The Silicon Valley Bank Collapse of 2023: A Deep Dive Into Regulatory Failures and Banking Oversight

Writer: Joeziel Vazquez,

CEO & Board Certified Credit Consultant (BCCC, CCSC, CCRS)

Experience: 17 Years in Credit Repair Industry

Published: Apr 29, 2023 | Updated: Dec 8 2025

Reading Time: 38 minutes

When Silicon Valley Bank collapsed on March 10, 2023, it sent shockwaves through the financial system that reverberated far beyond California's tech hub. The second-largest bank failure in American history didn't happen overnight, nor was it simply bad luck or poor management. It was the culmination of systematic regulatory failures, weakened oversight standards, and the erosion of safeguards specifically designed to prevent exactly this type of catastrophe.

As someone who has spent 17 years navigating the complexities of consumer finance and financial regulation, serving over 79,000 clients through every economic cycle since founding Credlocity in 2008, I've witnessed firsthand how regulatory frameworks either protect or expose consumers to financial risk. The SVB collapse represents a master class in what happens when banking regulations are systematically dismantled and supervisory vigilance is replaced with industry-friendly forbearance.

This isn't just a story about one bank's failure. It's a cautionary tale about the delicate balance between financial innovation and prudent regulation, between industry lobbying and consumer protection. More importantly, it's a story that directly impacts every American who trusts their money to the banking system, whether they realize it or not.

The Regulatory Foundation: What Dodd-Frank Was Supposed to Prevent

To understand how Silicon Valley Bank failed so spectacularly, we need to start with the regulatory framework that emerged from the 2008 financial crisis. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 wasn't just legislation; it was a comprehensive reimagining of banking supervision designed to ensure that "too big to fail" would become a relic of the past.

Dodd-Frank established enhanced prudential standards for bank holding companies with $50 billion or more in consolidated assets. These weren't arbitrary requirements dreamed up in Washington offices. They were carefully crafted safeguards based on hard lessons learned during the 2008 crisis when institutions like Lehman Brothers, Bear Stearns, and Washington Mutual collapsed, taking billions in consumer wealth with them.

The enhanced prudential standards included several critical requirements that, had they remained in effect for Silicon Valley Bank, might have prevented or at least mitigated the 2023 disaster. First and foremost were stress testing requirements. Banks meeting the $50 billion threshold had to undergo regular stress tests conducted both by regulators and internally by the bank itself. These tests simulated adverse economic scenarios to determine whether the institution could withstand severe financial shocks.

Second, liquidity requirements mandated that banks maintain sufficient high-quality liquid assets to cover 30 days of stressed cash outflows under the Liquidity Coverage Ratio. This wasn't theoretical regulatory busy work; this was practical preparation for the reality that depositors might suddenly want their money back all at once.

Third, capital requirements went beyond simple ratios to include requirements that banks recognize unrealized gains and losses on available-for-sale securities in their capital calculations. This provision, known as including Accumulated Other Comprehensive Income (AOCI) in capital, prevented banks from hiding mounting losses on their balance sheets simply by classifying securities as "held-to-maturity."

Fourth, resolution planning, colloquially known as "living wills," required banks to demonstrate how they could be wound down in an orderly fashion if they failed, without requiring taxpayer bailouts or triggering systemic crises.

These weren't onerous burdens designed to hamstring banking. They were reasonable prudential measures that said, in effect: if you're going to take deposits from thousands of businesses and individuals, you need to demonstrate that you can weather storms and won't put the entire financial system at risk.

Silicon Valley Bank, as it grew through 2020 and 2021, should have been subject to every single one of these requirements. Its asset base exceeded the $50 billion threshold mandated by the original Dodd-Frank legislation. But by the time SVB crossed that threshold, the rules had fundamentally changed.

The 2018 Rollback: How the Economic Growth, Regulatory Relief, and Consumer Protection Act Changed Everything

In 2018, Congress passed the Economic Growth, Regulatory Relief, and Consumer Protection Act, commonly known as S.2155 or EGRRCPA. Despite its consumer-friendly name, this legislation fundamentally weakened the regulatory architecture that Dodd-Frank had carefully constructed.

The banking industry had spent years lobbying for "regulatory relief," arguing that Dodd-Frank's enhanced prudential standards were too burdensome for regional and midsize banks that posed no systemic risk to the financial system. The narrative was compelling on its surface: why should community banks and regional institutions be held to the same standards as global systemically important banks like JPMorgan Chase or Bank of America?

Senator Mike Crapo of Idaho, then chairman of the Senate Banking Committee, worked with a bipartisan group of senators including Jon Tester of Montana, Joe Donnelly of Indiana, Heidi Heitkamp of North Dakota, and Mark Warner of Virginia to craft legislation that would provide this "tailored regulation." The political calculation was clear: several Democrats facing tough 2018 reelection battles in states that Trump had won could campaign on providing relief to local banks while Republicans could claim victory in rolling back Obama-era regulation.

The bill's most consequential provision raised the asset threshold for enhanced prudential standards from $50 billion to $250 billion. At a stroke, this change exempted 25 of the nation's 38 largest bank holding companies from the most stringent regulatory oversight. Silicon Valley Bank, with assets around $211 billion at its peak, suddenly found itself in a much lighter regulatory environment.

But EGRRCPA's impact extended beyond just the headline threshold change. The legislation gave the Federal Reserve discretion to apply standards on a "tailored" basis to banks between $100 billion and $250 billion in assets. While this theoretically allowed the Fed to reimpose stricter requirements on institutions that needed them, in practice the Fed's implementation leaned heavily toward the lighter end of the regulatory spectrum.

Senator Elizabeth Warren warned at the time that Congress was "about to make it easier for banks to run up risk, make it easier to put our constituents at risk, [and] make it easier to put American families in danger." Her concerns, dismissed by many as partisan fear-mongering in 2018, proved prophetic five years later.

The lobbying effort that produced EGRRCPA was intense and well-funded. Less than a month after the bill passed the Senate, Senator Tester met with Greg Becker, the CEO of Silicon Valley Bank, according to Tester's office schedule. Becker had specifically lobbied Congress and the Federal Reserve to take a light regulatory approach with banks of SVB's size. His bank had grown from around $50 billion in assets in 2017 to over $200 billion by 2022, fueled by deposits from venture capital-backed technology companies enjoying unprecedented access to cheap capital.

Lobbyists from the Franklin Square Group, retained by Silicon Valley Bank, donated $10,800 to Tester's campaign. Americans for Prosperity, the conservative grassroots group funded by the Koch brothers, ran ads commending Democrats who supported the bill. The political and financial incentives all pointed in one direction: weaken oversight of midsize banks.

The Federal Reserve's Tailoring Framework: How Implementation Made Things Worse

While EGRRCPA set the legislative foundation for lighter regulation, the Federal Reserve's implementation of the law through its "tailoring" framework cemented the weaker supervisory approach that would prove so consequential for Silicon Valley Bank.

In October 2019, the Federal Reserve issued its final rule implementing EGRRCPA's mandates. But the Fed went beyond what the law strictly required, adopting what its own post-mortem report would later describe as "a shift in the stance of supervisory policy" that "impeded effective supervision by reducing standards, increasing complexity, and promoting a less assertive supervisory approach."

The tailoring framework divided bank holding companies into four categories based on their size and risk profile. Category I covered the largest global systemically important banks. Category II included large institutions with significant cross-border activity. Category III covered banks with $250 billion to $700 billion in assets or $75 billion in certain other measures. Category IV, where Silicon Valley Bank eventually landed, covered banks with $100 billion to $250 billion in assets.

Each category received progressively lighter regulatory requirements. While Category I and II banks faced the full suite of enhanced prudential standards, Category IV banks like SVB received substantially reduced requirements. They weren't subject to the full enhanced Liquidity Coverage Ratio. They could opt out of including AOCI in their capital calculations. They faced longer transition periods for new requirements and less frequent stress testing.

Critically, when Silicon Valley Bank crossed the $100 billion threshold in 2021, triggering its transition to Category IV standards under the tailoring framework, the regulatory response was slow and accommodating. The bank was given extended transition periods to come into compliance with even the reduced requirements. Supervisors, operating under policy guidance that emphasized reducing burden and providing due process to supervised institutions, took a patient approach even as red flags accumulated.

According to the Federal Reserve's own review of SVB's supervision released in April 2023, "the Board raised the threshold for heightened supervision by the Large and Foreign Banking Organization portfolio from $50 billion in assets to $100 billion in assets in July 2018 to track the new EGRRCPA thresholds, which delayed application of heightened supervisory expectations." This wasn't just about following the law; it was about adopting a supervisory philosophy that prioritized accommodating bank preferences over assertive oversight.

The policy shift went beyond just regulatory requirements. In April 2021, the Federal Reserve Board adopted a rule codifying that supervisory guidance "does not have the force and effect of law, but rather outlines expectations and appropriate practices." While intended to clarify that guidance is not regulation, this policy change reinforced a culture where supervisors were reluctant to push hard on institutions that were technically in compliance with regulations, even when broader safety and soundness concerns were apparent.

What Silicon Valley Bank Should Have Faced Under Dodd-Frank

To appreciate what was lost through EGRRCPA and the Fed's tailoring framework, consider what requirements Silicon Valley Bank would have faced under the original Dodd-Frank standards once it crossed $50 billion in assets around 2017.

Comprehensive Stress Testing

Under Dodd-Frank's original framework, SVB would have been subject to annual stress tests conducted by the Federal Reserve and regular company-run stress tests. These wouldn't have been pro forma exercises. They would have required SVB to model how its balance sheet would perform under severely adverse economic scenarios, including rising interest rate environments.

