top of page
Writer's pictureJames Ross

New Fed Proposal to Tackle "Too Big to Fail" Risks: A Step Towards a More Resilient Financial System?

The 2007 financial crisis highlighted the dangers of "Too Big to Fail" (TBTF) financial institutions. These behemoths so interconnected with the economy, posed a threat that their collapse could trigger widespread financial chaos. The Federal Reserve Board (Fed) proposes a new approach to mitigate these risks, aiming to create a more resilient financial system.



The Proposed Approach: A Three-Pronged Strategy


  1. Identification: If they fail, the Fed will identify Systemically Important Financial Institutions (SIFIs) based on their size, interconnectedness, and potential economic impact. This identification will include both banks and non-bank financial firms, ensuring a comprehensive approach to risk assessment.

  2. Capital Surcharges: SIFIs will face additional capital requirements proportionate to their systemic importance. This aims to create a buffer against potential losses and incentivise SIFIs to reduce their risk profile.

  3. Persistent Monitoring: The Fed will continuously monitor SIFIs, reassessing their systemic importance and adjusting capital surcharges as needed. This ensures the regulatory framework remains adaptable to the ever-evolving financial landscape.


Firm Implications: A Balancing Act


The proposed approach carries both potential benefits and drawbacks for financial institutions:


  • Increased Capital Requirements: This could squeeze profitability and limit growth potential, especially for smaller institutions struggling to meet the additional capital demands.

  • Incentive to Reduce Risk: SIFIs will be encouraged to adopt less risky business practices, enhancing overall financial stability.

  • Enhanced Stability: By reducing the likelihood and impact of SIFI failures, the entire financial system becomes more resilient.

  • Level Playing Field: The new methodology aims to treat banks and non-bank financial firms equally, ensuring a fairer regulatory environment.


Conclusion: A Step in the Right Direction


The Fed's proposal marks a significant step towards addressing the TBTF problem. By incentivising SIFIs to become less risky and making their potential failures more manageable, it aims to protect the broader economy from future financial crises. However, the increased regulatory burden on firms and the potential impact on profitability cannot be ignored.


The future of this proposal remains uncertain, and it will likely undergo scrutiny and debate. Nevertheless, it sparks an important conversation about how to ensure the stability of our financial system while fostering a competitive and innovative environment.


Sign up to be notified about the latest updates of what we think

The posts listed on the 'What we think' webpages are our interpretation of regulatory developments we have been reading about. They should not be considered legal, regulatory or other advice. Contact us if you want to understand the impact of public policy, regulation and governance changes for you.

bottom of page