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

ICBA Stands with Sens. Brown and Vitter Against Wall Street Spin Machine

Mar 11, 2013

Washington, D.C. (Mar. 11, 2013)—Camden R. Fine, president and CEO of the Independent Community Bankers of America® (ICBA), released this statement today in support of a press release sent by Sens. Sherrod Brown (D-Ohio) and David Vitter (R-La.), which addressed claims by the largest members of the financial services industry regarding their “too big to fail” megabank subsidy.

“ICBA thanks Sens. Brown and Vitter for their unwavering support of Main Street and their ability to see through the smoke that the Wall Street spin machine is creating as a desperate move to protect the nation’s megabanks—the same group that caused, and nearly brought down, our entire financial system during the greatest financial crisis since the Great Depression.

“We agree with Sens. Brown and Vitter that it comes as no great surprise that the megabanks’ trade associations think the too-big-to-fail problem is behind us. Further, despite the claims made by the paid cheerleaders of the megabanks, too-big-to fail is alive and well, and the banks receive taxpayer subsidies. As Vitter said, ‘Chairman Bernanke knows it, the market knows it, and the taxpayers know it.’

“In fact, last week’s remarks from Attorney General Eric Holder confirm that too-big-to-fail financial institutions operate above the law. Holder’s statement that federal law-enforcement officials have hesitated to prosecute Wall Street firms because of their size and interconnectedness shows that these institutions receive favorable treatment, not only economically but in our justice system as well.

“It’s time to expose the Wall Street spin machine for what it really is, and I look forward to seeing the results of the Government Accountability Office study, which was spearheaded by Sens. Brown and Vitter to evaluate the potential market distortions caused by too-big-to-fail financial institutions.”

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About ICBA 
The Independent Community Bankers of America®, the nation’s voice for nearly 7,000 community banks of all sizes and charter types, is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, best-in-class education and high-quality products and services. For more information, visit

Letters to Congress

Title Recipient Date
Senators Crapo and Brown

Letters to Regulators

Title Recipient Date
Federal Reserve, OCC
Federal Reserve, OCC
Federal Reserve Bank of Minneapolis
OCC, Federal Reserve, and FDIC


Title Committee Presenter Date


Title Content Type Date