CCMC Comments on FDIC Bank Merger

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).