Harvey Rosenblum, Director of Research for the Dallas Fed, has written an interesting if flawed report on the status of “Too Big to Fail” and the early results of the Dodd-Frank reforms. Some highlights include:

  1. Since the 1970’s the share of assets of the five largest banks has grown from 17% to 52%. As Rosenblum notes, with size comes complexity, and with complexity the opportunities for obfuscation, malfeasance, and creative greed.
  2. Smaller banks generally weathered the crisis better, and are generally in better shape now. Most TBTF banks still have toxic assets which still infect the whole economy.
  3. Dodd-Frank remains a work in progress, as its broad prescriptions are turned into rules by the required agencies, and this process has introduced more uncertainty into the system. But it is fighting size and complexity with size and complexity, leaving the larger banks, with its squadrons of lawyers, lobbyists and accountants, in an advantageous position, and the smaller banks, who have no choice but to comply with the costly demands, in a tenuous one. The smaller banks face the burdens of these regulations even if they didn’t do anything wrong the first time around.
  4. So long as the Fed maintains its remarkably low interest rates it will be encouraging debtors and effectively penalizing savers.
  5. He recommends breaking up the larger banks into smaller ones as “the ultimate solution” for TBTF – one that seems almost self-evident.

One might quibble with his overall endorsement and understanding of capitalism, but I think it is pretty clear that Congress hasn’t done some of the things that need to be done in order to restore some sanity to the system, including reviewing the role of the Fed itself. Clearly one of the main problems in the collapse of ’08 was the behavior of the ratings agencies, and Dodd-Frank doesn’t address them at all. These are an obvious problem in the system, especially when one considers how the ratings work and how the agencies are incentivized or not by that which they are rating.

Then too, there is the problem of implementing such regulations. The NYSE does around $15 trillion in sales annually with hundreds of thousands of exchanges daily and has, if I’m not mistaken, five full time regulators overseeing it.

One reads reports such as this with a deepening sense that this is far, far from over.

Local Culture
Local Culture
Local Culture
Local Culture
Previous articleThe Hunger Games: Kids Killing Kids
Next articleThe Mishawaka Cruisers
Jeffrey Polet
Jeffrey Polet grew up in an immigrant household in the immigrant town of Holland MI. After twenty years of academic wandering he returned to Holland and now teaches political science at Hope College, where he also grudgingly serves as chair of the department, having unsuccessfully evaded all requests. In the interim, he continues to nurture quirky beliefs: Division III basketball is both athletically and morally superior to Division I; the Hope/Calvin rivalry is the greatest in sports; the lecture is still the best form of classroom instruction; never buy a car with less than 100,000 miles on it; putts will still lip out in heaven; bears are the incarnation of evil; Athens actually has something to do with Jerusalem; and Tombstone is a cinematic classic. His academic work has mirrored his peripatetic career. Originally trained at the Catholic University of America in German philosophy and hermeneutical theory, he has since gravitated to American Political Thought. He still occasionally writes about European thinkers such as Michel Foucault or the great Max Weber, but mostly is interested in the relationship between theological reflection and political formation in the American context. In the process of working on a book on John Marshall for The Johns Hopkins University Press, he became more sensitive to the ways in which centralized decision-making undid local communities and autonomy. He has also written on figures such as William James and the unjustly neglected Swedish novelist Paer Lagerkvist. A knee injury and arthritis eliminated daily basketball playing, and he now spends his excess energy annoying his saintly wife and their three children, two of whom are off to college. Expressions of sympathy for the one who remains can be posted in the comments section. He doesn’t care too much for movies, but thinks opera is indeed the Gesamtkuntswerk, that the music of Gustav Mahler is as close as human beings get to expressing the ineffable, that God listens to Mozart in his spare time, and that Bach is history’s greatest genius.


  1. Breaking up banks that are “too big to fail” is indeed a no-brainer.

    Apparently the Obama administration lacks sufficient independence to take such a momentous step. This may be because they are beholden to donors in the financial service industry, or because if he moved decisively, President Obama would be labeled “a socialist” once more. Perhaps both. Maybe Rosenblum can give the president some “right cover” to do the right thing.

    Dodd-Frank is condemnably complex in part because congress paid too much attention to the myriad objections of lobbyists, who are now complaining that the whole thing should be scrapped because it is so complex. A sound regulatory scheme would make the costs and burdens of regulation steeper as size and complexity of an institution increased. Done right, size would reach a point of diminishing returns.

    That doesn’t mean small institutions should face NO regulation. Small institutions can commit fraud also, and the Savings and Loan scandal showed how fraudsters could buy up and suck the life out of “small” institutions to run a scam. But, small institutions don’t need as detailed or expensive a set of regulation. Their books can be reviewed by a smaller staff, and their scope to do damage to the entire economy is much less.

Comments are closed.