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The final version of the 2023 Merger Guidelines, which were issued in December 2023, is a vast improvement over an earlier draft—which indicates that the Agencies took the many comments that they received on a draft very seriously. These Guidelines break some new ground that older Guidelines did not address, and make many positive contributions, which this paper spells out. They are also excessively nostalgic for a past era, however, and this may explain their propen sity to treat empirical questions as issues of law: This is one way to insulate these Guidelines from further revision. The excessive reliance on one decision, Brown Shoe, is unfortunate—particularly since that decision has been so often repudiated, even by the Supreme Court itself. This paper pays particular attention to: the Guidelines' treatment of structural triggers and direct measures of competitive effects; their aggressive position on potential competition mergers; their willingness to weigh a "trend" toward concentration as a factor; and their treatment of serial acquisitions. The Guidelines include a welcome new section on mergers involving multi-sided networks, although their view of networks is too one-sided; and the Guidelines also contain an expanded section on mergers with harmful effects on suppliers—including labor. The Guidelines' treatment of market definition is likely to lead to underenforcement because they define markets too broadly. Finally, the Guidelines could have made better use of recent retrospective studies—many of which would have provided further support for the substantive positions that the Guidelines take. [ABSTRACT FROM AUTHOR]

Supplier market power—such as the ability of branded goods suppliers to dictate terms to retailers—is an important feature of many markets. We show that supplier power can counteract the effects of downstream mergers on consumer prices where there are two-part contracts. This is because greater market power allows suppliers to set contracts that internalise partially the impact of the merger on downstream prices. Post-merger, the supplier reduces the per-unit price at which it supplies the merged downstream firms, with the aim of maintaining total industry profitability—and then recoups the profits via a larger fixed fee. We modify the standard upward pricing pressure (UPP) formula to account for the supplier's response to a horizontal merger in the downstream market, while preserving much of the simplicity of the standard approach. [ABSTRACT FROM AUTHOR]

This article discusses the auctioning of financial contracts by aggregations of consumers who aim to reduce the spot price of a concentrated industry's product; this is a frequent arrangement in electricity markets. The contracts' underlying asset is the product; the auctions' bidding variable is the strike price; and the bidders are the producers. Using a three-stage complete-information game, we show that when all consumers belong to some group, in the subgame perfect Nash equilibrium, each group fully hedges its consumption, and total output reaches its efficient level. Otherwise, each group over-hedges its consumption, and total production is below the efficiency level. [ABSTRACT FROM AUTHOR]

In the past year, Division economists have contributed to the Division's many investigations and enforcement actions. This review highlights several of the Division's enforcement efforts that have confronted issues of labor market competition, as well as a merger challenge that focused on the Division's theory of harm that would occur before the merger was consummated. [ABSTRACT FROM AUTHOR]

We analyze the competition issues in mobile money in Kenya–where Safaricom is the market leader–and in Uganda: where the market is duopolistic. We evaluate the multi-sided platform characteristics that have underpinned the rapid growth of the lead mobile money platforms and that also imply that the market leaders have substantial market power and can act as gatekeepers. The conduct of the lead firms is assessed along with competition measures and regulatory interventions made in each country. The analysis highlights the importance of–and challenges for–competition enforcement in developing countries to ensure effective rivalry while realizing the gains from innovation in digital platforms. [ABSTRACT FROM AUTHOR]

The antitrust enforcement Agencies' 2020 Vertical Merger Guidelines (VMGs) introduce a nontechnical application of bargaining theory into the competitive assessment of vertical acquisitions. This bargaining theory has much in common with the theory of unilateral effects that is applied to horizontal mergers. The VMGs focus on post-merger price increases requires consideration of a vertical merger's role in eliminating double marginalization (EDM). The problem occurs when two bargaining firms both have market power but are unable to coordinate their output. Assessing EDM bundles two themes that Ronald Coase developed in his two most well-known articles: "The Nature of the Firm" and "The Problem of Social Cost". The first argued that the boundaries of a firm are determined by the firm's continuous search to minimize costs. The second argued that two traders in a well-functioning market will achieve the joint-maximizing solution. Anti-interventionists rely heavily on Coasean arguments that unless high transaction costs get in the way firms will bargain to joint maximizing results. If that is true, then double marginalization will rarely provide a defense to a vertical merger. The law of vertical mergers deals largely with firms that transact with one another routinely, in legally enforceable buy-sell relationships. In a well-functioning vertical market durable double marginalization should be rare. [ABSTRACT FROM AUTHOR]