The Federal Reserve's Comprehensive Capital Analysis and Review (CCAR) process would have required SVB to demonstrate that it could maintain minimum capital ratios even after simulating nine quarters of severe stress, including sharp increases in interest rates, significant declines in asset values, and elevated unemployment.

Had this testing been in place, SVB's concentration risk and interest rate risk would have been exposed much earlier. The bank's portfolio of long-duration Treasury and agency securities, purchased with deposits from VC-backed tech companies, would have shown massive losses under rising rate scenarios. Its internal stress testing that repeatedly failed to meet its own standards starting in July 2022 would have been caught by regulators conducting independent tests.

Instead, because the stress testing threshold had been raised to $250 billion, SVB was exempt from this scrutiny. The bank conducted some internal stress tests, but as documented in the Federal Reserve's post-mortem review, when these tests showed problems, management responded by making the assumptions less conservative rather than addressing the underlying risks.

Full Liquidity Coverage Ratio

Under original Dodd-Frank standards, SVB would have been subject to the full Liquidity Coverage Ratio requirement, not the modified version that applied after EGRRCPA and tailoring. The LCR requires banks to maintain enough high-quality liquid assets to cover 30 days of stressed net cash outflows.

Former Senator Pat Toomey, a Republican co-sponsor of EGRRCPA, argued after SVB's collapse that the LCR wouldn't have caught the bank's problems. His reasoning relied on the assumption that SVB's stress scenario wouldn't have predicted the magnitude of deposit withdrawals that actually occurred. On March 9, 2023, depositors withdrew $42 billion in a single day – approximately 24% of the bank's deposits.

But this argument misses several critical points. First, the LCR isn't just about the mathematical calculation; it's about forcing banks to maintain diversified, high-quality liquid assets and to regularly model stress scenarios. The discipline of maintaining compliance would have required SVB to hold more Treasury bills and other truly liquid assets rather than loading up on long-duration bonds that couldn't be sold quickly without massive losses.

Second, SVB's concentrated deposit base and business model should have informed the stress assumptions. The bank's deposits came predominantly from VC-backed technology companies and their executives. This is inherently less stable than a diversified retail deposit base. A properly calibrated stress test would have recognized this concentration risk.

Third, even if the standard LCR wouldn't have prevented the run, it would have made SVB's liquidity profile visible to regulators much earlier. The requirement to regularly report and maintain the ratio would have created ongoing supervisory touchpoints where questions could have been raised about the bank's risk profile.

AOCI Recognition in Capital

Perhaps most critically, under Dodd-Frank's original framework SVB would have been required to include Accumulated Other Comprehensive Income in its regulatory capital calculations. This technical provision has enormous practical significance.

When interest rates rise, the market value of existing bonds falls. If a bank holds a $100 million bond paying 2% interest, and rates rise so that new bonds pay 4%, that original bond might now be worth only $90 million if sold. The $10 million difference is an "unrealized loss" because the bank hasn't actually sold the bond yet.

Banks can account for these bonds in two ways: as "available-for-sale" (AFS) securities, where unrealized gains and losses flow through AOCI and affect capital, or as "held-to-maturity" (HTM) securities, where they're carried at cost and unrealized losses don't affect reported capital. Silicon Valley Bank, like many banks, classified most of its securities as HTM, allowing it to avoid recognizing mounting losses in its capital.

But under the original Dodd-Frank framework for advanced approaches banks, institutions would have been required to recognize these unrealized losses even on HTM securities. This would have made SVB's deteriorating capital position visible much earlier, both to regulators and to sophisticated depositors monitoring the bank's financial health.

By year-end 2022, Silicon Valley Bank had approximately $15 billion in unrealized losses on its securities portfolio. Had these been recognized in capital, the bank's regulatory capital ratios would have been significantly lower, potentially triggering heightened supervisory attention or even enforcement actions long before the March 2023 crisis.

The EGRRCPA rollback and Fed tailoring framework allowed SVB to opt out of AOCI recognition. The bank took full advantage of this option, classifying $91.3 billion of its $120.1 billion securities portfolio as held-to-maturity by the end of 2021. This accounting choice, permitted by the lighter regulatory framework, allowed SVB to maintain the appearance of strong capital even as its economic solvency deteriorated.

Resolution Planning

Finally, under original Dodd-Frank standards, SVB would have been required to submit regular "living will" resolution plans to the FDIC and Federal Reserve. These plans detail how a bank could be wound down in an orderly manner if it failed, identifying key operations, interdependencies, and potential obstacles to resolution.

SVB did eventually submit a resolution plan after crossing the $100 billion threshold in 2021, as required under EGRRCPA's modified standards. But the requirement came much later than it would have under original Dodd-Frank, and the consequences for inadequate plans were lighter under the tailored regime.

More importantly, the process of developing a resolution plan forces bank management and directors to think through the institution's key vulnerabilities and dependencies. It creates a regular forum for discussing with regulators what would happen if things went wrong. This ongoing dialogue, had it been required earlier in SVB's growth trajectory, might have surfaced concerns about the bank's business model and risk profile before they became existential threats.

The Supervisory Failures: When Regulators Saw Problems But Didn't Act

Regulatory requirements are only as good as the supervisors who enforce them. Even with EGRRCPA and the tailored framework in place, regulators retained significant authority to identify and address problems at Silicon Valley Bank. The Federal Reserve, working jointly with the California Department of Financial Protection and Innovation (DFPI), conducted regular examinations of SVB. These examinations did, in fact, identify significant problems. What failed was the will and urgency to force the bank to fix them.

The Federal Reserve Bank of San Francisco served as SVB's primary federal supervisor. According to the comprehensive reviews released by both the Federal Reserve and DFPI following SVB's collapse, supervisors identified material concerns about the bank's risk management as early as 2019, well before the bank's ultimate failure.

In 2020, 2021, and 2022, supervisors identified interest rate risk deficiencies in their CAMELS examinations – the rating system that evaluates banks across six key areas: Capital, Asset Quality, Management, Earnings, Liquidity, and Sensitivity to market risk. Despite identifying these deficiencies repeatedly, supervisors did not issue formal supervisory findings that would have required the bank to take corrective action within specified timeframes.

This wasn't mere oversight. It reflected a supervisory culture that, following EGRRCPA and the Fed's policy shifts, emphasized burden reduction and extensive due process for supervised institutions. Supervisors were reluctant to escalate issues or impose formal enforcement actions unless they could meet increasingly stringent internal standards of proof.

The timeline of supervisory inaction is striking. In November 2021, examiners raised concerns about SVB's liquidity risk management and its ability to meet stressed scenarios in its own internal liquidity stress tests. Rather than issuing findings requiring immediate corrective action, supervisors engaged in extended discussions with bank management about their plans to address these concerns.

By July 2022, when SVBFG (the holding company) first became subject to enhanced prudential standards under Regulation YY after crossing $100 billion, the bank was already repeatedly failing its own internal liquidity stress tests. Management's response was telling: instead of fundamentally changing the bank's risk profile, they increased funding capacity (but executed these plans slowly and incompletely) and switched to less conservative stress testing assumptions that masked the underlying risks.

Supervisors documented these concerning developments but did not escalate their response commensurately. The Federal Reserve's post-mortem report is explicit about this failure: "When supervisors did identify vulnerabilities, they did not take sufficient steps to ensure that Silicon Valley Bank fixed those problems quickly enough."

In August 2022, supervisors began working on a formal enforcement action, downgrading the bank's management rating. But the process moved slowly, hampered by what the Fed's review described as a supervisory culture that required extensive documentation and internal review before taking action against an institution. By the time regulators were prepared to present enforcement action documents to SVB's board in early March 2023, it was already too late. The announcement of securities losses and capital raise on March 8 triggered the bank run that would doom the institution within 48 hours.

The California DFPI, as the state chartering authority and joint supervisor, relied heavily on the Federal Reserve to lead examination activities. While DFPI staff participated in examinations and monitoring, the division of responsibilities meant that oversight activities were "led primarily by the FRBSF, with DFPI staff monitoring supervisory activities and collaborating with the FRBSF." This arrangement, while efficient in theory, meant that DFPI's supervisory response was largely dependent on the Fed's approach.

In its own review, DFPI acknowledged several failures in its oversight of SVB. The department noted that "SVB's unusually rapid growth was not sufficiently accounted for in risk assessments" and that "SVB's high level of uninsured deposits contributed to the run on SVB" – factors that should have triggered more intensive supervision but didn't.

Perhaps most damning, both reviews acknowledged that supervisors had all the information they needed to see that SVB posed significant risks. The failure wasn't one of information gathering; it was one of supervisory will and urgency in the face of mounting evidence that the bank's business model was fundamentally unsound for the rising rate environment it faced.

The Concentration Risk That Everyone Saw But No One Stopped

One of Silicon Valley Bank's most glaring vulnerabilities was hiding in plain sight from its founding in 1983: extreme concentration risk in both its deposit base and its lending portfolio. The bank's entire business model was built on serving the technology and venture capital ecosystem of Silicon Valley and later the broader innovation economy.

This wasn't a diversified regional bank that happened to have some tech clients. Nearly half of all U.S. venture capital-backed healthcare and technology companies banked with SVB. Companies like Airbnb, Cisco, Fitbit, Pinterest, and Block (formerly Square) were clients. More importantly, thousands of early-stage startups that most people had never heard of kept their venture capital funding in SVB accounts.

This concentration created a uniquely unstable deposit base. Unlike retail depositors who might keep a few thousand or tens of thousands of dollars in their accounts, SVB's clients often had millions or tens of millions from recent venture capital funding rounds. These deposits vastly exceeded the $250,000 FDIC insurance limit, making them uninsured and vulnerable to runs if confidence in the bank wavered.

