Download Ending Too-Big-To Fail - The Independent Community Bankers of

March 14, 2013
Ending Too-Big-To Fail
On behalf of the 7,000 community banks represented by the Independent Community Bankers of
America, thank you for convening today’s hearing titled: “Who is Too Big to Fail? GAO’s
Assessment of the Financial Stability Oversight Council and the Office of Financial Research.”
We are pleased to submit the following statement for the record.
The greatest threat to the safety and soundness of our financial system today is the ongoing and
increasing dominance of too-big-to-fail institutions. Today, the four largest banking companies
control more than 40 percent of the nation’s deposits and more than 50 percent of the assets held
by U.S. banks. The largest banks have grown larger since the financial crisis of 2008. The ten
largest hold 77 percent of all U.S. bank assets compared with 55 percent of total assets in 2002,
according to a study by Bloomberg Government.i This concentration of banking assets in ten
institutions contravenes the public interest. A more diverse financial system would reduce risk
and promote competition, innovation, and the availability of credit to consumers of various
means and businesses of all sizes. ICBA looks forward to the results of a current Government
Accountability Office study evaluating the potential market distortions caused by too-big-to-fail
financial institutions.
Adding insult to injury, the Attorney General recently stated that federal law enforcement has
been inhibited from prosecuting large, interconnected institutions due to the “negative impact on
the national economy.” Large or interconnected institutions are too-big-to-prosecute and their
executives are too-big-to-jail. The very firms that have inflicted the most abuse on consumers
and the most damage to our financial system and economy – the firms whose executives most
deserve to be jailed – are effectively immune from prosecution. As if we did not have incentive
enough already to end the dominance of too-big-to-fail institutions. The Attorney General’s
statement reveals a new, appalling aspect of the problem.
As a result of the financial crisis of 2008, our nation went through an agonizing series of forced
buy-outs or mergers of some of the nation’s largest banking and investment houses, costing
American taxpayers hundreds of billions of dollars. Some mega-institutions – too-big-to-fail and
also too big-to-be-sold to another firm – were directly propped up by the government. The
doctrine of too-big – or too-interconnected – to-fail finally came home to roost. Our nation
cannot afford to go through that again.
The cost of the financial crisis and the resulting bailouts is not limited to taxpayer dollars and
market distortions. Another no less significant legacy of the crisis is the onslaught of new
regulations – aimed at large banks but sweeping in banks of all sizes – that has created a crushing
burden for community banks. These low-risk, community-based institutions did not cause the
crisis and pose no threat to consumers or the financial system. ICBA’s Plan for Prosperity (PFP)
would provide relief from regulatory burden and help community banks reach their full potential
as catalysts for entrepreneurship, economic growth, and job creation. We encourage this
committee to give serious consideration to the PFP, which consists of a dozen provisions
2
selected with input from community bankers nationwide and crafted to preserve and strengthen
consumer protections and safety and soundness. Each provision of the PFP has come before this
committee in prior congresses and is therefore positioned for immediate action.
Thank you again for the opportunity to submit this statement for the record. ICBA is committed
to working with this committee to end the problem of too-big-to fail banks and to advance the
provisions of the PFP.
i
“Too Big To Fail?” Bloomberg Government. March 18, 2011.