We find the optimal time for exercising a jointly held investment option. When the input market is competitive, the investment can take place earlier, later, or exactly when the optimal investment threshold is reached depending on how the option holders interact and on the bargaining power distribution. When instead the input supplier has market power, the game-theoretic framework downstream is shown to be of secondary importance. The timing effect that is attributed to the vertical relationship is always prevailing, which dictates the inefficient postponement of the investment. [ABSTRACT FROM AUTHOR]

We assess how the 2010 Merger Guidelines have been applied by agencies and courts. We conclude that: Increased reliance on direct evidence of market power has improved the analysis of mergers, but courts still sometimes overemphasize market definition. Market concentration thresholds remain a reflection of agency practice rather than economic research. The Upward Price Pressure concept yields useful intuition, but UPP can be overused. The benefits that could arise from the renewed focus on coordinated effects are squandered by the lack of a rigorous economic framework recognizing the connection to unilateral effects. The lack of merger retrospectives remains a problem. [ABSTRACT FROM AUTHOR]

Antitrust discussions in the U.S. have a long tradition of describing intellectual property (IP)—primarily patents and copyrights—in unqualified terms of "monopoly". Although there have been substantial efforts over the past two decades to pull back from this automatic association, the presumption of unqualified monopoly continues to appear in important legal decisions—as well as in legal and social sciences academic discussions—that involve IP. There is another place where these decisions and discussions might start: with a presumption that any IP is "primarily property"—albeit with some important distinctions that separate IP from "garden variety" tangible property and that raise the possibility of market power in some instances. This paper explores the important similarities—and differences—between "garden variety" property, such as real estate, and IP; it concludes that the similarities are substantial, so that the presumption that IP is "primarily property" is a reasonable alternative starting point for antitrust/IP discussions. It then discusses some beneficial differences that this alternative starting point could have made and/or could still make. [ABSTRACT FROM AUTHOR]

We examine the extent of market power in the brewing market of Perú, where the absence of preventive merger review eased consolidation into a single industrial brewer. We use a standard oligopoly model and exploit both seasonality in demand and atypically large and frequent variations in the structure and level of excise taxes to identify variations in market power. Our results provide evidence of the ineffectiveness of competition policy as uncontested mergers resulted in a degree of market power that decreased only with the entry of new firms. [ABSTRACT FROM AUTHOR]

In this paper, I analyze the effect of the merger between American Airlines (AA) and US Airways (US) on market price and product quality. I use difference-in-differences analysis (DID) as the identification strategy. The DID analysis shows that the price has decreased and that the decrease in price is larger in bigger city-pair markets. Smaller city-pair markets have not benefited from reduction in price. Price has increased in the smaller markets due to the merger. Slot divestiture also has been helpful in reducing the price. The DID analysis also shows that the merger has no significant effect on the frequency of flights or on the number of seats. Delay in arrival and delay in departure have increased, while the merger has a significant effect in reducing the number of canceled flights. [ABSTRACT FROM AUTHOR]

Fifty years ago, Williamson (Am Econ Rev 58:23, 1968) argued that an efficiency-enhancing merger that reduces production costs but increases market power could be saved from antitrust condemnation if the cost savings created by the merger offset the allocative inefficiency. In this paper, we discuss some extensions of Williamson's basic welfare tradeoff, and explore the attitudes of several countries around the world toward merger efficiencies. In spite of its economic logic, Williamson's analysis has not been embraced by most of the antitrust authorities around the world. We explore different reasons why antitrust authorities have failed to adopt an explicit social-welfare standard. [ABSTRACT FROM AUTHOR]

In many markets, prices adjust quickly when costs rise, yet adjust sluggishly when costs fall. Such asymmetric pricing has received particular attention in retail gasoline where larger asymmetry has been related to greater market power. Using novel data from urban and rural gasoline markets, I document new evidence on this relationship by providing the first estimates of asymmetric pricing from rural towns. I find substantial asymmetry in these markets, show that local market concentration is positively related to asymmetry, and highlight the potential role of role collusion in generating these patterns. [ABSTRACT FROM AUTHOR]

In this paper, we discuss whether the consumer welfare (CW) standard needs to be replaced or revised in order for antitrust law to deal effectively with the economic challenges of the platform economy. We argue that both the general and platform-specific assaults on the CW standard are misguided, that the CW standard is capable of addressing the economic concerns that critics have raised, and that the proposed alternatives would make things worse—not better. [ABSTRACT FROM AUTHOR]

