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DALLASFED
VOLUME 2, ISSUE 1
FEBRUARY 28, 2013

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CALENDAR OF EVENTS
March 19
Corporate Payments Council
Meeting
Dallas, TX

March 21–22
Economic Roundtable
Fort Worth, TX

March 26
Community Depository
Institutions Advisory Council
Meeting
Dallas, TX

Financial Insights
FIRM • FINANCIAL INSTITUTION RELATIONSHIP MANAGEMENT

The Time-Proven Community Bank Model
by Thomas F. Siems

F

rom the mid-1960s through the mid-1980s, the number of commercial banks in the United
States did not change much, fluctuating generally in the range from 13,500 to 14,500. But
in 1984, the number of commercial banks peaked at 14,470 and has gradually declined
to around 6,100 today. Chart 1 shows that, during the same time, the average inflation-adjusted
bank size increased from under $200 million in the mid-1980s to more than $900 million today.

Chart

1

Number of banks

March 28

16,000

Economic Roundtable
Sulphur Springs, TX

14,000

April 10
Dialogue with the Dallas Fed
Louisiana Tech University

The Trend Is Toward Fewer and Larger Banks

12,000

Average assets (dollars in millions)

1,000
900
Number of banks

800
700

10,000

600

8,000

500

April 11

6,000

400

Dialogue with the Dallas Fed
Tarleton State University

4,000

April 16
Economic Roundtable
Midland, TX

April 18–19
Economic Roundtable
Kilgore, TX

April 25
Economic Roundtable
El Paso, TX

May 17
Economic Insights:
Conversations with the
Dallas Fed
Webcast

May 29–30
Economic Roundtable
Amarillo, TX
For more information about
these events, email FIRM at
Dallas_Fed_Firm@dal.frb.org.

2,000

300
Average bank size

200
100

0
0
’66 ’68 ’70 ’72 ’74 ’76 ’78 ’80 ’82 ’84 ’86 ’88 ’90 ’92 ’94 ’96 ’98 ’00 ’02 ’04 ’06 ’08 ’10 ’12

Moreover, the share of banking industry assets held by the largest banks has become
increasingly concentrated, while the share of assets held by smaller institutions has contracted.
In 1992, 72 percent of the commercial banks were small institutions with total assets under $100
million. These small banks controlled nearly 10 percent of total banking industry assets. By
2012, only 33 percent of banks were considered small, and they held under 1 percent of banking
industry assets.
By contrast, the largest banks—those with total assets of more than $1 billion—made up 3.3
percent of the banks in 1992 and controlled 71 percent of industry assets. In 2012, the billiondollar banks constituted 8.5 percent of the banking institutions and held 91 percent of the
industry’s assets.
Today, many consumers, business leaders, bankers and policymakers are questioning whether
the dual trends of fewer and larger commercial banks are good for the national economy. Are the
biggest banks too big? Are they too complex? If so, do big and complex banks create any special
problems? And what about the smaller community banks? What role do small banks play in the
economy? Is this role unique? What is the future for smaller community banks?

FIRM • Financial Institution Relationship Management
Federal Reserve Bank of Dallas
2200 N. Pearl St., Dallas, TX 75201

DALLASFED
Financial Stability: Traditional Banks Pave the Way. Earlier this year, the Federal

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Reserve Bank of Dallas released a series of five online essays that consider these broad trends
and rethink America’s banking system. These essays provide evidence that the best path to
addressing much of the uncertainty that continues to plague the U.S. economy and returning it
to prosperity is to:

DALLAS FED RESOURCES
Special Report
“Financial Stability:
Traditional Banks Pave the
Way”

Economic Insights:
Conversations with the
Dallas Fed (webcast)
“Ending Too Big to Fail:
A Program for Financial
Reform”

Texas Economic
Indicators
Economic Updates
Regional—“Regional
Economy Grows at a
Moderate Pace”

1. restore market discipline to banks of all sizes and ensure that no institution is “too big
to fail” (TBTF), and
2. return to the old and familiar traditional community bank model—built on long-term
relationships and time-tested judgment—that results in better lending decisions, more
small business lending and greater financial stability.
While each essay is briefly summarized below, readers are encouraged to follow the links in this
article to read all of the essays and get the most complete picture for these arguments.

Community Banks Withstand the Storm examines the inherent stability of smaller,
customer-focused institutions. Locally owned and operated banks are generally financially
conservative and depend on a relationship lending model. That is, community banks
know their customers and, when making lending decisions, look beyond credit scores and
quantitative assessments used by their larger competitors. Firsthand knowledge of a borrower’s
creditworthiness and vital customer information not readily or easily captured quantitatively
appear to be far more valuable in generating and maintaining higher loan quality. Chart 2
is likely the most demonstrative chart in all of the essays. The chart clearly shows that the
performance of community banks in maintaining residential real estate loan quality during
and after the Great Recession (2008–09) has been far superior to that experienced by the nation’s
largest institutions.

