CFA Response to Proposed Suncorp-ANZ merger

The Consumers’ Federation of Australia has made a further submission to the Australian Competition & Consumer Commission (ACCC) about the proposed merger of ANZ Banks and Suncorp Bank.

The submission, following the publication of ACCC’s preliminary views, agrees with the ACCC that there are regulatory and structural barriers for smaller providers and newer entrants in the Australian banking market. It also suggests that the ACCC is right to identify a risk of increased coordinated conduct resulting from this proposed merger and question claimed public benefits arising from the acquisition.

CFA’s submission puts forward the following points:

  • That the ACCC should consider, in its analysis of competition in the banking market, markers of competitive outcomes (efficient prices, innovation, quality services etc.) as a richer and more meaningful approach than only considering the number of choices or level of switching.
  • That in considering claimed public benefits arising from the merger, the ACCC should give weight to concomitant detriments that arise from the removal of a mid-tier competitor from the market or the loss of opportunity for a stronger competitor that might arise should Suncorp Bank merge with another mid-tier bank.
  • That the ACCC should be concerned not just with efficiency of services when considering bank branch closures, but also with accessibility and inclusion which are stand-alone public benefits.
  • That the ACCC consider as a public detriment any innovative or good practices of Suncorp that may be lost should the proposed acquisition proceed.

A copy of the submission can be downloaded here.