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: Compliance Costs Exacerbate Industry Consolidation

Oct 23, 2017
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Washington, D.C (Oct. 23, 2017)—Independent Community Bankers of America® (ICBA) President and CEO Camden R. Fine released the following statement on today’s speech from FDIC Chairman Martin Gruenberg on the importance of community banks.

“ICBA strongly agrees with Chairman Gruenberg that community banks are vital to the U.S. financial system and economy because of their emphasis on small-business and farm lending and on serving markets neglected by larger institutions. ICBA also shares Chairman Gruenberg’s concern with the lack of de novo formation, consolidation in the banking industry and the cost of regulatory compliance on community banks—issues that are closely related.

“As the Federal Reserve and Conference of State Bank Supervisors recently reported in a new survey, community bank compliance costs have increased by nearly $1 billion in the past two years to $5.4 billion, or 24 percent of community bank net income. Of the survey respondents who said they considered an acquisition offer in the past year, virtually all (96.7 percent) said regulatory costs were a very important, important or moderately important reason—showing a direct impact of regulatory burden on community bank consolidation.

“ICBA will continue working with regulators, Congress and the administration to address the harmful impact of excessive regulatory burdens on community banks and the customers and communities they serve.”

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


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