Moreover, these deposits were highly correlated with conditions in the venture capital and technology sectors. When VC funding was plentiful and startups were raising large rounds, deposits poured into SVB. From December 2019 to March 2022, SVB's deposits nearly tripled from $61.8 billion to $189.2 billion, driven by the massive influx of venture capital into tech companies during the low-rate pandemic era.

But this correlation worked both ways. When VC funding dried up as interest rates rose and investor appetite for unprofitable growth companies evaporated, SVB's clients began drawing down deposits to fund operations. From its peak of $198 billion in March 2022, SVB's deposits fell to $173 billion by year-end 2022 and would drop precipitously in early 2023.

The concentration extended to the asset side as well. SVB specialized in lending to higher-risk early-stage companies that conventional banks wouldn't touch. The bank required exclusive relationships from borrowers – you banked with SVB and only SVB if you wanted their specialized startup lending.

Regulators were well aware of this concentration. It wasn't hidden in footnotes or obscure disclosures. It was SVB's core business strategy, openly discussed in investor presentations and regulatory filings. The bank's management believed this specialization was a competitive advantage. They were right that it differentiated them from competitors. What they failed to adequately appreciate, and what supervisors failed to force them to address, was that this concentration created massive correlated risks.

Basic banking prudence suggests that when your deposit base and lending portfolio are both concentrated in a single volatile sector, your asset management needs to be extremely conservative to offset that concentration risk. Instead, SVB did precisely the opposite. The bank took the deposits pouring in during 2020 and 2021 and invested them primarily in long-duration government and agency securities that offered slightly higher yields than short-term Treasury bills but were highly sensitive to interest rate changes.

By the end of 2021, SVB held $120.1 billion in securities against $189.2 billion in deposits. Of those securities, $91.3 billion were classified as held-to-maturity, a mix of Treasury and agency bonds and mortgage-backed securities with an average duration of six years. This meant that if interest rates rose, the market value of these securities would fall dramatically, and the bank would be unable to sell them without realizing massive losses that would decimate its capital.

This was not sophisticated risk management matching correlated deposit and lending risks with conservative, liquid assets. This was chasing yield by taking duration risk that was poorly hedged and fundamentally incompatible with the bank's deposit volatility.

Several elements of the regulatory framework that were weakened by EGRRCPA and the Fed's tailoring approach would have specifically addressed this concentration risk. Comprehensive stress testing would have forced SVB to model scenarios where tech sector deposits fled while interest rates rose sharply. Full LCR requirements would have demanded that the bank maintain more truly liquid assets rather than long-duration securities that couldn't be sold quickly without losses. Enhanced capital requirements recognizing AOCI would have made the mounting losses on these securities visible before they became fatal.

Most importantly, assertive supervision would have questioned whether a bank with SVB's extreme concentration should be allowed to pile additional interest rate risk on top of its inherent sector risks. Supervisors had the authority under both the law and the Fed's own regulations to impose heightened standards on SVB given its unique risk profile. They didn't.

Interest Rate Risk Management: When Hedging Becomes Unhedging

Silicon Valley Bank's management of interest rate risk represents a case study in how sophisticated financial institutions can make catastrophically bad decisions when incentives, culture, and oversight all point in the wrong direction.

Interest rate risk is fundamental to banking. When banks take in deposits (a liability) and invest them in loans or securities (assets), they're inherently exposed to changes in interest rates. If rates rise, the value of existing fixed-rate assets falls, while deposit costs may increase. Managing this mismatch is Banking 101, taught in every introductory finance course and every bank management training program.

SVB was well aware of its interest rate risk. The bank had sophisticated risk management systems and employed people who understood these dynamics. In fact, according to the Federal Reserve's review, SVB initially had some interest rate hedges in place during 2021 to protect against rising rates.

But here's where the story takes a troubling turn. As interest rates remained low throughout 2021, SVB's hedges proved costly – they were paying for protection against rate increases that weren't happening. In a fateful decision, bank management removed many of these hedges in late 2021, effectively betting that rates would remain low for an extended period.

This decision appears to have been driven by a desire to maximize short-term profits and protect against potential rate decreases rather than managing the long-run risk of rising rates. When rates are low and the yield curve is steep, banks can earn higher profits by taking duration risk – buying longer-term assets that pay higher yields than short-term funding costs. SVB's management, under pressure to deliver attractive returns to shareholders during a period of massive deposit growth, apparently prioritized this profit opportunity over prudent risk management.

The decision to remove rate hedges occurred despite multiple warning signs that the Fed might need to raise rates. Inflation was beginning to accelerate in late 2021. Fed officials were increasingly discussing the possibility of rate increases. The yield curve itself was signaling market expectations of higher future rates. Yet SVB's management chose to increase rather than reduce their interest rate exposure at precisely the moment when prudence called for the opposite.

Even more troubling, when supervisors identified interest rate risk concerns in examinations during 2020, 2021, and 2022, they did not issue formal supervisory findings requiring corrective action. Instead, examiners documented these concerns and engaged in discussions with management that apparently went nowhere.

The consequences of this mismanagement became apparent once the Federal Reserve began its aggressive rate hiking campaign in March 2022. The Fed raised its benchmark rate from near zero to over 4.5% within a year, one of the fastest tightening cycles in history. As rates rose, the market value of SVB's securities portfolio collapsed.

Remember those $91.3 billion in held-to-maturity securities? By year-end 2022, they carried approximately $15 billion in unrealized losses. If SVB needed to sell these securities to meet deposit withdrawals, it would have to recognize those losses, wiping out a substantial portion of the bank's capital.

SVB was caught in a vise. Rising rates meant two things simultaneously: their securities portfolio was worth far less than book value, and their depositors were drawing down accounts to fund operations in a higher-rate environment where venture capital was scarce. The bank couldn't meet deposit withdrawals without selling securities at massive losses, but selling securities would reveal the underlying insolvency that the held-to-maturity accounting had masked.

In late 2022 and early 2023, SVB's management scrambled to address the situation. They developed plans to restructure the balance sheet, moving some securities from held-to-maturity to available-for-sale to provide more flexibility. But these plans required careful execution and market cooperation. When the bank announced on March 8, 2023, that it had sold $21 billion in securities at a $1.8 billion loss and was attempting to raise $2.25 billion in new capital, sophisticated depositors immediately understood the implications.

If SVB needed to raise capital urgently and was willing to realize huge losses on securities sales, the bank must be in much worse shape than its financial statements suggested. The race was on to withdraw deposits before the bank collapsed. Over the next 36 hours, depositors attempted to withdraw $142 billion – nearly 80% of the bank's deposits. No bank can survive that.

The Regulatory Authority That Was Always There

A critical fact often lost in post-collapse analysis is that federal regulators always had the legal authority to prevent SVB's failure. EGRRCPA and the Fed's tailoring framework weakened requirements and shifted supervisory culture, but they didn't eliminate regulatory tools.

The Federal Reserve Board retained what's known as "reservation of authority" under its enhanced prudential standards regulation. This provision, codified at 12 CFR 252.5, explicitly states that "nothing in this part limits the authority of the Board under any provision of law or regulation to impose on any company additional enhanced prudential standards."

Let that sink in. The Fed could have, at any point after SVB crossed $100 billion in assets, imposed stricter capital requirements, liquidity standards, stress testing obligations, or any other prudential measure it deemed necessary. The law didn't prevent this. The Fed's own regulations explicitly preserved this authority.

The Bank Policy Institute, which represents large banks, issued a detailed analysis after SVB's failure explaining that under both EGRRCPA's text and the Federal Reserve's implementing regulations, "the Federal Reserve retained ample authority" to apply enhanced standards to SVB "and could have done it as soon as early 2021 by issuing an order directing the fast-growing SVB to meet more stringent regulatory requirements."

The Fed could have required SVB to meet full Liquidity Coverage Ratio standards despite being under the $250 billion threshold. It could have required AOCI recognition in capital. It could have imposed more frequent and rigorous stress testing. All of these actions were legally available through either rulemaking or direct supervisory orders.

Why didn't it happen? The Federal Reserve's own review provides uncomfortable answers. The "shift in the stance of supervisory policy" following EGRRCPA meant that supervisors were reluctant to impose requirements beyond what the tailoring framework specified without extensive justification. The emphasis on "reducing burden on firms, increasing the burden of proof on supervisors, and ensuring that supervisory actions provided firms with appropriate due process" created a culture where assertive supervision was difficult.

Supervisors needed to build extensive documentation justifying any departure from the base tailored standards. They needed to provide institutions with significant opportunities to respond and contest supervisory findings. The process became so cumbersome that it discouraged early intervention even when problems were visible.

This cultural shift didn't happen in a vacuum. It reflected policy choices made by Federal Reserve leadership in response to political pressure following EGRRCPA's passage. If Congress had just voted to provide "regulatory relief" and "tailored regulation" for midsize banks, Fed officials apparently concluded that they shouldn't immediately turn around and impose the very requirements Congress had just rolled back.

But this logic confuses political preferences with legal obligations. The Federal Reserve's fundamental job is to ensure the safety and soundness of the banking system and to protect depositors. Those obligations don't change because Congress passed a law making life easier for banks or because imposing tough standards might be politically uncomfortable.

The Silicon Valley Bank collapse demonstrates that having legal authority means nothing if supervisors lack the will, culture, or political backing to use it. Regulators watched SVB accumulate massive interest rate risk, build an unstable concentrated deposit base, repeatedly fail its own internal stress tests, and ignore supervisory concerns – and still didn't use the ample legal authorities they possessed to force change until it was too late.

