Are Some Banks Too Large To Fail? Myth And Reality

At the time of the Continental Illinois National Bank insolvency, bank regulators considered some commercial banks “too large to fail” (TLTF) and were reluctant both to legally fail such banks and to impose pro rata losses on any of the uninsured creditors of these insolvent banks and their parent holding companies. This policy was introduced due to widespread fears that large bank failures would set off a domino effect bringing down other banks and possibly even the macroeconomy as it did during the 1930s. Also, because these banks are considered special in that they provide money and credit to their communities, many feared that their failure could reduce greatly the availability of these services. This paper analyzes the validity of these fears by examining both theory and the historical record. It concludes that neither theory nor history provides strong support for either fear. In addition, the paper finds that the costs of regulatory forbearance granted to insolvent banks and their creditors greatly exceed the alleged benefits. It also reviews how policy makers apply the TLTF principle in practice. The paper concludes that the policy has been modified progressively over time so that some large banks now are declared legally insolvent and all creditors of bank holding companies—and some uninsured creditors of the banks themselves—incur losses. One may reasonably expect that TLTF will be modified further as the large societal costs become more evident to the public and regulators alike.