Phil Timyan

I have a stake in @BankofZachary, my children are substantial owners of another community bank. Our little parts of the world are blessed to have community banks. Both were charted in 1904.

We need more community banks, not fewer. Before the 2008 financial crisis: New banks were frequently approved with $5–12 million (sometimes as low as $7–10 million). After the Great Financial Crisis and Dodd-Frank: Regulators roughly doubled typical requirements (to around $20 million or more). Analyses put average or median post-crisis figures in the $25–32 million range. Throughout the past decade, industry advisers and regulators have consistently treated roughly $20 million as the practical floor for most community banks, with many proposals required to raise more (often $25–50 million depending on size, market, and risk). There has been no general reduction in this expectation. Every previous wave of consolidation has been met with de novo bank creation. Community banks have always “disappeared” but new ones have always been formed to take their place. The dearth of community banks is not organic. It is bureaucratically engineered.