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

Title Publication Date
Comment Letter Regarding DOJ's Bank Merger Competitive Review Guidelines Testimony, NewsWatch Today Article, Letters to Regulators 09/30/20
Community Banks Are the Megabank Alternative Press Release, News 04/10/19
Romero Rainey: Another Wall Street Tall Tale NewsWatch Today Article 03/05/19
Agencies Planning Resolution Reform: McWilliams NewsWatch Today Article 11/29/18
ICBA Opposes Plan to Ease Capital Rules on Riskiest Megabanks Press Release 06/13/18
ICBA Statement on Minneapolis Fed Plan to End Too-Big-To-Fail Press Release 11/16/16
ICBA: Hold Wall Street Bad Actors Personally Accountable Press Release 09/30/13
ICBA: Greatest Threat to Financial System is Too-Big-To-Fail Press Release 06/26/13
ICBA Lauds Brown-Vitter Legislation Taking on Too-Big-To-Fail Press Release 04/24/13
ICBA: Survey Shows Americans Want Washington to Address Too-Big-To-Fail Problem Press Release 03/21/13
ICBA: Evidence Mounting against Too-Big-To-Fail Press Release 03/18/13
ICBA: Senate Report Shows Continued Threat of Too-Big-To-Fail Press Release 03/15/13
ICBA Stands with Sens. Brown and Vitter Against Wall Street Spin Machine Press Release 03/11/13
Too Big to Jail? Press Release 01/24/13
ICBA Backs Dallas Fed Plan to Restructure Too-Big-To-Fail Firms Addressing Systemic Risks, Reinforcing Market Discipline Needed for Long-Term Stability Press Release 01/17/13

Letters to Congress

Title Recipient Date
Senators Crapo and Brown

Letters to Regulators

Title Recipient Date
USPS Office of Inspector General
U.S. Postal Regulatory Commission
Federal Reserve, OCC
Federal Reserve, OCC


Title Committee Presenter Date


Title Content Type Date