"It would seem that legislative canon that purports to better regulate those institutions deemed 'too big to fail' is unwittingly creating a class of banks that may be 'too small to succeed.'"  

                M&T CEO Bob Wilmers in his latest annual letter to shareholders.


I personally would credit the genesis of the phrase “too small to succeed” to Immediate Past-President of the National Creditors Bar Association, Joann Needleman, as she frequently spoke and continues to speak on the increasing costs of regulation and the impact on the creditors rights attorney firms and the industry. It is a welcoming sight to see that our fellow colleagues on the small banking side are also joining in with a loud call to rein in federal regulations to stem the tide of putting small and medium sized businesses and firms “out of business”.

Bob Wilmers went on to say in his letter, "We have witnessed, through the rise of nonbank players, a subtle but steady shift in which regional banks are playing an ever-diminished role in the financial leadership of the communities and small towns of America that they have traditionally served so well," Wilmers went on to say 


"Such is the collateral damage of far-reaching regulation inspired by the misdeeds of a few."


                                                         M&T CEO Bob Wilmers

 A recent blog article I wrote applauded the federal government for going after a “bad actor” in the debt collection industry. This was a prime example of how enforcement of existing laws and regulations can truly clean up the landscape and focus on the “misdeeds of a few”. We truly don’t need more regulation to expel the bad players, we need to, as Harvey Moore, President of the National Creditors Bar Association, reminds us – “Enforce and execute the existing laws and regulations we already have on the books”.
  
“Today we face a turning point,” Wilmers said. “Will we continue to look for villains to punish or will we take steps that will enable banks to serve again as agents of an expanding prosperity?”
  
The cooperation between industry groups and the regulatory bodies, which enforce laws to eliminate those who consciously harm consumers through deceptive practices, is a mutual goal we want to continue to pursue together. If we force too many “good players” out because of increasingly costly regulations – small banks or small creditors rights attorney firms – to become “too small to succeed”, then we risk causing consumers more harm than good.

Mark Dobosz