The Depositor Base: How Uninsured Deposits Created Instability

Understanding Silicon Valley Bank's collapse requires understanding the unique nature of its depositor base and why that mattered for bank stability. This isn't an abstract technical issue – it's fundamental to how modern bank runs happen and how regulatory frameworks need to adapt.

Federal Deposit Insurance Corporation (FDIC) insurance covers $250,000 per depositor per bank. This insurance, created during the Great Depression, has been remarkably successful at preventing retail bank runs. When ordinary individuals know their deposits are insured, they have less reason to panic and withdraw their money at the first sign of trouble.

But FDIC insurance was designed for a different era of banking. The $250,000 limit made sense when most bank accounts were held by individuals and families. It still works well for retail banking today. But it creates significant vulnerabilities for banks that primarily serve business clients, particularly businesses that need to maintain large operational balances.

Consider a typical Silicon Valley startup that just raised a $50 million Series B funding round. That money goes into the company's bank account – probably at SVB, since that's where their VC investors expected them to bank. Of that $50 million, only $250,000 is FDIC insured. The remaining $49.75 million is uninsured, meaning the company faces the full risk of bank failure.

For depositors with uninsured funds, the calculus in a crisis is straightforward and brutal: if there's even a small chance the bank might fail, you need to be among the first depositors to withdraw funds. Wait too long, and you might lose everything. This creates the classic conditions for a bank run, where rational individual action produces collectively catastrophic outcomes.

Silicon Valley Bank's deposit base was extraordinary in both its concentration and its lack of insurance coverage. At year-end 2022, approximately 93% of SVB's deposits exceeded FDIC insurance limits. The average account size was far higher than typical retail or commercial banks. These weren't thousands of small accounts; they were hundreds or thousands of very large accounts held by startup companies and wealthy individuals.

This concentration was well-known to regulators. The California DFPI's post-mortem review explicitly notes that "SVB's high level of uninsured deposits contributed to the run on SVB" and should have triggered enhanced supervisory attention.

Moreover, these depositors were sophisticated and well-networked. Many banked with SVB not out of loyalty or convenience but because their venture capital investors required it as a condition of funding. They talked to each other, shared information through Slack channels and WhatsApp groups, and monitored the same tech news sources and financial Twitter feeds.

When SVB announced its securities losses and capital raise on March 8, information spread through the tech ecosystem at internet speed. Prominent venture capitalists began advising their portfolio companies to withdraw funds. The bank run of 2023 looked nothing like the panicked crowds outside Northern Rock in 2008 or depositors lining up at Lehman Brothers in 1931. Instead, it happened through wire transfer requests, ACH transactions, and mobile banking apps.

On March 9, 2023 – just one day after the capital raise announcement – depositors attempted to withdraw $42 billion. By the close of business, SVB had a negative cash balance of $958 million and owed the Federal Reserve $15 billion. The next morning, when the bank opened for business, another $100 billion in withdrawal requests waited to be processed. The bank simply didn't have the liquidity, and California regulators had no choice but to close it before markets opened on the West Coast.

The speed of this run – $142 billion in withdrawal requests across less than two business days – was unprecedented in American banking history. It wasn't that depositors were irrational or panicking without cause. They were making entirely rational decisions based on their understanding that if SVB failed, they would lose most of their uninsured deposits.

This dynamic raises profound questions about deposit insurance design and bank supervision. Should the $250,000 limit be increased to provide more coverage for business accounts? Should certain types of business operating accounts receive unlimited insurance? Or should banks with high concentrations of uninsured deposits face much stricter capital and liquidity requirements to offset the instability those deposits create?

These questions don't have easy answers, but SVB's collapse makes clear that the current framework isn't working. The assumption underlying much of bank regulation has been that retail deposits are stable and sticky, while wholesale funding is flighty and dangerous. But large uninsured business deposits, it turns out, can be just as unstable as any wholesale funding when confidence evaporates.

More assertive supervision could have addressed this risk even under existing regulations. Supervisors could have imposed higher capital requirements on SVB given its concentrated uninsured deposit base. They could have required the bank to maintain larger liquidity buffers or more conservative asset-liability matching. They had the authority to do all of this but chose not to exercise it until too late.

The Government Response: Systemic Risk Exception and the Bank Term Funding Program

When Silicon Valley Bank failed on March 10, 2023, followed quickly by Signature Bank on March 12, federal officials faced a crisis that required immediate action. The question wasn't whether to respond – the risk of contagion to other banks was too serious to ignore – but how to respond in ways that balanced financial stability with moral hazard concerns.

The Federal Deposit Insurance Corporation took over SVB as receiver and initially appeared to follow standard resolution procedures. Insured deposits – those under $250,000 per depositor – would be fully protected, as always. Uninsured depositors would receive a receivership certificate for their share of SVB's assets as they were liquidated, potentially recovering much but not all of their money over time.

This outcome, while following the letter of the law, would have been economically devastating for thousands of companies that banked with SVB. Many of these businesses couldn't make payroll or pay vendors without access to their deposits. The immediate economic harm would extend far beyond Silicon Valley's tech community to anywhere those companies operated or had employees.

Over the weekend of March 11-12, Treasury Secretary Janet Yellen, Fed Chair Jerome Powell, and FDIC Chairman Martin Gruenberg consulted about extraordinary measures. On Sunday evening, they announced an unprecedented action: invoking the "systemic risk exception" to provide full protection to all SVB depositors, including those with balances far exceeding the $250,000 insurance limit.

The systemic risk exception, created under the Federal Deposit Insurance Corporation Improvement Act of 1991, allows federal banking regulators to protect uninsured depositors when a bank's failure would create "serious adverse effects on economic conditions or financial stability." Using this authority requires a two-thirds vote of the FDIC Board and the Federal Reserve Board, consultation with the President, and a determination by the Treasury Secretary in consultation with the President.

The decision to invoke this exception for SVB was controversial from the start. Critics on the right argued it was a bailout of wealthy tech entrepreneurs and venture capitalists who should have diversified their deposits or accepted the consequences of banking with a poorly managed institution. Critics on the left worried it created moral hazard, signaling that any bank failure threatening politically connected industries would receive similar treatment.

The Biden administration strenuously avoided using the word "bailout," emphasizing that SVB's shareholders and bondholders would not be protected – only depositors. The costs of the resolution would be covered by special assessments on the banking industry, not taxpayers. This distinction, while technically accurate, didn't eliminate concerns about moral hazard.

The irony wasn't lost on observers: SVB had lobbied aggressively for lighter regulation to avoid being classified as a systemically important institution requiring enhanced oversight. Now, facing failure, the bank and its depositors were deemed systemically important enough to warrant extraordinary government protection. As economists Mathias Dewatripont, Peter Praet, and Andre Sapir noted in analysis for CEPR, "SVB got the better end of the stick, twice: First it dodged regulatory oversight, and then, once in trouble, it got bailed out from the regulatory protection."

Simultaneously with invoking the systemic risk exception, the Federal Reserve announced the creation of the Bank Term Funding Program (BTFP). This emergency lending facility addressed one of the core problems revealed by SVB's failure: banks across the country held securities that had lost significant value as rates rose, creating unrealized losses that could force them to recognize if they needed to sell securities to meet deposit withdrawals.

The BTFP offered one-year loans to eligible depository institutions, accepting U.S. Treasuries, agency securities, and mortgage-backed securities as collateral. The crucial feature: collateral would be valued at par (face value) rather than current market value. A bank holding a Treasury bond worth $90 on the open market but with a face value of $100 could borrow $100 from the BTFP, effectively allowing the bank to avoid recognizing the unrealized loss.

The Treasury Department backstopped the program with up to $25 billion from the Exchange Stabilization Fund. The Federal Reserve expected not to need this backstop and indeed never did, as the program was structured to be low-risk for the Fed despite providing substantial relief to banks.

Initial usage of the BTFP was modest but grew over the following months. By late March 2023, banks had borrowed $53.7 billion. Usage fluctuated through 2023, reaching record highs of $136 billion in December 2023 and $161.5 billion by January 2024.

These high usage figures raised concerns that banks were "gaming" the system. Under the BTFP's initial terms, banks could borrow at rates that were sometimes lower than the interest the Federal Reserve paid on bank reserves. This created a profitable arbitrage opportunity: borrow from the BTFP using securities as collateral, deposit the borrowed funds at the Fed as reserves, and pocket the spread. This wasn't the program's intended purpose.

In January 2024, the Federal Reserve announced it would let the BTFP expire as scheduled on March 11, 2024, and raised the interest rate on new loans to eliminate the arbitrage opportunity. The program successfully accomplished its immediate goal of preventing widespread bank failures in the aftermath of the SVB collapse, though at the cost of providing highly advantageous terms to banks that had taken excessive interest rate risk.

The BTFP represents emergency crisis management, not a sustainable solution to the underlying regulatory problems that allowed SVB's failure. It was necessary given the circumstances but also demonstrated how government backstops can encourage risky behavior when banks expect regulators will provide generous terms if things go wrong.

The Political Fallout and Reform Efforts

Silicon Valley Bank's collapse immediately became political, with lawmakers, regulators, and industry representatives offering sharply different diagnoses of what went wrong and what should be done.

Senator Elizabeth Warren, who had opposed EGRRCPA in 2018, introduced the Secure Viable Banking Act within days of SVB's failure. Co-sponsored by Representative Katie Porter and dozens of Democratic lawmakers, the bill would repeal Title IV of EGRRCPA, effectively rolling back the 2018 rollback and restoring Dodd-Frank's $50 billion threshold for enhanced prudential standards.

