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 Denounces Megabanker Claim of Too Many Banks

Oct 20, 2017
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Washington, D.C (Oct. 20, 2017)—Independent Community Bankers of America® (ICBA) President and CEO Camden R. Fine released the following statement on claims from Kelly King, the head of $220 billion-asset megabank BB&T, that there are too many U.S. banks.

“ICBA strongly disagrees that there too many banks in the United States. On the contrary, decades-long consolidation of the U.S. banking system into fewer and fewer hands has contributed to a decline in access to financial services for many communities, a reduction in consumer choice, and the exponential growth of too-big-to-fail financial institutions. This consolidation, fueled by rising regulatory burdens on community banks, culminated in the 2008 Wall Street financial crisis and the worst economic downturn since the Great Depression—a calamity from which we are still recovering. Not all banks are the same, and the community bank voice needs to be differentiated, elevated and heard.

“Locally based community banks are highly capitalized, reinvest in their communities, provide local leadership, and operate a business model built on relationships and accountability to the customers they serve. While these local institutions are the only physical banking presence in nearly one in five U.S. counties, their numbers have dwindled by roughly 1,500 since 2009. Meanwhile, the trickle of new, de novo banks entering the market further inhibits access to credit and financial services in communities overlooked by larger institutions.

“The nation’s growth and development over the past century and a half is due in no small part to its economic diversity and access to local sources of capital. Community banking is synonymous with the American traditions of independence, self-reliance and entrepreneurship. It goes to the heart of what we believe as a nation: that we are stronger from the bottom up than from the top down. That we are more powerful collectively when we are empowered individually.

“The challenge facing the banking industry today is not how to bump off more locally based competition to benefit megabank investors, but how to maintain a diverse and decentralized system to ensure continued access to financial services for all Americans. While megabank CEOs and their representatives in Washington might think there are too many banks, in truth there are not enough.”

About ICBA
The Independent Community Bankers of America®, the nation’s voice for more than 5,700 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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