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

Megabanks Admit Ditching Local Communities

Mar 22, 2019
A new report from the nation’s largest financial institutions confirms they are withdrawing from Main Street communities while community banks reinvest in them, ICBA said.

The Bank Policy Institute—which represents the largest banks—reported that while deposit growth in urban areas is higher at megabanks, community banks are more than tripling the deposit growth of their larger competitors in rural communities.

ICBA President and CEO Rebeca Romero Rainey said the report shows the local communities hit hardest by the Wall Street financial crisis are being left behind by the entities that caused it while community banks are busy adding new bank offices to meet these areas’ needs.

“As the only physical banking presence for one in five U.S. counties, the nation’s community banks will continue their work in fostering economic vitality in every corner of every community, whether urban, suburban or rural,” she said.

Read the BPI Report
Read ICBA Release

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