"In 2018, I rang the alarm bell about what would happen if Congress rolled back critical Dodd-Frank protections: banks would load up on risk to boost their profits and collapse, threatening our entire economy – and that is precisely what happened," Warren said in announcing the legislation.

Senator Bernie Sanders was characteristically blunt: "Five years ago, I helped lead the effort against the bank deregulation bill that led to the collapse of Silicon Valley Bank and Signature Bank. Now is the time to repeal that bill, break up too big to fail banks, and address the needs of working families, not vulture capitalists."

Republicans and moderate Democrats who had supported EGRRCPA pushed back against this narrative. Senator Mark Warner of Virginia, a Democrat who voted for the 2018 law, told CBS News's "Face the Nation" that "I have not seen any evidence" that the deregulation was responsible for SVB's fall.

Some Republicans blamed SVB's focus on environmental, social, and governance (ESG) initiatives and diversity programs, arguing the bank had been distracted from core risk management. The Wall Street Journal published an op-ed noting that SVB's board included "one Black," "one LGBTQ+," and "two veterans," suggesting diversity demands had diverted attention from financial fundamentals.

This ESG/diversity argument was thoroughly debunked by banking experts. Anita Ramasastry, a former Federal Reserve regulator and professor at the University of Washington School of Law, explained that SVB's problems stemmed from poor risk management and inadequate supervision, not its diversity initiatives. The bank's board composition, whatever its demographics, failed to prevent management from taking excessive interest rate risk – but so did boards at numerous other banks facing similar challenges.

The real political battle lines formed around regulatory reform. Democrats generally favored reversing EGRRCPA and reimposing stricter requirements on midsize banks. Republicans generally argued that SVB's failure reflected management incompetence and supervisory failures rather than inadequate regulation.

The Biden administration took a middle position. Without explicitly calling for legislation to repeal EGRRCPA, the White House supported federal regulators imposing stricter rules on midsize banks using their existing authority. This approach had the advantage of not requiring Congressional action in a divided government, but it meant changes would be slower and more limited than a legislative fix.

Federal Reserve Vice Chair for Supervision Michael Barr led the internal review of SVB's supervision and released a comprehensive 102-page report on April 28, 2023. The report was remarkably candid about regulatory failures, acknowledging that "regulatory standards for SVB were too low," supervision "did not work with sufficient force and urgency," and the Fed's tailoring approach "impeded effective supervision by reducing standards, increasing complexity, and promoting a less assertive supervisory approach."

Barr announced plans to strengthen supervision through changes in supervisory culture and practices, not waiting for new legislation. The Fed would move more quickly to escalate supervisory concerns, would be more assertive in requiring banks to fix identified problems, and would pay closer attention to interest rate risk and liquidity risk even for banks below the $250 billion threshold.

In July 2023, the Federal Reserve, FDIC, and OCC issued proposed rules to strengthen capital requirements for large banks – though notably, most of these proposals focused on banks over $100 billion and the largest institutions, rather than fundamentally reversing EGRRCPA's threshold changes.

The political reality is that comprehensive regulatory reform of the 2018 rollback remains unlikely without significant Democratic gains in Congress. The banking industry continues to argue against reimposing what it characterizes as unnecessarily burdensome requirements on midsize institutions. Bipartisan agreement on banking regulation, always difficult, seems particularly elusive in the current polarized environment.

Yet the fundamental questions raised by SVB's collapse remain unresolved. Should banks between $100 billion and $250 billion in assets face the same enhanced prudential standards as larger institutions? Should concentration risk and business model idiosyncrasies matter more in determining regulatory requirements than simple asset size? How can supervisors be empowered to act more assertively when they identify problems, even in the face of bank pushback and political pressure for lighter touch oversight?

These aren't merely technical regulatory questions. They're fundamental choices about how we balance financial system stability with banking industry profitability, how we distribute the costs of bank failures, and whether we learn from crises or repeat the same mistakes.

The Broader Context: Other Banks and Contagion Fears

Silicon Valley Bank didn't fail in isolation, and its collapse sent shockwaves through a banking system where multiple institutions faced similar pressures from rising interest rates and potentially unstable deposit bases.

Two days after SVB's closure, New York regulators seized Signature Bank, a large institution with significant exposure to the cryptocurrency industry. Signature's failure looked different from SVB's in the particulars – its problems centered on crypto exposures rather than tech startup deposits – but the underlying dynamic was similar: a concentrated, potentially flighty deposit base combined with asset-liability management challenges in a rising rate environment.

First Republic Bank, a large private bank serving wealthy clients in coastal cities, saw its stock price plummet as depositors feared a similar fate. Despite having a superficially different business model from SVB – First Republic focused on jumbo mortgages for wealthy individuals rather than tech company deposits – the bank faced similar fundamental challenges: a high proportion of uninsured deposits and an asset base significantly underwater due to rising rates.

In late March 2023, a group of large banks led by JPMorgan Chase committed $30 billion in uninsured deposits to First Republic to shore up confidence. This private sector intervention, clearly orchestrated with regulatory blessing if not outright pressure, temporarily calmed fears. But First Republic's problems proved fatal, and the bank was eventually seized and sold to JPMorgan in May 2023, becoming the second-largest bank failure in U.S. history after Washington Mutual.

Charles Schwab, Western Alliance Bancorporation, PacWest Bancorp, and other regional banks saw their stock prices hammered as investors and depositors scrutinized their balance sheets for SVB-like vulnerabilities. Many of these banks issued press releases and held conference calls attempting to distinguish their situations from SVB's, with varying degrees of success.

In Europe, the SVB crisis contributed to the collapse of Credit Suisse, a major Swiss global bank that had been struggling for years. While Credit Suisse's problems were distinct and predated the SVB crisis, the loss of confidence in banking institutions created by the American bank failures helped trigger the final crisis that forced Credit Suisse's emergency sale to UBS.

This pattern of contagion – where one bank's failure raises questions about similar institutions and triggers deposit flight even from healthier banks – is exactly what bank regulation is supposed to prevent. Dodd-Frank's enhanced prudential standards were designed to ensure that no single bank's failure would threaten the broader financial system. EGRRCPA's weakening of those standards for midsize banks was premised on the idea that banks under $250 billion couldn't pose systemic risks.

SVB's failure proved this premise false. A $200 billion bank, specialized in serving a concentrated sector, absolutely could threaten financial stability when its failure occurred in an environment where many other banks faced similar interest rate pressures.

The Federal Reserve's creation of the Bank Term Funding Program represented an acknowledgment that the risk of broader contagion was real and required extraordinary intervention. The program wasn't just about SVB; it was about preventing a cascade of failures as depositors questioned whether other banks might suffer similar fates.

Some banking experts argued that the contagion fears were overblown. They noted that most banks had more diversified business models than SVB and were better positioned to weather the interest rate environment. Federal Reserve analysis suggested that while many banks had unrealized losses on securities portfolios, most maintained adequate capital and liquidity to ride out the storm if depositors remained calm.

But this "if depositors remain calm" qualification is critical. Banking fundamentally depends on confidence. Banks engage in maturity transformation, taking in short-term deposits and making long-term loans and investments. This works when depositors trust that they can get their money back whenever they need it. When that trust evaporates, even well-capitalized banks can face fatal runs.

The question posed by the SVB crisis is whether the regulatory framework provides adequate protection against loss of confidence and contagion. The evidence suggests it doesn't, particularly for the 25 banks exempted from enhanced prudential standards by EGRRCPA.

Lessons for Consumers and Financial System Protection

For those of us who work in consumer finance and credit, the Silicon Valley Bank collapse offers crucial lessons about financial system fragility and the importance of robust regulatory frameworks. As someone who has spent nearly two decades helping consumers navigate credit challenges and advocating for stronger consumer protections, I see several critical takeaways.

First, regulation matters tremendously for consumer protection, even when consumers don't directly interact with the regulated institutions. Most SVB depositors weren't consumers in the traditional sense – they were businesses, often tech startups. But those businesses employ people, pay wages, and provide services that affect countless individual consumers. When SVB failed, thousands of companies suddenly couldn't make payroll or pay vendors. That's not an abstract financial system problem; it's a real harm to working people.

The decision to fully protect all depositors, including uninsured business accounts, prevented this harm from fully materializing. But relying on after-the-fact government intervention is an expensive and uncertain way to protect the economy. It would be far better to have regulatory requirements that prevent banks from failing in the first place.

Second, the arguments made for rolling back Dodd-Frank in 2018 should sound familiar to anyone who follows credit repair industry regulation. Banks argued that enhanced prudential standards were too burdensome, that they needed "tailored regulation" recognizing their lower risk profiles, and that lighter oversight would allow them to better serve their customers and communities.

Credit repair companies have made strikingly similar arguments about the Credit Repair Organizations Act and the Telemarketing Sales Rule. They claim these consumer protection laws are too restrictive, that they should be trusted to self-regulate, and that the regulations prevent them from effectively helping consumers improve their credit.

The SVB collapse demonstrates what happens when these arguments prevail: institutions take on risks they shouldn't, supervisors fail to catch problems early enough, and when failure comes it's sudden and catastrophic. The same dynamic plays out in credit repair fraud, where companies operating outside regulatory guardrails damage thousands of consumers before they're caught.

Third, concentration risk isn't just a banking concept – it applies to personal finances as well. SVB's clients learned an expensive lesson about keeping all their eggs in one basket. While the government ultimately made them whole, that outcome wasn't guaranteed, and many businesses went through terrifying days wondering whether they would lose their entire operating capital.