Recent calls for using the antitrust laws to break up the large Internet giants are misplaced for a number of reasons. First, similar efforts against oil, tobacco, motion-picture, and telecommunications monopolies have not proved to be beneficial to economic welfare. Second, the failure to break up Microsoft using Section 2 has not proved to be a mistake: competition in operating systems and Internet browsers has flourished recently. Finally, a Section 2 case against Amazon, Facebook, or Google could not succeed if it focused on the digital advertising market. Even in a case based on market power on the other side of their platforms, a structural remedy—a break-up—would not improve economic welfare in the long run. [ABSTRACT FROM AUTHOR]

In this essay we consider why American colleges and universities participate in big-time commercialized intercollegiate sports, and how sports came to play such a prominent role on American college and university campuses. We also review how the National Collegiate Athletic Association (NCAA) developed as a body to regulate player safety and transformed itself into an economic regulator, the means by which the NCAA attempts to maintain its control, increase revenues, and reduce costs for college sports programs. We also examine how the organization succeeds in the face of institutional characteristics that imply that its cartel activities would be doomed. Finally, we speculate on what changes might be on the horizon for the NCAA and college athletics. [ABSTRACT FROM AUTHOR]

We investigate how the effects of market structure changes and mergers in restructured electricity markets depend on the level of forward contracting. We develop a Cournot model of Alberta's wholesale electricity market that incorporates firms' forward positions. Using data from 2013 to 2014, we calibrate the forward positions of the five largest firms and simulate the effects of different market structure changes, including a hypothetical merger with asset divestitures. We examine the sensitivity of the simulated effects to assumptions with regard to the firms' forward commitments. The wholesale market effects of these transactions depend critically on firms' forward commitments. These results demonstrate the importance of establishing a clear understanding of the size and nature of forward commitments in forecasting the effects of mergers and other market structure changes in wholesale electricity markets. [ABSTRACT FROM AUTHOR]

We examine search costs and product variety among multi-product retailers. Search costs may rise in variety, because consumers have more alternatives to consider, but may fall on the margin as product variety allows better matches between consumers and brands. We estimate a hierarchical model that disentangles the effect of variety on brand and store search costs. Our findings reveal that search costs within each store rise in product variety, suggesting that retailers reduce consumer search by offering deeper product assortments. But, the cost of searching among stores falls in product variety, which limits the exercise of market power. [ABSTRACT FROM AUTHOR]

The Federal Communications Commission is responsible for regulation in the telecommunications and electronic media sectors, and for management of the nation's non-federal radio frequency spectrum. During the past year, Commission economists contributed to the analysis of market power and the efficacy of various regulatory regimes in the business data services market, assessed potential harms that were associated with major mergers in the cable television industry and the efficacy of conditions designed to mitigate those harms, and helped to structure service and licensing rules to promote efficient usage of spectrum in the face of burgeoning demand for new wireless broadband services. [ABSTRACT FROM AUTHOR]

In the presence of naive consumers, a participation distortion arises in competitive markets because the additional profits from naive consumers lead competitive firms to lower transparent prices below cost. Using a simple calibration, we argue that the participation distortion in the US credit-card market may be massive. Our results call for a redirection of some of the large amount of empirical research on the quantification of the welfare losses from market power, to the quantification of welfare losses that are due to the firms' reactions to consumer misunderstandings. [ABSTRACT FROM AUTHOR]

Both the 'law of one price' and Bertrand's (J Savants 67:499-508, ) prediction of marginal cost pricing for homogeneous goods rest on the assumption that consumers will choose the best price. In practice, consumers often fail to choose the best price because they search too little, become confused comparing prices, and/or show excessive inertia through too little switching away from past choices or default options. This is particularly true when price is a vector rather than a scalar, and consumers have limited experience in the relevant market. All three mistakes may contribute to positive markups that fail to diminish as the number of competing sellers increases. Firms may have an incentive to exacerbate these problems by obfuscating prices, thereby using complexity to make price comparisons difficult and soften competition. Possible regulatory interventions include: simplifying the choice environment, for instance by restricting price to be a scalar; advising consumers of their expected costs under each option; or choosing on behalf of consumers. [ABSTRACT FROM AUTHOR]

