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 Statement on Minneapolis Fed Plan to End Too-Big-To-Fail

Nov 16, 2016

ICBA Statement on Minneapolis Fed Plan to End Too-Big-To-Fail

Washington, D.C. (Nov. 16, 2016)—Independent Community Bankers of America® (ICBA) President and CEO Camden R. Fine released the following statement on today’s Federal Reserve Bank of Minneapolis plan to end too-big-to-fail.

“ICBA commends the Federal Reserve Bank of Minneapolis for its important work and analysis on the matter of systemic risk and ending too-big-to-fail. ICBA generally supports enhanced prudential standards and higher capital requirements for the largest banks as well as further regulatory requirements on the shadow banks to reduce the systemic risk they pose to our financial system and economy.

“ICBA also commends the Minneapolis Fed for its recognition that reducing unnecessary regulatory burdens on community banks is essential to promoting a stronger, safer and more secure financial system. We look forward to continuing to work with the Minneapolis Fed and others to advance policies that mitigate community bank overregulation and systemic risks to our financial system.”

About ICBA
The Independent Community Bankers of America®, the nation’s voice for nearly 6,000 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.

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