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VOL. 12, NO. 3 • FEBRUARY 2017

DALLASFED

Economic
Letter
Small-Business Lending Languishes
as Community Banking Weakens
by Kelsey Reichow

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ABSTRACT: Community banks
are key providers of loans
to small businesses, which
are important contributors
to the local economy and
international trade. While
regulatory burden on small
banks and its impact on
lending has received attention,
it is difficult to isolate the most
significant driver of sluggish
small-business lending.

A

merica’s small businesses have
struggled securing credit since
the end of the financial crisis
in 2009. Small-business loans
at U.S. commercial banks have declined
15 percent from their precrisis high, while
total business loans increased 33 percent
(Chart 1).
As a result, small-business loans’ share
of total bank loans is down 13 percentage
points. The trend extends beyond the crisis, as small-business loans —those with
original amounts of less than $1 million—
have shrunk from almost 40 percent of the
overall business loan portfolio in 2004 to
20 percent in 2016.
This is particularly worrisome because
small businesses, defined as those with
fewer than 50 employees, are significant
job creators. Small businesses employ
about 120 million people, roughly half of
the nation’s private-sector workforce. New
firms in particular—almost all of which
are small—are responsible for a majority
of total net job creation.1 Moreover, the
Federal Reserve Bank of Cleveland’s 2015
Small Business Credit Survey found that 95
percent of all firms employed fewer than
50 people.2
A less-heralded role small business
fills is that of driving innovation. Relative
to larger enterprises, small business
develops more patents per employee,
with the smallest firms (fewer than 25

employees) producing the greatest number per employee.3 More broadly, small
businesses contribute significantly to
private nonfarm gross domestic product
and to international trade, comprising more than 97 percent of exporters
and importers and roughly one-third of
export and import value.4

Community Banks and Lending
Community banks, those with less
than $10 billion in assets, are a key local
source of credit, particularly for small
businesses. While small-business loans
comprise 35 percent of small-banks’
assets, they only made up 2 percent of
that for larger banks in 2016 (Chart 2).
This proportion has held over time. In
2007, small-business loans made up
roughly 44 percent of small-banks’ assets
compared with only 3 percent for larger
banks. This partly reflects that large borrowers’ capacity to borrow from community banks is limited by institutional
size and small banks’ need to maintain a
diversified portfolio.
This high concentration of smallbusiness loans highlights a possible
unintended consequence of the consolidation among community banks: making it more difficult for small business to
access credit.
The number of community banks
has steadily declined, with contraction

Economic Letter
Chart

1

U.S. Banks Cutting Small-Business Loan Concentrations

Amount outstanding (billions of dollars)

3,500

Percent of business loans

45

Small business,
percent of total

Total business loans

Small-business loans

3,000

40
35

2,500

30

2,000

25

1,500

20
15

1,000

10

500
0

5
2000

2002

2004

2006

2008

2010

2012

2014

2016

0

NOTES: Data are adjusted for inflation. Data are year end except for 2016, which is through June 2016.
SOURCE: Consolidated Reports of Condition and Income, Federal Financial Institutions Examination Council.

Chart

2

U.S. Community Banks Focus on Small-Business Loans

Business loans, percent of assets

35
30

Business loan size
Less than $1M

$1M +

25
20
15
10
5
0

< $100M $100M– $1B–
> $10B
$1B
$10B
Asset size group, 6/3/2007

< $100M $100M– $1B–
> $10B
$1B
$10B
Asset size group, 6/30/2016

SOURCE: Consolidated Reports of Condition and Income, Federal Financial Institutions Examination Council.

particularly pronounced among the smallest banks (Chart 3). The number of institutions with assets less than $100 million fell
roughly 64 percent between 2000 and 2016,
from 4,528 institutions to 1,636 as of June
2016.5 As a group, the number of community banks has dropped by just more than
40 percent since June 2000.
Moreover, although bank failures have
eased from peak levels in 2009 and 2010, as
broader industry conditions improve, few
new banks are being formed. On average,
138 new banks were chartered each year
from 1990 to 2010; only one new bank has

2

been chartered during each of the past five
years (Chart 4).6
Bankers argue the industry is less
inviting to newcomers. They cite reduced
earnings prospects due to the low interest
rate environment and greater expenses
required to meet demands of increasing
regulation attributable to the 2010 Dodd–
Frank Wall Street Reform and Consumer
Protection Act.7

