Ninety-eight banks have already failed in 2009 — the highest number in nearly 20 years.
Camden Fine, chief executive of the Independent Community Bankers of America, said the 1,200 to 1,500 community banks that deal directly with agriculture could be the next to struggle, due to inflated commodities and farmland prices.
"I can tell you that from the community banking standpoint, that if TARP were the Titanic, the community banks were the third-class passengers," he said.
"There were no lifeboats for us."
As the Federal Deposit Insurance Corp. struggles with the alarming pace of small bank failures, Fine said the "best of the worst options" that the FDIC faces is to propose a prepayment rule for the banks themselves.
If the agency goes to the Treasury asking for a bailout, it won't be seen as a bailout of the FDIC, but rather as a bailout of the entire banking sector, he said.
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But despite the sector's struggle, Fine said it's important for people to keep scale in mind when analyzing community banks' health.
"There are over 8,000 community banks, and I would say that between now and 2010...less than 2 1/2 percent of those banks will actually fail," he said.
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Disclosure information was not available for Fine or his company.