While post-GFC regulations targeted "too big to fail" institutions, their primary victim was the community banking sector. The new regime made it "too small to succeed," causing half of these banks to disappear. This choked off credit for small businesses and real estate, hindering Main Street's recovery.
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Large banks have offloaded riskier loans to private credit, which is now more accessible to retail investors. According to Crossmark's Victoria Fernandez, this concentration of risk in a less transparent market, where "cockroaches" may be hiding, is a primary systemic concern.
According to PIMCO's CIO, post-crisis regulation heavily targets the last failure point (e.g., banks and consumer lending post-GFC). This makes previously regulated sectors safer while risk migrates to areas that escaped scrutiny, like today's non-financial corporate credit market.
Contrary to popular belief, community banks' CRE loans are not to large, vacant office towers. Their portfolios consist of local, stable properties like gas stations and small professional offices. This localized knowledge and asset type make their CRE exposure far less risky than that of larger banks.
The concept of 'banking deserts' extends beyond underserved regions. When specialized banks like SVB disappear, entire industry verticals (like tech, agriculture, or wine) can become 'underbanked.' This creates a vacuum in specialized credit and financial services that larger, generalist banks may not fill, thus stifling innovation in specific economic sectors.
Regulatory capture is not an abstract problem. It has tangible negative consequences for everyday consumers, such as the elimination of free checking accounts after the Dodd-Frank Act was passed, or rules preventing physicians from opening new hospitals, which stifles competition and drives up costs.
The US banking system is technologically behind countries in Eastern Europe, Asia, and Latin America. This inefficiency stems from a protected regulatory environment that fosters a status quo. In contrast, markets like the UK have implemented fintech-friendly charters, enabling innovators like Revolut to thrive.
Banks started in the 80s and 90s are led by founders nearing retirement. With no new generation of talent eager to run small, three-branch banks, these institutions are increasingly looking for an exit. This succession problem is a primary driver of M&A activity in the sector.
The system often blamed as capitalism is distorted. True capitalism requires the risk of failure as a clearing mechanism. Today's system is closer to cronyism, where government interventions like bailouts and regulatory capture protect established players from failure.
Enormous government borrowing is absorbing so much capital that it's crowding out corporate debt issuance, particularly for smaller businesses. This lack of new corporate supply leads to ironically tight credit spreads for large borrowers. This dynamic mirrors the intense concentration seen in public equity markets.
While the Dodd-Frank Act successfully bolstered regulated banks, it pushed systemic risk into less visible parts of the financial system like crypto. The challenge has transformed from managing institutions that are 'too big to fail' to identifying risks in areas that are 'too small to see' and outside the regulatory perimeter.