For individual consumers, concentration risk manifests differently. It might be carrying large balances on multiple credit cards from the same issuer, maintaining all accounts at a single bank, or depending entirely on one income source. Diversification isn't just an investment principle; it's a fundamental risk management strategy for personal finances.

Fourth, the importance of understanding how financial regulations protect you, even indirectly, can't be overstated. FDIC insurance on bank deposits, regulations governing credit reporting, and laws protecting against unfair debt collection practices all work in the background to make the financial system function. When these protections are weakened, consumers face greater risks even if they don't immediately notice the change.

This is why at Credlocity, we've always focused on more than just credit repair. We incorporate financial literacy education, budgeting assistance, and advocacy for stronger consumer protection laws into our work. Understanding how the financial system operates and how regulations protect consumers is essential for making informed decisions.

Fifth, the speed at which modern bank runs can unfold should concern everyone who maintains bank accounts. The traditional image of a bank run – crowds lined up outside bank branches – doesn't reflect modern reality. SVB faced $142 billion in withdrawal requests over less than two days, executed through digital channels. If your bank faced a crisis, you might have only hours to make decisions about moving your money.

This reality makes FDIC insurance limits even more important. The $250,000 per depositor per bank limit isn't arbitrary – it's the government's commitment to immediately make you whole if your bank fails. Balances above that limit require more careful consideration of whether the bank is sound or whether you should spread deposits across multiple institutions.

Sixth, regulatory capture – where industries gain undue influence over their regulators – is a constant threat that requires public vigilance. The banking industry's success in weakening Dodd-Frank wasn't achieved through convincing technical arguments about optimal regulatory design. It was achieved through lobbying, campaign contributions, and political pressure on lawmakers from bank-dependent constituencies.

Similar dynamics affect credit repair regulation, where industry groups constantly push to weaken enforcement of CROA and TSR requirements. As consumers and consumer advocates, we need to pay attention to these regulatory battles and make our voices heard when industries try to weaken consumer protections.

What Should Change: Regulatory Reforms Post-SVB

The Silicon Valley Bank collapse offers a clear roadmap for necessary regulatory reforms. While comprehensive legislation remains politically unlikely, the Federal Reserve and other banking regulators have substantial authority to strengthen oversight using existing legal powers. Here's what needs to happen:

Restore Enhanced Prudential Standards for Banks Over $100 Billion

The most straightforward reform would be restoring the original Dodd-Frank threshold of $50 billion in assets for enhanced prudential standards, or at minimum applying these standards to all banks over $100 billion. The Federal Reserve has the legal authority to do this without new legislation, using its reservation of authority under existing regulations.

Banks between $100 billion and $250 billion should face the full suite of requirements including comprehensive stress testing, full Liquidity Coverage Ratio requirements, mandatory AOCI recognition in capital calculations, and annual resolution planning. The argument that these institutions pose no systemic risk has been conclusively disproven.

Strengthen Supervisory Culture and Enforcement

Having the right rules on the books means nothing if supervisors don't enforce them assertively. The Federal Reserve's post-SVB review acknowledged that supervisory culture had shifted toward burden reduction and extensive due process for banks at the expense of forceful action when problems were identified.

Supervisors need clear authority and institutional backing to escalate concerns quickly, impose restrictions on risky activities, and move to formal enforcement actions when banks don't promptly address identified weaknesses. The burden of proof should be on banks to demonstrate they're managing risks safely, not on supervisors to prove risks are imminent before acting.

This cultural change requires support from the Federal Reserve Board and from political leadership. If supervisors know they'll face criticism and pushback every time they require a bank to strengthen its operations, they'll inevitably pull their punches. Strong supervision requires strong backing from leadership.

Address Concentrated Deposit Risks

Banks with highly concentrated uninsured deposit bases should face additional capital and liquidity requirements reflecting the instability these deposits can create. The current regulatory framework treats deposits as uniformly stable funding, but SVB's failure demonstrates that large concentrations of business deposits can be just as flighty as wholesale funding.

Regulators should develop measures of deposit concentration and volatility that inform capital and liquidity requirements. A bank where 90% of deposits are uninsured and come from a concentrated industry sector should face much higher standards than a bank with a diversified retail deposit base.

Reconsider Deposit Insurance Limits for Business Accounts

The current $250,000 FDIC insurance limit, appropriate for retail depositors, creates significant problems for businesses that need to maintain larger operational balances. Various proposals have been floated to address this, including higher limits for payroll accounts, extended coverage for business operating accounts, or facilitated access to programs like CDARS that spread deposits across multiple banks to stay within insurance limits.

These reforms involve trade-offs. Higher insurance coverage reduces run risk but increases taxpayer exposure and moral hazard. Finding the right balance requires careful analysis, but the current system clearly isn't working well for business depositors or for banking system stability.

Improve Interest Rate Risk Supervision

SVB's catastrophic failure to manage interest rate risk despite repeated supervisory warnings demonstrates that current examination practices aren't adequate. Supervisors need better tools for assessing interest rate risk, particularly in rapidly changing rate environments, and need to be more assertive when they identify deficiencies.

This includes requiring banks to maintain interest rate hedges appropriate to their asset-liability structure, questioning business decisions that concentrate rather than diversify risks, and being willing to impose restrictions on securities purchases when banks are taking duration risk they can't afford.

Increase Transparency Around Unrealized Securities Losses

One of SVB's most dangerous features was the ability to hide massive unrealized losses on its held-to-maturity securities portfolio. While these losses were disclosed in financial statement footnotes, they weren't reflected in headline capital ratios, making the bank appear healthier than it actually was to unsophisticated observers.

Requiring all banks over a certain size to recognize unrealized gains and losses in regulatory capital, regardless of securities classification, would make these risks visible to supervisors and markets earlier. This transparency might prevent problems from growing as large before they're addressed.

Mandate Comprehensive Climate and Economic Scenario Stress Testing

The Fed's stress testing program should include scenarios explicitly modeling rapid interest rate increases and their effects on securities portfolios. The fact that SVB's problems weren't caught earlier by stress testing suggests the scenarios weren't comprehensive enough or weren't applied to the right institutions.

Climate change-related stress tests should also be incorporated, as physical and transition climate risks will increasingly affect bank asset values and liquidity profiles. Building resilience to these predictable long-term risks should be a regulatory priority.

The Credit Repair Industry Parallel: Lessons in Regulatory Protection

Throughout my career in credit repair and consumer advocacy, I've observed striking parallels between banking regulation and credit repair industry oversight. The lessons from the Silicon Valley Bank collapse apply directly to how we protect consumers seeking credit repair services.

The Credit Repair Organizations Act (CROA) and Telemarketing Sales Rule (TSR), much like Dodd-Frank in banking, established comprehensive consumer protections based on decades of industry abuses. CROA requires credit repair companies to provide written contracts, prohibits advance fees, mandates specific disclosures, and gives consumers cancellation rights. The TSR adds additional protections for companies that enroll clients via telephone, requiring a six-month waiting period before charging fees.

Just as banks lobbied to weaken Dodd-Frank, credit repair companies constantly push against CROA and TSR enforcement. They argue these regulations are too restrictive, prevent them from serving consumers effectively, and should be relaxed or eliminated. Some operate in blatant violation of these laws, as documented in our investigative work exposing companies like Lexington Law and Credit Saint.

The parallels are instructive. When financial institutions or credit repair companies argue for lighter regulation, they emphasize their good intentions and professional management. They claim problems are isolated to a few bad actors and that industry self-regulation would be sufficient. They warn that compliance costs will be passed to consumers or that beneficial services won't be available if regulations remain strict.

These arguments often prevail in political environments friendly to business interests. EGRRCPA passed with bipartisan support in 2018 because enough lawmakers accepted the banking industry's assurances that midsize banks were different, better managed, and posed no systemic risks. We saw similar dynamics in 2019 when the Federal Trade Commission under the Trump administration dramatically reduced credit repair industry enforcement actions.

But when regulatory protections are weakened and enforcement becomes lax, problems inevitably emerge. SVB's failure demonstrated that banks given lighter oversight will take risks they shouldn't and that supervisors without strong enforcement cultures won't catch problems in time. In credit repair, reduced enforcement led to exactly what we documented in our investigations: companies engaging in systematic fraud, fake review manipulation, and deceptive practices that harm vulnerable consumers.

At Credlocity, we've built our business model specifically to comply with all regulatory requirements while delivering effective services. We don't offer phone enrollments precisely because the TSR's six-month waiting period for phone-enrolled clients makes this business model unworkable. We provide detailed written contracts, comprehensive disclosures about consumer rights, and comply with every CROA requirement.

We do this not because it's easy or maximally profitable, but because these regulations exist for good reasons based on decades of industry abuse. Just as banking regulations like capital requirements and stress testing protect depositors and financial system stability, CROA and TSR protect credit repair consumers from fraud and abuse.

The temptation to cut corners or "disrupt" regulatory compliance is strong in any industry. Companies that avoid regulatory compliance can undercut compliant competitors on price, spend more on marketing, and grow faster. But this competitive advantage comes at the expense of consumer protection and systemic stability.

When we see credit repair companies operating illegally – charging advance fees, providing inadequate disclosures, enrolling clients by phone and immediately charging fees in violation of TSR requirements – we don't hesitate to expose them. Our investigative journalism on companies like Lexington Law and Credit Saint serves the same function that banking regulators should have served in stopping SVB's problematic practices: identifying violations and holding bad actors accountable before they harm more consumers.

The lesson from both banking and credit repair is clear: robust regulation and assertive enforcement are essential for consumer protection and market integrity. When regulations are weakened or enforcement becomes lax, bad actors proliferate, consumer harm increases, and eventually systemic crises emerge. We've seen this pattern repeat too many times to continue pretending that industry self-regulation or light-touch oversight will suffice.

