On Feb. 29 one of the members of the Federal Open Markets Committee, Dallas Fed President Richard Fisher, called for the breakup of the top five U.S. Banks.

Big banks are in a battle for their existence. They are singled out and defined as unique by the government. There are many trade associations for banks (such as the ABA and the Financial Services Roundtable), but none yet exist explicitly for the benefit of America's largest banks. As the Federal Reserve is continuing to call for the dismemberment of the top banks, new representation is needed more than ever before.

The argument for breaking up the biggest banks is they are too big and have excessive deposits post economic meltdown. The reasoning seems at odds with the spirit of Volcker, that banks should only take deposits and lend. At a time when the Federal Reserve is call for the break of big banks, other regulators are exploring the diversification of community banks. There is a double standard at work.

It is true deposits are up, but is this possibly due to lack of alternatives and unlimited insurance? As of December 2011, the top 50 bank holding companies are about $15 trillion dollars in assets. The top five banks are just about 57%, but the top ten banks are about 75%. One could say the top five are not a sufficient sample to house the perception of systemic risk. But including the top ten would be undeniably representative of banking. So again, why just the top five? Every legal action seems to involve the top five banks. They are visible-well known, just not completely representative of all banking.

If the Volcker rule is implemented it will tear up our largest banks.

Suppose banking controls about $15 trillion in assets and, as reported in the December 2011 Quarterly Banking Profile, those assets are almost evenly split between loans and "other assets." If Volcker went in as proposed now, these get divested. Five or six trillion dollars of assets move into the wild, outside banking and outside all monetary control. The single largest loss to America was AIG. There were no big bank losses — help, yes, but no losses. Do we reward AIG and the likes? How could any central bank claim ownership of any form of monetary policy when hemorrhaging such a volume of currency?

If banking shed 40-50% of all assets, what is the need for regulators? If Mr. Fisher wins, would he accept the first pink slip?

Congress presumes that if ordered, banks will shed the "other assets" and "other businesses." But what if banks keep the "other" and shed banking?

Lending remains unprofitable with such low interest rates. This is an uncomfortable truth.

Artificial financial conditions have caused deposits to mushroom. Some banks are talking of halting deposits, others are thinking of charging deposit fees. Between about 2009 and the end of 2011 bank assets have increased, but loans have decreased.

If the "other assets" represent viable businesses, why not dump banking and keep the profitable pieces?

Banking has had a traditional bifurcated revenue stream: fees and interest. The interest had been pushed and held below both market and acceptable levels. Then fee income received the hatched. Banks have then tried to move into diversified areas and are now told that is a poison pill. What is left? Congress needs to understand they have accountability and they are very close to restraint of trade.

Suppose one was to look back over the recent past and ask has big bank lobbing or representation been successful. The resounding answer is an absolute "no!" The proof is seen in the comments of Mr. Fisher.

It is time for insanity to end and reason to return. The large banks need a new trade representation. There is no time to waste.

Timothy Alexander is the managing director of Triune Global Financial Services, which provides appraisal services, forensic investigations and collateral review for banks.