National—“Factors
Restraining U.S. Economy
Should Lessen”
International—“Financial
Risks Ease, but Effects May
Be Slow to Reach Global
Economy”

Chart

2

Residential real estate loans, percent noncurrent

Dallas Beige Book

14

Texas Business Outlook
Surveys

12

Agricultural Survey
Southwest Economy
“Determining
Creditworthiness and Texas’
Case for a Top Rating”

Economic Letter
“Falling Off the Fiscal Cliff”

Building Wealth
“A Beginner’s Guide to
Securing Your Financial
Future”

Community Banks Maintain Residential Real Estate Loan Quality

10
8

Bank asset size
Over $250 billion
$10–$250 billion
$1–$10 billion
Less than $1 billion

6
4
2
0

2008

2009

2010

2011

2012

NOTE: Data for commercial banks. Residential real estate loans are closed-end, first-lien one- to four-family mortgages. Asset size
is based on the total assets (expressed in June 2012 prices) of a U.S. banking organization (holding company, when applicable).
Noncurrent loans are loans past due 90 days or more and loans no longer accruing interest. Noncurrent loan rates have been adjusted
to exclude loans rebooked from Government National Mortgage Association securitizations.
SOURCES: Call Report, Federal Financial Institutions Examination Council; Consolidated Financial Statements for Bank Holding
Companies (FR Y-9C), National Information Center data, Federal Reserve System.

Community Banking
Connections
Find other resources on the
Dallas Fed website at
www.dallasfed.org.

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FIRM • Financial Institution Relationship Management
Federal Reserve Bank of Dallas
2200 N. Pearl St., Dallas, TX 75201

DALLASFED
A Lender for Tough Times shows how smaller institutions support their customers during

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recessions. Unlike the biggest financial institutions, smaller community banks continued to
provide credit to firms, especially small businesses, during and after the recent financial crisis.
These smaller banks depended heavily on their relationship lending model and provided credit
to many businesses when it was needed most, proving that they were a more stable source
of credit. Smaller community banks were able to continue lending during these tough times
because they were far more adept at making good loans.

ABOUT FINANCIAL
INSIGHTS AND FIRM
Financial Insights is
published periodically by
FIRM – Financial Institution
Relationship Management –
to share timely economic
topics of interest with
financial institutions.
FIRM was organized in 2007
by the Federal Reserve Bank
of Dallas as an outreach
function to maintain mutually
beneficial relationships
with all financial institutions
throughout the Eleventh
Federal Reserve District.
FIRM’s primary purpose
is to improve information
sharing with district financial
institutions so that the
Dallas Fed is better able
to accomplish its mission.
FIRM also maintains the
Dallas Fed’s institutional
knowledge of payments,
engaging with the industry to
understand market dynamics
and advances in payment
processing.
FIRM outreach includes
hosting economic roundtable
briefings, moderating CEO
forums hosted by Dallas
Fed senior management,
leading the Dallas Fed’s
Community Depository
Institutions Advisory Council
(CDIAC) and Corporate
Payments Council (CPC),
as well as creating relevant
webcast presentations and
this publication. In addition,
the group supports its
constituents by remaining
active with financial trade
associations and through
individual meetings with
financial institutions.

Small Banks Squeezed discusses small banks’ uphill struggle for market share. The
community bank model seems superior with its better loan quality and ability to weather
economic crises.However, economic factors and political forces have resulted in fewer
community banks and a decreasing share of industry assets. Most noteworthy are the so-called
“too big to fail” policies that sustain and support the largest financial institutions. These policies
have weakened community banks by creating an unlevel playing field with respect to funding,
risk taking and creditor protection. Furthermore, regulatory “solutions” designed to prevent
another financial crisis and solve the TBTF dilemma have unfairly overburdened smaller
institutions because of their “one-size-fits-all” approach and great complexity.

Regulatory Burden Rising illustrates the growing burden smaller banks face because of
regulations aimed at policing the activities of the large institutions. Smaller institutions are
affected more from complicated and burdensome regulations. Recent banking laws have grown
in scope, size and complexity. This has forced community banks to increase staff relative to
assets to a greater degree than at large banks, further undermining their ability to compete.
A better approach would be to create a regulatory framework that more fully accounts for the
operational differences between small and large banks.

