The existing rules and oversight are not up to the acute regulatory challenge imposed by the biggest banks. First, they are sprawling and complex—so vast that their own management teams may not fully understand their own risk exposures. If that is so, it would be futile to expect that their regulators and creditors could untangle all the threads, especially under rapidly changing market conditions. Second, big banks may believe they can act recklessly without fear of paying the ultimate penalty. They and many of their creditors assume the Fed and other government agencies will cushion the fall and assume the damages, even if their troubles stem from negligence or trickery. They have only to look to recent experience to confirm that assumption.
Richard Fisher expressed his concerns in his annual 2011 report Five big banks now own 52% of the industry's assets:However, Dodd–Frank does not eradicate
TBTF. Indeed, it is our view at the Dallas
Fed that it may actually perpetuate an already
dangerous trend of increasing banking industry
concentration. More than half of banking
industry assets are on the books of just five
institutions. The top 10 banks now account
for 61 percent of commercial banking assets,
substantially more than the 26 percent of only
20 years ago; their combined assets equate to
half of our nation’s GDP.
Another Fed Chief in Philadelphia called for the big banks to be broken up. Click here to read.
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