confirms Too-Big-To-Fail Exists, Taxpayer Subsidy Continues Press Release 07/31/14
ICBA: Hold Wall Street Bad Actors Personally Accountable Press Release 09/30/13
ICBA: Greatest Threat to Financial System is Too-Big-To-Fail Press Release 06/26/13
ICBA Lauds Brown-Vitter Legislation Taking on Too-Big-To-Fail Press Release 04/24/13
ICBA: Survey Shows Americans Want Washington to Address Too-Big-To-Fail Problem Press Release 03/21/13
ICBA: Evidence Mounting against Too-Big-To-Fail Press Release 03/18/13
ICBA: Senate Report Shows Continued Threat of Too-Big-To-Fail Press Release 03/15/13

Letters to Congress

Title Recipient Date
Senator Vitter
Representative Capuano

Letters to Regulators

Title Recipient Date
Federal Reserve Bank of Minneapolis
OCC, Federal Reserve, and FDIC
Secretary of Labor Thomas Perez
CFTC, FDIC, Federal Reserve, OCC and SEC
Federal Reserve
Federal Reserve


Title Committee Presenter Date
Senate Subcommittee On Financial Institutions and Consumer Protection
Written Statement
Senate Subcommittee on Financial Institutions and Consumer Protection
Written Statement
House Financial Services Committee
Written Statement


Title Content Type Date