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: Community Banks Are the Megabank Alternative

Apr 11, 2019
With CEOs from seven of the nation’s largest financial institutions testifying before Congress, ICBA reminded policymakers of the positive role community banks serve in their local communities.

In a news release ahead of the hearing, ICBA said community banks continue to be leading small-business and agricultural lenders even while operating within the strenuous regulatory requirements and economic fallout often provoked by the misbehavior of the megabanks.

ICBA also cited the bipartisan policy recommendations included in its Community Focus 2020 policy platform.

“ICBA and the nation’s community banks look forward to continuing to work with policymakers on common-sense reforms that will help these local institutions promote greater access to financial services and economic opportunity throughout every corner of the country,” ICBA President and CEO Rebeca Romero Rainey said.

The hearing touched on a range of issues, including systemic risks posed by the megabanks, cybersecurity concerns, fintech and cryptocurrency, financing gun manufacturers and energy companies, and serving unbanked communities.

Read ICBA Release
View the Hearing

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