Less Small-Business Credit
One way to determine the cause of
the drop in small-business loans is to

create hypothetical lending scenarios for
2016 based on prefinancial crisis data to
assess whether changes in banks’ smallbusiness lending practices or financial
institution consolidation best explain
the decline in the banks’ small-business
concentrations.
Controlling for the effects of consolidation explains only a small part of
the decline in banks’ small-business
portfolios; if banks had the same asset
size distribution today as in 2007, their
small-business portfolios would only be
$19 billion higher.
However, if small-business loans are
calculated based on 2007 small-business
loan concentrations for banks of each
size category, the data suggest a different story. If 2007 lending patterns stayed
consistent, banks would report more
small-business lending, even with the
consolidation experienced over the past
10 years (Chart 5). The data indicate
small-business loans make up a smaller
part of portfolios among banks of all
sizes.
The pullback in small-business
lending is a product of several factors,
with regulatory burden among the most
prominent. More stringent requirements
are also hurting larger banks’ ability to
provide credit to small businesses. Large
banks have indicated they are less likely
to make small loans because the cost
of processing a $100,000 loan is comparable to that of a $1 million loan.8 As
a result, large banks have significantly
reduced loans below a certain threshold,
typically $250,000, or have stopped lending to businesses with revenue less than
$2 million.9
The fixed costs associated with regulatory compliance, such as hiring another
employee to help comply with additional
requirements, make it disproportionately
expensive for smaller banks to adapt to
the tighter regulatory regime implemented
since the financial crisis. And, regulatory
burden hits the smallest community banks
much harder than the larger community
banks, as evidenced by comparing ratios of
total compliance expenses to noninterest
expenses. The average ratio of compliance
expenses to noninterest expenses was
roughly 8.9 percent for banks with assets of
less than $100 million compared with 2.9
percent for larger community banks, those

Economic Letter • Federal Reserve Bank of Dallas • February 2017

Economic Letter
with assets of $1 billion to $10 billion.10
Higher regulatory compliance expenses
shift resources from core operations.
There are also measurements of
regulatory burden outside of dollars and
cents. The size and complexity of the call
report—banks’ quarterly accounting of
their operations and finances—provide
a telling proxy for the increase in official
requirements. Call report filings were
four pages in 1950, grew to around 30
pages in the 1980s and are 84 pages currently. The number of items within them
also increased, from 53 at the end of 1970
to 2,379 in fourth quarter 2015.11
Regulators have taken some measures to ease the regulatory burden on
smaller institutions, such as reducing
the call report page count to 61 pages for
banks with assets of less than $1 billion.
Another notable regulatory barrier
for smaller banks is the standardization
of underwriting under the Dodd–Frank
Act, particularly involving the Consumer
Financial Protection Bureau created
under the act. Standardized models used
by regulators to identify safe products for
consumers may not be as applicable to
the community banking model, which
has historically been more dependent on
personal relationships.12
Credit availability for small business
appears to be improving but remains
relatively tight given current economic
conditions. Paradoxically, two surveys
of small-business owners—the monthly
National Federation of Independent
Businesses (NFIB) and the quarterly
Wells Fargo/Gallup survey—found
weaker demand for credit despite a
more optimistic outlook among smallbusiness owners. The December 2016
NFIB survey reported increasing smallbusiness optimism even as those businesses encountered difficulties fulfilling
their borrowing needs.13 However, the
2016 quarterly Wells Fargo/Gallup Small
Business survey suggests access to credit
is improving, with 36 percent saying it
was somewhat or very easy for their companies to obtain credit over the past 12
months—the highest level since fourth
quarter 2008.14

Lingering Structural Barriers
Community banks play an important role in lending to small business.

Chart

3

Consolidation Concentrated in Smallest Institutions

Number of institutions
11,000

Asset size

10,000

>10B
$1B–$10B

9,000

$100M–$1B
< $100M

8,000
7,000
6,000
5,000
4,000
3,000
2,000
1,000
0

2000

2002

2004

2006

2008

2010

2012

2014

2016

NOTES: Data are adjusted for inflation. Data are year end except for 2016, which is through June 2016.
SOURCE: Consolidated Reports of Condition and Income, Federal Financial Institutions Examination Council.

Chart

4

Rate of New Bank Formation Declines

Number of new charters

300
250
200
150
100
50
0

1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016

NOTE: Data are year end except for 2016, which is through 2016.
SOURCE: Federal Deposit Insurance Corporation.

