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’s Cam Fine Reacts to Latest Wells Fargo Scandal News

Sep 06, 2017
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Washington, D.C (Sept. 6, 2017)—Independent Community Bankers of America® (ICBA) President and CEO Camden R. Fine issued the following statement today in reaction to recent news that Wells Fargo found two-thirds more fake customer bank and credit card accounts than previously realized. This brings the total number of fake customer accounts, in which Wells Fargo used its customers’ names and credit information without permission, up to 3.5 million from the 2.1 million first reported last year. This follows news last month that Wells Fargo was caught charging 800,000 people for auto insurance they did not want or need.  

“Week after week, month after month, additional scandals are uncovered at Wells Fargo involving hundreds of thousands of customers. The most shocking aspect of the multiple Wells scandals is not that some of these practices have gone on for years—it is that federal regulators have taken no meaningful action against the board and senior managers who were supposedly responsible for the ethical, moral and legal conduct of the bank. Federal regulators haven’t even given them a good slap on the wrist.

“Had this been a community bank board and senior managers, not only would they all have been removed from the bank months ago, but they would also be facing prosecution. Yet nothing has happened to Wells, its senior management or its board.

“Wells Fargo’s conduct is outrageous and unacceptable. No community bank would have been given this kind of regulatory deference. There is not supposed to be a double standard for regulation and enforcement in this nation, but the wrongdoings of Wells Fargo show us that apparently one exists for too-big-to-fail banks. Federal regulatory authorities are too compromised to take meaningful action against the too-big-to-fail banks like Wells Fargo. We all know that too-big-to-fail is too-big to-manage. Now it appears that the nation’s largest financial firms are too big to regulate as well.

“This egregious mayhem done upon millions of Wells Fargo customers has got to stop. Wells Fargo’s wrongdoing is tarring the good reputations of thousands of community banks and bankers who serve their communities and customers honestly every day.

 “The Wells Fargo board should be replaced, and so should its senior management. End of story.”  

About ICBA
The Independent Community Bankers of America®, the nation’s voice for more than 5,800 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 ICBA’s website at

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Senators Crapo and Brown

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