Since 2009 aggregate loans for small commercial banks are down around 16% or around $120 billion. Plus they now have to conform to basel 111 where their common equity has to exceed 4.5% of their risk adjusted assets plus they need a 2.5% buffer. That came as a big surprise today when the Fed made the announcement. I suppose the small guys can meet this over the next few year as their assets continue to shrink largely because they do not have products to cross sell.
But what do I know? I can't hold a candle to queenfooey, smarty, inlet and nobanker.