Consumer Action Steps: Protecting Yourself in an Unstable Banking Environment

While regulatory reform is essential for systemic protection, individual consumers and businesses need practical strategies for protecting their finances in the current environment. Based on 17 years of experience helping clients navigate financial challenges, here are concrete steps you can take:

Understand and Respect FDIC Insurance Limits

The $250,000 FDIC insurance limit is per depositor per bank. If you have more than this amount in deposit accounts, consider spreading funds across multiple FDIC-insured institutions. The FDIC provides a calculator on their website to help you understand how different account ownership structures affect your coverage.

For business accounts that need to maintain larger balances, look into programs like Certificate of Deposit Account Registry Service (CDARS) or Insured Cash Sweeps (ICS) that automatically spread funds across multiple banks to stay within insurance limits.

Diversify Your Banking Relationships

Don't keep all your accounts at one institution, particularly if it's a smaller or specialized bank. Having accounts at multiple banks provides backup access to funds if one bank faces problems and gives you options for moving money quickly if concerns arise.

Consider maintaining accounts at different types of institutions: a large national bank for stability, a community bank or credit union for personal service and local connections, and perhaps an online bank for higher interest rates on savings.

Monitor Your Bank's Financial Health

While most consumers can't analyze bank balance sheets like professional analysts, you can watch for warning signs: negative news coverage, stock price declines if it's a publicly traded bank, or unusual restrictions on withdrawals or services.

If your bank is experiencing problems, act quickly. Modern bank runs unfold over hours or days, not weeks. Have a plan for where you would move funds in an emergency.

Separate Your Banking from Other Services

Silicon Valley Bank's clients often maintained multiple relationships with the bank: deposits, loans, private banking, and other services. This concentration created challenges when the bank failed because multiple services were disrupted simultaneously.

Where possible, separate your banking from loans, investments, and other financial services. This diversification means you're less likely to face multiple simultaneous problems if one institution fails.

Maintain Emergency Cash Reserves

Keep enough cash outside the banking system to cover essential expenses for at least a few days. If your bank fails or faces a crisis, you might face temporary disruptions in accessing your funds even if they're insured. Having physical cash available provides security during this disruption.

Understand Your Consumer Rights

Whether you're dealing with banking issues, credit problems, or other financial challenges, understanding your legal rights is essential. Federal laws like the Fair Credit Reporting Act, Fair Debt Collection Practices Act, and Fair Credit Billing Act provide important protections, but only if you know they exist and how to invoke them.

If you're considering credit repair services, understand your CROA rights: no company can charge you before services are fully performed, you must receive written contracts with detailed disclosures, and you have three days to cancel any contract. Any company that doesn't comply with these requirements is operating illegally.

Be Skeptical of Deregulation Arguments

When industries lobby to weaken consumer protections, they always claim the changes will benefit consumers through lower costs, more innovation, or better services. The SVB collapse demonstrates how hollow these promises can be.

As consumers and citizens, we need to be skeptical when financial institutions or other regulated industries argue for lighter oversight. History shows that when regulations are weakened, consumer harm and systemic instability usually follow.

Support regulatory agencies like the Consumer Financial Protection Bureau, which was created after the 2008 crisis specifically to protect consumers in financial transactions. Despite constant industry pressure to eliminate or weaken the CFPB, it has returned billions of dollars to consumers harmed by financial misconduct.

The Future of Banking Regulation: Unfinished Business

As this article is published in late 2025, nearly three years after the Silicon Valley Bank collapse, the regulatory landscape remains incomplete and contested. While some reforms have been implemented, fundamental questions about banking oversight remain unresolved.

The Federal Reserve has strengthened certain supervisory practices, moving more quickly to escalate concerns and being more assertive about requiring banks to address identified problems. But comprehensive legislative reform has not materialized. EGRRCPA remains in effect, with its $250 billion threshold for enhanced prudential standards continuing to exempt 25 of the largest non-global systemically important banks from the strictest oversight.

The banking industry continues to fight even modest regulatory strengthening. Industry groups have opposed Federal Reserve proposals to increase capital requirements, arguing that stronger requirements would restrict lending and harm economic growth. These arguments echo those made before the SVB collapse and before the 2008 financial crisis, suggesting little has been learned about the costs of inadequate oversight.

Political polarization makes comprehensive reform unlikely without significant changes in Congressional control. Democrats generally favor returning to stronger Dodd-Frank standards, while Republicans generally oppose significant new regulations. This stalemate means that regulatory changes will likely come incrementally through agency rulemaking rather than comprehensive legislation.

The international regulatory environment adds another layer of complexity. European banking regulators have drawn their own lessons from the SVB collapse and Credit Suisse failure, with some jurisdictions moving to strengthen requirements while others resist changes. In a globally integrated financial system, divergent regulatory approaches create arbitrage opportunities and competitive inequities.

Climate-related financial risks are becoming increasingly important to banking regulation. As climate change creates physical risks to assets and transition risks to carbon-intensive industries, banks' exposure to these risks grows. Regulatory frameworks are slowly adapting to require disclosure and assessment of climate risks, but progress remains slow compared to the pace of climate change itself.

Technological change in banking, particularly the growth of digital banking and fintech, creates new regulatory challenges. When SVB's depositors could request withdrawals through mobile apps and wire transfers, the speed of bank runs accelerated dramatically. Future regulatory frameworks need to account for these technological realities.

Cryptocurrency and digital assets pose related challenges. Signature Bank's failure was linked partly to its crypto exposure, and other banks with significant digital asset activity face unique risks. How regulators should oversee these activities remains contentious, with industry advocates pushing for lighter touch oversight while consumer advocates warn of fraud and instability risks.

The FDIC deposit insurance fund remains under pressure. While the fund is not at imminent risk of depletion, the special assessments required to cover SVB, Signature Bank, and First Republic failures were substantial. If another wave of bank failures occurred, the fund might need replenishment through higher assessment rates on remaining banks – costs ultimately borne by depositors through higher fees and lower interest rates.

Addressing concentrated deposit risks requires rethinking deposit insurance design, but fundamental reform faces political obstacles. Increasing insurance limits helps businesses but increases taxpayer exposure. Creating special categories for business operating accounts adds complexity. Requiring businesses to use deposit spreading services creates friction in banking relationships.

The moral hazard created by full protection of SVB's uninsured depositors hasn't been resolved. Future bank failures will face questions about whether similar protection should be provided. If markets expect that systemically important failures will always result in full depositor protection, banks and depositors may take greater risks assuming bailouts will be available.

The question of how to treat unrealized securities losses in bank capital requirements remains contentious. While greater transparency would help identify problems earlier, banks argue that recognizing unrealized losses from securities they intend to hold to maturity artificially depresses their capital levels and restricts lending capacity.

Interest rate risk management standards need updating for the modern rate environment. The long period of ultra-low rates from 2008 to 2021 made many banks complacent about interest rate risk. As the Fed's aggressive tightening cycle demonstrated, rates can move quickly and dramatically. Regulatory frameworks need to ensure banks are prepared for rate volatility, not just the most recent rate environment.

The SVB collapse revealed significant gaps in how regulators assess rapid growth as a risk factor. SVB's deposits nearly tripled in two years, which should have triggered intensive supervisory scrutiny but didn't. Regulatory frameworks need clearer triggers for enhanced oversight when banks experience unusual growth, particularly when that growth comes from concentrated sources.

About Credlocity: Our Commitment to Ethical Credit Repair and Consumer Education

For 17 years, Credlocity Business Group LLC has provided ethical, transparent credit repair services while advocating for stronger consumer protections and financial literacy. Founded in 2008 after I experienced credit repair fraud by Lexington Law, Credlocity was built on a simple principle: consumers deserve honest, compliant credit repair services that actually help them understand and improve their financial situations.

As a Board Certified Credit Consultant (BCCC) and holder of the Certified Credit Score Consultant (CCSC), Certified Credit Repair Specialist (CCRS), and FCRA Certified Professional credentials, I bring both professional expertise and personal experience to this work. Having served over 79,000 clients nationwide and successfully helped remove $3.8 million in unverified debt from credit reports, we've demonstrated that ethical credit repair can be both effective and compliant with all federal and state regulations.

Our approach extends beyond traditional credit repair. Every client receives monthly one-on-one consultations and budgeting assistance, because we understand that credit problems are usually symptoms of broader financial challenges. We provide access to our mobile app for real-time credit monitoring and maintain educational resources covering everything from credit reporting law to personal finance fundamentals.

We're proud to operate as a Hispanic-owned, minority-owned, women-owned, and LGBTQAI+-owned business serving all 50 states from our Philadelphia headquarters. Our diversity isn't about checking boxes; it reflects our understanding that financial systems often fail marginalized communities and that consumer advocacy requires voices from those communities.

Since 2019, we've conducted investigative journalism exposing systematic fraud in the credit repair industry, including detailed investigations of major companies like Lexington Law and Credit Saint. This work, while sometimes controversial, serves our fundamental mission: protecting consumers from predatory practices and advocating for robust enforcement of consumer protection laws.

We comply fully with the Credit Repair Organizations Act and Telemarketing Sales Rule, never charging advance fees, always providing comprehensive written disclosures, and accepting enrollments only through our online platform to avoid TSR's phone enrollment restrictions. We maintain a 180-day money-back guarantee and offer a 30-day free trial so consumers can evaluate our services risk-free.