ACOs were promoted in the 2010 Patient Protection and Affordable Care Act (ACA) to incentivize integrated care and cost control. Because they involve vertical and horizontal collaboration, ACOs also have the potential to harm competition. In this paper, we analyze ACO entry and formation patterns with the use of a unique, proprietary database that includes public (Medicare) and private ACOs. We estimate an empirical model that explains county-level ACO entry as a function of: physician, hospital, and insurance market structure; demographics; and other economic and regulatory factors. We find that physician concentration by organization has little effect. In contrast, physician concentration by geographic site-which is a new measure of locational concentration of physicians-discourages ACO entry. Hospital concentration generally has a negative effect. HMO penetration is a strong predictor of ACO entry, while physician-hospital organizations have little effect. Small markets discourage entry, which suggests economies of scale for ACOs. Predictors of public and private ACO entry are different. State regulations of nursing and the corporate practice of medicine have little effect. [ABSTRACT FROM AUTHOR]

We extend the Areeda-Turner rule to two-sided markets. We show that a two-sided monopolist may find it short-run profit-maximizing to charge a price below marginal cost on one side of the market. Hence showing that the price is below marginal cost on one side of a two-sided market cannot be considered a sign of predation. We then argue for a two-sided Areeda-Turner rule that takes into account price-cost margins on both sides of the market. Two examples highlight that applying a one-sided Areeda-Turner rule may lead one to assess legitimate prices as predatory or to consider predatory prices as legitimate. [ABSTRACT FROM AUTHOR]

In the only predatory pricing case in Australia to reach the High Court, the ideas and recommendations contained in the 1975 Harvard Law Review article by Phillip Areeda and Donald Turner were at the heart of the case. That case, the Boral case, decided by the High Court in 2003, raised a number of interesting issues with regard to whether and how the test that was proposed by Areeda and Turner should be employed to deal with price cuts by large firms that are aimed at competitors. Equally important, the case raised some fundamental questions about whether there was a serious 'gap' in the Australian equivalent of Section 2 of the Sherman Act-Section 46 of the Competition and Consumer Act 2010, formerly the Trade Practices Act 1974 (TPA)-which made it difficult to challenge predatory conduct. Boral led immediately to some radical changes in the TPA; but, even today, more than 10 years after Boral, Australians are still struggling to develop the right statutory framework to deal with predatory pricing. This paper will describe the Boral case, discuss how the Australian courts, including the High Court, attempted to apply the A-T test to the facts of the case, and survey and comment on the ongoing legislative turmoil that followed from High Court's decision. [ABSTRACT FROM AUTHOR]

The Interstate Commerce Act and Sherman Antitrust Act were passed within 3 years of each other. Although regulation and antitrust both address market power, the ICA and Sherman Act had different objectives. After a minimal reference to just and reasonable prices, the ICA focused on preventing price discrimination in rail. No posited Sherman Act goal-inequality, consumer welfare, efficiency-is in the ICA. Priority of discrimination in the ICA, however, is predictable. Shippers would care less about absolute rates-which can be passed on to final consumers-and more about preventing rivals from gaining advantages through input price discounts. [ABSTRACT FROM AUTHOR]

Anecdotal evidence suggests that domestic firms can use the antidumping petition process to engage in collusion and increase domestic prices. In this paper, I test whether the antidumping petition process itself can help domestic firms raise prices. I propose a method to identify whether firms in the industry experience a structural break in the level of market power possessed by the firms at the time that they file their antidumping petition. I use this methodology to analyze the impact of antidumping petitions on competition levels in two industries. I find little evidence that either of these industries increased their market power following the filing of petitions for trade relief, nor even from the protection that resulted from these petitions. These findings suggest that the widespread belief that antidumping leads to more market power may not always hold. [ABSTRACT FROM AUTHOR]

The countervailing power of large buyers subdues the market power of sellers, but price concessions won by large buyers in upstream markets may or may not translate into lower prices downstream as Galbraith (American capitalism: The concept of countervailing power. Houghton Mifflin, Boston, , Am Econ Rev 44:1-6, ) once contended. This paper presents a model that formalizes certain previously neglected elements of Galbraith's argument, and shows that upstream price concessions may lead to lower downstream prices. In this model, a large retail chain store with countervailing power plays one large supplier off against another to win lower prices. An indirect effect of these interactions is that small retailers also pay lower prices, although not as low as the chain. Finally, competition among the retailers drives retail prices lower. The retail-price-restraining effect of the chain is stronger than the effect that is produced by the entry of an additional supplier. [ABSTRACT FROM AUTHOR]

