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

Romero Rainey: Another Wall Street Tall Tale

Mar 05, 2019

While megabanks have been withdrawing from local communities in the wake of the financial crisis they created, a new Wall Street Journal article claims these areas can’t possibly get by without them, ICBA President and CEO Rebeca Romero Rainey writes. ICBA and community bankers have a more positive story to share, she wrote on Main Street Matters.

Romero Rainey pushed back against the misleading article by noting that community bank acquisitions of megabank branches are more often an economic boon for local communities. She noted that community banks are out-lending their competitors, have been adding bank offices while noncommunity bank offices are declining, and are taking advantage of innovative banking technologies.

“We at ICBA know better than to buy into the megabank spin,” Romero Rainey wrote. “So community bankers, let’s continue to keep up the good work in serving our customers, innovating, meeting the needs of our communities, and brushing off the negativity from our megabank competitors.”

Read ICBA Blog Post

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