ABSTRACT
Some two years after the adoption of the Dodd-Frank Act, its implementation is still far from complete. And despite the fact that one of the major objectives of the legislation was to remove the threat that banks that are “too big to fail” (TBTF) would require a taxpayer bailout, the financial system has become even more concentrated and the largest banks even larger. According to the president of the Federal Reserve Bank of Dallas, “Dodd-Frank… may actually perpetuate an already dangerous trend of increasing bank industry concentration” (Fisher 2012, 1). Indeed, the top five financial conglomerates now account for over 50 percent of total industry assets, and three of them are over or near the 10 percent limit on the share of national deposits set by the 1994 Riegle-Neal Act liberalizing branch banking (see the figures presented in Rosenblum 2012).