Leveling the Playing Field analyzes how market discipline and public policy reform can
influence bank size and contain the risk of TBTF banks. The market increasingly perceives
that a large, complex bank will be protected by the federal safety net because it’s considered
systemically important (that is, its failure could send shocks throughout the financial system
and cause other failures and harm to the economy). The bank has become “too big to fail.” The
problem is—for banks perceived to be TBTF—that market discipline no longer has much impact
on restraining excessive risk taking, often leading to poor decisions and reckless behavior.
Smaller community banks, in contrast, face a great degree of market discipline because the
bank’s owners frequently have a significant portion of their wealth invested in the bank.
For market discipline to be restored, the federal government’s financial safety net should be
rolled back to cover only a bank’s essential commercial banking activities and their role in the
payments system.
In summary, the time-proven community bank model based on relationship lending and a
strong customer focus is superior to the large bank model, where market discipline has eroded.
As a result, financial reform must be redirected toward solutions based on greater market
discipline. This will lead to a more stable financial system and enable stronger economic
growth.
Thomas F. Siems is senior economist and economic outreach officer in the Financial Institution Relationship
Management Department at the Federal Reserve Bank of Dallas. Send comments or questions about this
article to the author at Tom.Siems@dal.frb.org.

Contact us at Dallas_Fed_
FIRM@dal.frb.org.

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FIRM • Financial Institution Relationship Management
Federal Reserve Bank of Dallas
2200 N. Pearl St., Dallas, TX 75201

DALLASFED
Noteworthy Items

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MEMBERS OF FIRM
Diane de St. Germain
Vice President
Diane.M.De.St.Germain@dal.frb.org

Tom Siems
Senior Economist &
Economic Outreach Officer
Tom.Siems@dal.frb.org

Jay Sudderth
Relationship Management
Officer
Jay.Sudderth@dal.frb.org

Steven Boryk
Relationship Management
Director
Steven.Boryk@dal.frb.org

Matt Davies
Director of Payments Outreach
Matt.Davies@dal.frb.org

Susan Springfield
Program Director
Susan.Springfield@dal.frb.org

Richard Fisher’s speech on “Ending ‘Too Big to Fail’: A Proposal for Reform Before It’s
Too Late” before the Committee for the Republic in Washington, D.C. (Jan. 16, 2013)
President Fisher contends that the Dodd–Frank Act has not done enough to corral “too-big-to-fail”
(TBTF) banks and that, on balance, the act has made things worse, not better. The governmentsanctioned policy of coming to the aid of TBTF firms has undermined the discipline that market
forces normally assert on management decisionmaking. The Dallas Fed’s proposal relieves small
banks of unnecessary burdens arising from the Dodd–Frank Act that unfairly penalize them and
reshapes TBTF banking institutions into smaller, less-complex institutions, which allows both
regulatory and market discipline to restrain excessive risk taking.
http://www.dallasfed.org/news/speeches/fisher/2013/fs130116.cfm
Governor Duke’s speech on “The Future of Community Banking” at the
Southeastern Bank Management and Directors Conference at the University of
Georgia (Feb. 5, 2013)
Governor Duke discusses the important role that community banks play in our nation’s financial
system. She cites research that supports the community bank model and confirms her own
experience that community banks with deep ties to the community, engaged managers and
directors, conservative underwriting and strong risk management can not only survive, but thrive,
even in adverse conditions. Duke understands community bankers’ concerns that the burden of
new regulations may inhibit their ability to lend in their communities and urges bankers to continue
to communicate about the challenges that regulations pose.
http://www.federalreserve.gov/newsevents/speech/duke20130205a.htm
Economic Insights: Conversations with the Dallas Fed webcast on “Ending Too
Big to Fail: A Proposal for Financial Reform” (Feb. 1, 2013)
Harvey Rosenblum, the Dallas Fed’s executive vice president and director of research, presents a
proposal to end the “too-big-to-fail” policy that has effectively removed market discipline as a force
to control behavior at the largest institutions.
http://presentations.dallasfed.org/frm130201/index.htm
Federal Reserve Board announces preliminary, unaudited income and expense
results for 2012 (Jan. 10, 2013)
Under Board policy, the residual earnings of each Federal Reserve Bank are distributed to the
U.S. Treasury after providing for the costs of operations, payment of dividends and the amount
necessary to equate surplus with capital paid-in. The Reserve Banks provided for payments
of approximately $88.9 billion of their estimated 2012 net income to the U.S. Treasury, derived
primarily from interest income on securities acquired through open market operations. The link
below includes a chart illustrating the Reserve Banks’ residual earnings distributed to the U.S.
Treasury from 2003 through 2012.
http://www.federalreserve.gov/newsevents/press/other/20130110a.htm

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FIRM • Financial Institution Relationship Management
Federal Reserve Bank of Dallas
2200 N. Pearl St., Dallas, TX 75201