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

Blog: Megabanks Continue Exiting Local Communities

Nov 04, 2019

ICBA President and CEO Rebeca Romero Rainey wrote in a new blog post that the latest news from Wells Fargo reinforces that when the going gets tough, the megabanks head for the exits.

In Main Street Matters, Romero Rainey wrote that Wells Fargo's cutbacks of agricultural lenders in rural areas is part of the growing trend of megabanks withdrawing from Main Street communities.

"Unlike the megabanks, community banks are not fair-weather lenders," she wrote. "We stick with our borrowers in good times and bad because we are rooted in the communities we serve."

Read the 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