Conventional wisdom suggests a decline
in the number of smaller banks has
reduced small businesses’ access to
credit. Yet, the decline in small-business
lending extends beyond financial industry consolidation.
Loan portfolios across banks of all
asset sizes are shifting away from smallbusiness loans, suggesting consolidation is not the greatest cause for a drop
in banks’ small-business lending. The
drivers behind banks reducing their
small-business lending include stricter
regulatory requirements, tighter lending
standards, shrinking demand for credit

and structural changes in the banking
industry.
While a great deal of attention has
been paid to the effects that regulatory
burden has had on banks and their ability to lend, challenges to small-business
lending were present before the financial
crisis and have only intensified since the
end of 2007.
It is too soon to tell if weaker smallbusiness lending represents a new, longer-run credit gap or if small businesses
will be able to adjust by obtaining credit
outside traditional channels. Whatever
the driving forces may be, it is imperative

Economic Letter • Federal Reserve Bank of Dallas • February 2017

3

Economic Letter

Chart

5

“Why Small-Business Lending Has Not Recovered,” by
Karen Mills, Forbes, Aug. 4, 2014, www.forbes.com/sites/
hbsworkingknowledge/2014/08/04/why-small-businesslending-has-not-recovered/#612b3a92c0b4.
10
“Bank Size, Compliance Costs and Compliance
Performance in Community Banking,” by Drew Dahl,
Andrew Meyer and Michelle Neely, Federal Reserve Bank
of St. Louis, May 2016, www.communitybanking.org/
documents/2016-Conference-Papers/Session2_
Paper2_Neely.pdf.
11
“Too Small to Succeed?—Community Banks in a New
Regulatory Environment,” by Preston Ash, Christoffer
Koch and Thomas F. Siems, Federal Reserve Bank of Dallas Financial Insights, vol. 4, no. 4, 2015, www.dallasfed.
org/outreach/insights.aspx#tab2.
12
“Regulatory Burdens: The Impact of Dodd–Frank on
Community Banking,” testimony by Hester Peirce, director
of Financial Markets Working Group, July 18, 2013, http://
mercatus.org/publication/regulatory-burdens-impactdodd-frank-community-banking.
13
Data from December 2016 Report: Small Business Optimism Index, National Federation of Independent Business,
November 2016, www.nfib.com/surveys/small-businesseconomic-trends/.
14
Data from Wells Fargo Survey: Small Business
Optimism Up Slightly in Third Quarter, Wells Fargo/
Gallup Small Business Index, August 2016,
https://wellsfargoworks.com/small-business-optimismup-slightly-in-third-quarter.
9

What Explains Soft Lending to Small Businesses?
Bank asset size
< $100M

$100M–$1B

$1B–$10B

2007 actual

> $10B

$789

2016 actual

$611

2016 hypothetical with
2007 bank asset
size distribution

$630

2016 hypothetical with
2007 small-business
loan concentration

$832
0

100

200 300 400 500 600 700 800
Small-business loans (billions of dollars)

900

SOURCES: Consolidated Reports of Condition and Income, Federal Financial Institutions Examination Council; author’s
calculations.

that small-business owners obtain adequate access to credit markets because
of the importance of small businesses to
the economy.
Reichow is a financial industry analyst in
the Financial Industry Studies Department
of the Federal Reserve Bank of Dallas.

Notes
“Who Creates Jobs? Small vs. Large vs. Young,” by
John C. Haltiwanger, Ron S. Jarmin and Javier Miranda,
National Bureau of Economic Research, NBER Working
Paper no.16300, August 2010, www.nber.org/papers/
w16300.pdf.
2
“2015 Small Business Credit Survey Report on Nonemployer Firms,” Federal Reserve Bank of Cleveland, December 2016, www.clevelandfed.org/community-development/
small-business/about-the-joint-small-business-creditsurvey/2015-joint-small-business-credit-survey.aspx.
1

DALLASFED

“An Analysis of Small Business Patents by Industry
and Firm Size,” by Anthony Breitzman and Diana
Hicks, November 2008. A report developed under a
contract with the Small Business Administration, Office
of Advocacy, http://rdw.rowan.edu/cgi/viewcontent.
cgi?article=1011&context=csm_facpub.
4
Data from SBE Council Database, Small Business Facts
& Data, http://sbecouncil.org/about-us/facts-and-data/.
5
Institutions include both commercial banks and savings
and loan associations.
6
Data from FDIC Statistics at a Glance, Commercial Banks
and Savings Institutions data for New Reporters from
1990–2016 year to date.
7
“Community Banking in the 21st Century,” Federal
Reserve Bank of St. Louis, Sept. 28–29, 2016, www.
communitybanking.org/documents/2016-ConferencePapers/CB21Cpublication_2016.pdf.
8
“Fall of 2013 Small Business Credit Survey,” by Federal
Reserve Bank of New York, September 2013, www.
newyorkfed.org/smallbusiness/Fall2013/index.html.
3

Economic Letter

is published by the Federal Reserve Bank of Dallas.
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should not be attributed to the Federal Reserve Bank
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Economic Letter is available on the Dallas Fed
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