Our zero negative BBB reviews after 17 years in business reflect our commitment to transparency and ethical service. When consumers trust us with their credit repair needs, we take that responsibility seriously, providing honest assessments, realistic timelines, and comprehensive support throughout the process.

Credlocity represents what credit repair should be: compliant, transparent, educational, and genuinely helpful to consumers navigating complex credit challenges. Just as strong banking regulation protects financial system stability, strong credit repair regulation protects consumers from fraud – and we're committed to both following and advocating for these protections.

Legal Disclosures

Not Legal or Financial Advice

This article provides educational information only and does not constitute legal or financial advice. Every individual's situation is unique, and you should consult with qualified professionals regarding your specific circumstances. For legal questions, consult a licensed attorney. For financial advice, work with a qualified financial advisor.

CROA and TSR Compliance Statement

Credlocity operates exclusively within the requirements and limitations of the Credit Repair Organizations Act (CROA) and the Telemarketing Sales Rule (TSR). We make no guarantees regarding credit score improvements or specific results. Credit repair outcomes depend on numerous factors including the accuracy of information on your credit reports, your credit history, and actions you take during the process.

Accurate Information Disclaimer

We cannot and do not remove accurate negative information from credit reports. We work exclusively to address inaccurate, unverifiable, or improperly reported information as permitted under the Fair Credit Reporting Act and related consumer protection laws.

TSR Phone Enrollment Warning

Federal law requires that credit repair companies who enroll clients over the phone must wait six months before charging any fees. Credlocity avoids this requirement by accepting enrollments only through our online platform, never over the phone. We disclose this information so consumers can protect themselves from companies violating this law. Any credit repair company charging fees immediately after a phone consultation is operating illegally, and you should report them to the FTC at https://reportfraud.ftc.gov/.

FTC Reporting Encouragement

We encourage all consumers to report any credit repair company who charges for services after signing up following a phone consultation at https://reportfraud.ftc.gov/. Consumer protection depends on consumers reporting violations when they encounter them.

Conclusion: The Price of Regulatory Failure and the Path Forward

The Silicon Valley Bank collapse wasn't an unforeseeable black swan event. It was a predictable consequence of weakened regulations, lax supervision, and a business model that concentrated multiple correlated risks without adequate safeguards. Every element of SVB's failure – the concentrated deposit base, the interest rate risk, the inadequate liquidity, the rapid growth without corresponding risk management improvements – was visible to regulators years before the collapse.

What failed wasn't the ability to see these problems. What failed was the regulatory framework that would have prevented SVB from taking these risks in the first place, and the supervisory culture that would have forced the bank to fix problems once they were identified. EGRRCPA and the Federal Reserve's implementation of tailoring standards created an environment where a $200 billion bank faced less oversight than it would have under Dodd-Frank, despite posing clear systemic risks.

The cost of this regulatory failure extends far beyond SVB itself. Thousands of companies faced existential threats when their deposits were frozen. Other banks faced runs as depositors questioned whether similar problems lurked on their balance sheets. The government had to invoke extraordinary emergency authorities and create new lending facilities to prevent broader contagion. Taxpayers indirectly bore costs through the special assessments on banks needed to cover FDIC's losses.

Most troublingly, the moral hazard created by the government's decision to protect all SVB depositors, including those with uninsured balances far exceeding FDIC limits, sets a precedent that may encourage greater risk-taking in the future. If banks and their depositors believe that institutions deemed systemically important will always receive full protection regardless of their regulatory status, the incentive to maintain prudent risk management diminishes.

The path forward requires acknowledging uncomfortable truths. First, the premise underlying EGRRCPA – that banks with $100 billion to $250 billion in assets pose no systemic risks and therefore merit lighter oversight – has been conclusively disproven. These institutions can absolutely threaten financial stability, particularly when multiple similar institutions face common shocks or when their depositors are concentrated and interconnected.

Second, supervisory culture matters as much as regulatory requirements. Even with perfect rules on the books, if supervisors lack the will, authority, or institutional support to enforce them assertively, the rules provide little protection. The Federal Reserve's post-SVB reforms to supervision culture are important, but they need to be sustained through leadership changes and political pressure to be effective.

Third, rapid change creates risk that regulatory frameworks often fail to capture adequately. SVB's deposits tripled in two years, driven by unprecedented venture capital flooding into tech startups during the pandemic. This growth should have triggered intensive supervisory scrutiny but didn't, partly because regulatory frameworks treat growth primarily as a sign of success rather than a risk factor requiring enhanced oversight.

Fourth, concentration risk deserves much more attention in regulatory frameworks. Asset size alone is an inadequate measure of systemic importance. A bank with $200 billion in diversified assets across many sectors, geographies, and depositor types poses very different risks than a bank with $200 billion concentrated in a single sector with a handful of depositor types. Regulatory requirements need to account for these differences.

Fifth, the political economy of financial regulation requires constant vigilance from consumers, academics, and advocates. The banking industry will always push for lighter oversight, arguing that regulations are too burdensome and that industry self-regulation suffices. These arguments can be politically compelling, particularly in environments favoring business interests. But history repeatedly demonstrates that weakened regulation leads to greater risk-taking, supervisory failures, and eventually crises.

The Silicon Valley Bank collapse of 2023 will be studied in economics and finance courses for decades as a case study in regulatory failure. It offers clear lessons about the costs of weakening prudential standards, the importance of assertive supervision, and the dangers of concentration risk. Whether we learn these lessons and implement necessary reforms, or repeat the same mistakes in the next crisis, remains to be seen.

As someone who has devoted my career to consumer protection and financial education, I believe strongly that robust regulation and vigorous enforcement are essential for both consumer welfare and economic stability. The patterns I've observed in credit repair industry fraud mirror those in banking regulation: when oversight weakens and enforcement becomes lax, bad actors proliferate and consumer harm increases until a crisis forces renewed attention to the importance of protection.

We can do better. We must do better. The tools, knowledge, and legal authorities necessary to prevent financial crises exist. What's required is the political will to maintain strong regulatory frameworks and the supervisory culture to enforce them assertively. The Silicon Valley Bank collapse provides a painful reminder of what happens when we fail in this essential responsibility.

Sources

1. Board of Governors of the Federal Reserve System. "Review of the Federal Reserve's Supervision and Regulation of Silicon Valley Bank." April 28, 2023. https://www.federalreserve.gov/publications/files/svb-review-20230428.pdf

2. California Department of Financial Protection and Innovation. "Review of DFPI's Oversight and Regulation of Silicon Valley Bank." May 8, 2023. https://dfpi.ca.gov/wp-content/uploads/sites/337/2023/05/Review-of-DFPIs-Oversight-and-Regulation-of-Silicon-Valley-Bank.pdf

3. U.S. Government Accountability Office. "Bank Regulation: Preliminary Review of Agency Actions Related to March 2023 Bank Failures." GAO-23-106834. https://www.gao.gov/products/gao-23-106834

4. Federal Deposit Insurance Corporation. "Silicon Valley Bank." https://www.fdic.gov/resources/resolutions/bank-failures/failed-bank-list/silicon-valley.html

5. Roosevelt Institute. "How 2018 Regulatory Rollbacks Set the Stage for the Silicon Valley Bank Collapse, and How to Change Course." December 20, 2023. https://rooseveltinstitute.org/blog/how-2018-regulatory-rollbacks-set-the-stage-for-the-silicon-valley-bank-collapse-and-how-to-change-course/

6. Bank Policy Institute. "Congress's 2018 Regulatory Tailoring Law Did Not Preclude the Fed from Applying Enhanced Prudential Standards to Silicon Valley Bank." May 4, 2023. https://bpi.com/congresss-2018-regulatory-tailoring-law-did-not-preclude-the-fed-from-applying-enhanced-prudential-standards-to-silicon-valley-bank/

7. Dewatripont, Mathias, Peter Praet, and Andre Sapir. "The Silicon Valley Bank collapse: Prudential regulation lessons for Europe and the world." CEPR VoxEU. March 20, 2023. https://cepr.org/voxeu/columns/silicon-valley-bank-collapse-prudential-regulation-lessons-europe-and-world

8. Federal Reserve Board. "Bank Term Funding Program." https://www.federalreserve.gov/financial-stability/bank-term-funding-program.htm

9. Federal Reserve Board. "Federal Reserve Board announces it will make available additional funding to eligible depository institutions to help assure banks have the ability to meet the needs of all their depositors." March 12, 2023. https://www.federalreserve.gov/newsevents/pressreleases/monetary20230312a.htm

10. Wessel, David, and Timothy G. Massad. "What did the Fed do after Silicon Valley Bank and Signature Bank failed?" Brookings Institution. January 25, 2024. https://www.brookings.edu/articles/what-did-the-fed-do-after-silicon-valley-bank-and-signature-bank-failed/

11. CBS News. "Silicon Valley Bank's collapse shines light on lobbyists who helped deregulate banks." March 21, 2023. https://www.cbsnews.com/news/silicon-valley-bank-collapse-deregulation-dodd-frank/

12. U.S. Senator Elizabeth Warren. "Warren, Porter, Dozens of Democratic Lawmakers Introduce Bill to Repeal 2018 Rollback of Critical Dodd-Frank Protections." https://www.warren.senate.gov/newsroom/press-releases/warren-porter-dozens-of-democratic-lawmakers-introduce-bill-to-repeal-2018-rollback-of-critical-dodd-frank-protections

13. Wikipedia. "Collapse of Silicon Valley Bank." Accessed December 2025. https://en.wikipedia.org/wiki/Collapse_of_Silicon_Valley_Bank

14. Wikipedia. "Bank Term Funding Program." Accessed December 2025. https://en.wikipedia.org/wiki/Bank_Term_Funding_Program