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
FDIC’s Gruenberg Blasts Plan to Ease Megabank Capital Standards NewsWatch Today Article 09/07/18
Op-Ed: Preserve Megabank Capital Standards NewsWatch Today Article 08/30/18
Fed Approves Rule Limiting Megabank Counterparty Limits NewsWatch Today Article 06/14/18
ICBA Opposes Plan to Ease Megabank Capital Rules NewsWatch Today Article 06/13/18
ICBA Opposes Plan to Ease Capital Rules on Riskiest Megabanks Press Release 06/13/18
Agencies Extend Comment Period on Megabank Capital Proposal NewsWatch Today Article 05/21/18
Wells Fargo Fined $1B for Auto, Mortgage Violations NewsWatch Today Article 04/23/18
Treasury Recommends Reforming Megabank Liquidation Authority NewsWatch Today Article 02/22/18
ICBA: More, Not Fewer, Community Banks Needed NewsWatch Today Article 02/08/18
ICBA Commends Fed on Wells Fargo Penalty NewsWatch Today Article 02/06/18
Fed Restricts Wells Fargo’s Growth Following Abuses NewsWatch Today Article 02/05/18
“Small Enough to Jail” Documentary Nominated for Oscar NewsWatch Today Article 01/24/18
Minn. Fed Proposes Community Bank Relief in TBTF Report NewsWatch Today Article 01/11/18
ICBA Supports Senate Community Bank Regulatory Relief Agreement Press Release 11/13/17
ICBA: Compliance Costs Exacerbate Industry Consolidation Press Release 10/23/17
ICBA Denounces Megabanker Claim of Too Many Banks Press Release 10/20/17
ICBA’s Cam Fine Reacts to Latest Wells Fargo Scandal News Press Release 09/06/17
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

Letters to Congress

Title Recipient Date
Senators Crapo and Brown
Senator Vitter

Letters to Regulators

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


Title Committee Presenter Date


Title Content Type Date