speeches · March 17, 2010
Regional President Speech
Thomas M. Hoenig · President
Are Community Banks Important?
Thomas M. Hoenig
President
Federal Reserve Bank of Kansas City
American Bankers Association Government Relations Summit
Washington, D.C.
March 18, 2010
As a Federal Reserve Bank president, I am occasionally asked outrageous questions
regarding central banking and commercial banks. “Is the Federal Reserve owned by a European
banking cabal?” “How much ownership of the Federal Reserve do the Rockefellers hold?” But
over the past few days, the questions have become truly outrageous:
“Will the regional and community bank model survive in the future?” Are community
banks important?
“Shouldn’t the Federal Reserve supervise only the very largest banks and not community
banks?”
What’s more, it is particularly bothersome to me that these last two questions are most
often asked by individuals who have not been in or know what a community bank does. So let
me answer the question.
Whether you are here today representing JP Morgan or the First State Bank of
Hometown, Kansas, the answer is the same. When you cut through the fog, there is no question
as to the need for and the importance of community banks in our nation’s financial system. The
maps on the screen behind me show that banks with less than $10 billion in total assets hold
substantial market share in much of the United States and hold the majority of deposits in 16
states. Bank subsidiaries of bank holding companies with less than $50 billion hold the majority
of deposits in 26 states.
As you can see from these maps, regional and community banks serve local markets, and
in turn, support local economic growth. These banks rely on knowing their customer, and
managing those relationships to work with borrowers through good times and bad. Regional and
community banks are also typically locally owned and managed, which means they have an
immediate and vested interest in the success of their local communities.
Yes, regional and community banks also are under pressure from this crisis, and it will be
a straggle for them to regain their footing; but, certainly no more so than that for our largest
institutions that received significant government support. Commercial real estate will be a drag
on earnings for some quarters yet, and there will be bank failures. But this segment of the
industry will recover and its model, with its focus on relationship banking, will prosper as the
economy recovers and expands.
Interestingly, looking at preliminary data, I suspect future analysis of this crisis will find
that regional and community banks dining the crisis actually may have done a better job of
serving their local markets and maintaining lending standards. While this group of banks has a
higher concentration of commercial real estate to capital, there is evidence that they are working
effectively, and in some instances, more cooperatively than the largest banks with their
borrowers to work out or reduce losses, based on their knowledge and active monitoring of
customers.
Some of our largest banks would be well-served to take a lesson.
It is also no coincidence that with breakdowns in other parts of the marketplace, a
substantial portion of regional and community banks have increased their loans to businesses.
During 2009, 45 percent of the banks with under $1 billion in assets increased then business
lending.
And while it may make some of the largest banks uncomfortable to hear this, regional
and conununity banks have managed all this while operating at a competitive disadvantage. For
it is the largest financial firms that have an implicit, recently made explicit, guarantee that
taxpayer dollars will be used to protect them from failure, regardless of what risks they assume.
It is only now that we are discussing legislation to address the issue of a special class of the
largest films that we have deemed too-big-to-fail. This is the one item that must be addressed if
we are to have any real competitive equity among all financial institutions. What is proposed
may need to be strengthened, but it is a start.
Let me end my remarks by quickly commenting on the Federal Reserve’s role as a
supervisor of regional and community banks, something that will soon come under debate in the
Seriate and perhaps again in the House. The strong opposition to removing the Federal Reserve
from regional and conununity bank supervision, voiced by myself and others from the Federal
Reserve, is not driven by the idea of simply protecting our “turf’ or saving Federal Reserve jobs.
The record very clearly shows that the Federal Reserve System has made important
changes to its operations when such moves benefit the country as a whole regardless of the
impact on the Federal Reserve. Most notably, the Federal Reserve was among the strongest
supporters of Check 21 legislation, while realizing it would mean the eventual loss of thousands
of Federal Reserve check processing jobs. The legislation improved the efficiency of our
payments system, and while it was painfill for me personally to see the elimination of hundreds
of jobs in my District, it was a step we had to take to best serve the nation.
In this case, however, serving the best interest of the nation does not mean reducing the
Federal Reserve’s supervisory role.
Given the importance of 6,800 regional and community banks located in almost as many
communities across this country, it is inconceivable to me that the Central Bank of the United
States would not have a role in their oversight, through the supervision of state member banks
and bank holding companies.
The Federal Reserve System was designed by its founders with the goals of it supervising
a broad cross section of U.S. banks, assuring equitable access to the Federal Reserve liquidity
facilities regardless of institutional size or location, and contributing to the stability of the
financial system - not only on Wall Street but on America’s Main Street. It does this job well.
In the crisis of the ’80s, which affected both large and small banks, banks supervised by the
Federal Reserve proportionately imposed the least losses on the FDIC when they failed relative
to banks supervised by other Federal agencies.
In addition, the Federal Reserve’s role in supervision of banks and bank holding
companies provides it critical information on local economies in places such as Muskogee,
Okla.; Santa Fe, N.M. and Scottsbluff, Neb. And to answer the question: yes, our role in
regional and community bank supervision supports our responsibilities as members of the
Federal Open Market Committee, by expanding our understanding of local and regional
economies.
Stripping the Federal Reserve of its responsibility for supervising regional and
community banks and bank holding companies should be unacceptable to anyone who cares
about equity in the nation’s banking system, largest to smallest bank, and the nation’s regional
and local economies. Confining the Federal Reserve’s supervisory role to only the largest firms
will, I fear, inadvertently make the Federal Reserve the Central Bank to the largest firms while
disenfranchising the other 6800 banks. The map tells the story.
When Congress created the Federal Reserve nearly a century ago, it gave us a
decentralized system that spanned the continent. The explicit purpose for this structure was to
better balance the interest of Main Sheet against those of Wall Sheet. Recent experience
confirms that this structure is as important today as then, perhaps more so. Community banks are
important to the banking system and to the economy, and therefore continue to be important to
the Federal Reserve. I have said before but it deserves repeating: It would be a tragic irony if the
outcome of this crisis is a gain in power for the largest firms at the expense of the other 6,800
regional and community banks. If so, it would be a win for Wall Street.
Geographic Market Share of Banks in the U.S.
Geographic market share of banks over $10 billion
69% of total deposits are held at
banks with greater than $10
billion in total assets.
Banks with less than $10 billion in
total assets make up the majority
Percentage of deposits in 16 states.
□ 20 and below
■ 20 to 40
■ 40 to 60
Mt 60 to 80
■ 80 and above
Source: FDIC Summary of Deposits (June 2009)
Geographic market share of bank subsidiaries of BHCs over $50 billion
• 60% of total deposits are held
at bank subsidiaries of BHCs
with greater than $50 billion
in total assets.
• These BHCs own the majority
of deposits in 24 states.
• Total assets of the largest
BHCs constitute 83% of all
BHC assets in the U.S.;
however, represent less than
1% of the total population of
BHCs.
■ 80 and above
Source: FDIC Summary of Deposits (June 2009)
Cite this document
APA
Thomas M. Hoenig (2010, March 17). Regional President Speech. Speeches, Federal Reserve. https://whenthefedspeaks.com/doc/regional_speeche_20100318_thomas_m_hoenig
BibTeX
@misc{wtfs_regional_speeche_20100318_thomas_m_hoenig,
author = {Thomas M. Hoenig},
title = {Regional President Speech},
year = {2010},
month = {Mar},
howpublished = {Speeches, Federal Reserve},
url = {https://whenthefedspeaks.com/doc/regional_speeche_20100318_thomas_m_hoenig},
note = {Retrieved via When the Fed Speaks corpus}
}