that blew up in 2007, but they bear disturbingly similar characteristics. Widespread commercial real estate losses in the coming months threaten to destroy any gains Wall Street has seen during the last year.

This threat has many analysts predicting a rise in the number of banks going belly up. More than 170 banks have failed since the beginning of the recession. To put that in perspective, only three banks failed between July 2004 and December 2007. And the bank closures show no signs of slowing down. In October the feds shut down 20 banks, the most of any month since 1994. Some analysts have predicted that as many as 1,000 banks will have imploded by the time the economy recovers.

The glass-half-full banking results that the administration has been toutingFargo's Silvia asks. "It is problematic."

Banks are aware of this problem. Interbank lending remains limited as confidence problems continue to plague the financial industry. "There is no grease in the engine in terms of bank credit or trade credit," CreditRiskMonitor.com CEO Jerry Flum told The Institutional Risk Analyst in October. The goal of the TARP capital injections was to get the lending engine going, but banks have largely been sitting on the money, holding increased excess reserves.

With so much money sitting idle, cash flow is a major concern for banks and their customers. It is unclear when the market will see stability again, and until new operational norms emerge banks are likely to remain tight with their cash. With the administration now promoting the biggest banking regulatory overhaul