Since the passage of Dodd-Frank, we've heard a lot of debate about whether the problem of "too big to fail" has been solved. No one thinks the problem has been all together erased. Some think the problem is actually getting worse, as top banks are even more dominant.

Here are some arresting facts from Robert Wilmers, chairman of M&T Bank in Buffalo, who has often warned of overconcentration by the top six banks for years. He tells Forbes that JPMorgan Chase, Goldman Sachs, Bank of America, Citigroup, Morgan Stanley and Wells Fargo control 35 percent of all deposits and 53 percent assets.

The real danger "lies in their trading revenues, accomplished with borrowed funds, which amounted in 2010 to $56.1 billion--or 93 percent of ALL trading revenues by ALL banks. But, get this--the combined trading revenues of the four largest banks represent more than the pre-tax income of all the other banks. Herein lies the risk. These large institutions have as their chief counter-parties in all their derivative trading each other."

The columnist suggests that "should there be a problem with one institution, instantly the wherewithal of the others would be impacted. This is not a perpetually  safe arrangement."

Theoretically, an exchange-based clearing approach would require collateral posted, which would reduce this problem. But the overall point is a good one.

Solutions to too-big-to-fail have proven elusive. Dodd-Frank may solve some problems, but not this one.

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