An Attempt at Defining 'Too Big to Fail'

Last year there were lots of debates about whether to bail out companies that were “too big to fail.” Then this spring the government began developing plans for monitoring companies that were considered “too big to fail” (although by then the preferred term had morphed into “systemically important”).

What does it actually mean for an institution to be “too big to fail” (T.B.T.F.)?

That’s a very tricky question. And of course, you can’t trust any given company’s self-assessment of T.B.T.F.-ness. When a company is in trouble and seeking government help, it will proclaim itself T.B.T.F. But to the extent that being labeled T.B.T.F. subjects a company to more regulation and oversight when times are good, that company will likely excuse itself from the T.B.T.F. category.

So are there some objective, lobby-proof criteria for this designation?

James B. Thomson at the Federal Reserve Bank of Cleveland says yes. In a new report, he takes a stab at outlining the definition of a “systemically important” financial institution (SIFI, for short), and how it might be contained and monitored. His model focuses on five characteristics, with an emphasis on the latter four:

And from those, Mr. Thomson constructs five categories for systemically important institutions, with each ideally subject to a different level or type of scrutiny and regulation.

Here’s a video, put out by the Cleveland Fed, that helps explain this proposal in accessible layman’s terms:

Whatever happened to the Sherman Anti-Trust Act? Is it still being used?

The debate over “too big to fail” is chasing the wrong goal. It’s really about reasoned decisions vs ideology.

We let Lehman fail, now regret it, but only beacuse the results were terrifying. Does it make sense to allow CIT to fail? CIT isn’t large enough to pose a catastrophic failure risk for the general economy. But it can mean crisis for thousands of small to middling commercial borrowers. We can let our imaginations run to a cascading failure of small and medium businesses, in order to build the TBTF case. Why do we need to do that? Isn’t the dislocation of many of America’s middle market companies an event worth avoiding, even if there’s little risk of total catastrophe? Wasn’t CIT management basically reasonable in it’s stewardship? It’s not a question of TBTF, it’s a question of what’s best for eveyone.

Creating a “systemic risk” regulatory protocol doesn’t solve this problem. if anything, it contributes to the greatest systemic risk we face: the financial failure of Federal or local government. The answer already lies within our regulatory structures: what is needed is regulators who won’t turn their back on a failing Lehman because they are concerned with political fallout, or because rescue is at odds with some weird philosophy. I deeply concerned that so many of these decisions were and continue to be made by Treasury, which is a wholly political organ. Far better to relegate these decisions to structures which are more insulated from the political process: FDIC, SEC, the Fed and the SRO’s. This after all, was the idea behind the New Deal reforms. The only problem I see is finding a few good people to fill these roles.

The “Too Big to Fail” concept always begs a simple question: Is the loss of an equal number of key small businesses as damaging as the loss of one key large business?

Oddly enough, no one ever dares to answer that question.

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David Leonhardt writes the Economic Scene column, which appears in The Times on Wednesdays.

Catherine Rampell is the economics editor at nytimes.com.

R.M. Schneiderman is a Web producer for nytimes.com.

Marc Lacey is The Times's bureau chief for Mexico, Central America and the Caribbean.

Carter Dougherty is a European economic correspondent for The Times and the International Herald Tribune.

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