The U.S. Chamber of Commerce (“the Chamber”) appreciates the opportunity to
respond to the Federal Deposit Insurance Corporation (“FDIC”) solicitation of public
comments on rules, regulations, guidance, and policy on bank merger transactions.
The Chamber agrees that the FDIC should review the existing regulatory
framework in light of the significant changes in the last quarter century to current
economic realities and to our empirical understanding of the market, including the
following: the explosive growth in competition from online banks, credit unions, and
other finance options for consumers; studies indicating that concentration has declined
in finance markets and that, in any case, concentration does not reduce competition,
particularly given the relative ease of entry into credit markets and the ready availability
of competition from creditors outside of particular geographic markets; studies finding
that mergers can increase competition; and studies that call into question the use of
deposits as a metric for calculating the Herfindahl-Hirschman Index (HHI).