The invention of the price/cost margin (P-MC)/P as an index of market power is usually credited to Lerner (Rev Econ Stud 1(3):157-175, ). Landes and Posner (Harv Law Rev 94(5):937-996, ) is similarly often considered the main reference for the generalized version of the index in the case of a dominant firm that shares the market with price-taking rivals. From the viewpoint of the history of industrial economics both claims are incorrect. It was not Lerner who invented the price/cost margin index and the generalized version was fully derived before WWII. In both cases, priority should be given to Luigi Amoroso, the leading Italian mathematical economist in the interwar decades. In the latter case the names of Heinrich von Stackelberg and George Stigler also deserve credit. [ABSTRACT FROM AUTHOR]

In this article we introduce the abuse of dominance provisions in China's Anti-monopoly Law (AML) that was enacted in 2007, and we put this in context by briefly describing the laws on the abuse of dominance that existed before the AML, and their relationship with the provisions in the AML. We then discuss the interpretation and enforcement of the AML's abuse of dominance provisions, on the one hand generally in the context of China's new market competition environment and its political-legal system, and on the other hand specifically through a consideration of some recent antitrust cases on the abuse of market dominance. Finally, we offer a preliminary appraisal of the law and its enforcement. [ABSTRACT FROM AUTHOR]

Choosing the wrong theoretical model to describe an industry's behavior may lead to biased estimates of the degree of market power. This paper presents a two-step, data-driven methodology to reduce the risk of mis-specification bias. In the first step, a sliced inverse regression identifies the significant factors that affect the industry's pricing behavior. In the second step, a non-parametric regression of price on the SIR factors estimates the link functions. The output of the algorithm offers useful information to identify the model that best approximates the industry's pricing behavior. In addition, the output of the algorithm is used to develop a post-estimation test for model specification. [ABSTRACT FROM AUTHOR]

It is well known that market power depends on the price elasticity of demand and the intensity of competition. It is also well known that technology can influence market power through its effect on market structure. However, there is limited research on the direct link between market power and technology. In this paper, we investigate this relationship. We find that the monopoly price can be constrained to be identical to marginal cost under certain technological conditions. We also show how market power depends directly upon technology, holding constant demand conditions, market structure, and the degree of competition. [ABSTRACT FROM AUTHOR]

The well-known structural model used to estimate market power suffers from a severe collinearity problem if both the marginal cost and demand equations are linear. If the equations hold exactly, the variables are perfectly collinear so the model cannot be estimated. If the true linear model equations hold with errors, one can estimate the equations, but the estimated coefficients are likely to be highly unstable and unreliable due to nearly perfect collinearity. [ABSTRACT FROM AUTHOR]

In this paper we apply an innovative econometric tool to estimate mark-ups in an output market. The contribution of the paper is in the novel use of the stochastic frontier approach that is widely used to estimate efficiency. We show that this method, which we call the stochastic frontier estimator of market power, can be used both in the dual cost function framework and in the primal framework, and that mark-ups can be estimated with or without constant returns to scale. We apply this method to the Norwegian sawmilling industry, 1974-91. [ABSTRACT FROM AUTHOR]

The new Horizontal Merger Guidelines, if treated by courts as a source of law, would reduce the discretion that is traditionally exercised by courts in defining relevant markets and market power in merger cases. This is an undesirable shift in the balance of power because courts have used the market power inquiry stage of merger analysis as a general checkpoint or weigh station for evaluating factors relevant to the welfare effects of a merger. [ABSTRACT FROM AUTHOR]

This paper lays out and extends a derivation of the 'upward pricing pressure' ('UPP') tool for analyzing unilateral competitive effects of horizontal mergers on differentiated products that is featured in the 2010 Guidelines. In the most novel extension, the merger alters the differentiated products' qualities. The resulting tool analyzes whether the merger creates upward pressure on quality-adjusted or 'hedonic' prices. Another extension applies where one firm acquires just a partial equity stake in a competing firm. The paper also develops the Gross Upward Market Power Pressure Index (GUMPPI) that generalizes UPP measures to include output as well as price effects. [ABSTRACT FROM AUTHOR]

The 2010 Horizontal Merger Guidelines set forth the current antitrust enforcement practices but do not address mergers that result in bilateral monopoly. We show that, given the presence of lawful, enduring market power, such mergers may improve social welfare. As a result, these mergers deserve careful scrutiny before condemning them as anticompetitive. In this paper, we address this issue and suggest an economically sound enforcement policy. [ABSTRACT FROM AUTHOR]

Standard Oil formed the South Improvement Company in the fall of 1871, supposedly to negotiate 'secret' discounts on published railroad tariffs and place independent refiners at a transportation cost disadvantage. We argue that discriminatory railway rates were common both before and after Standard Oil's founding in 1870, played little or no part in its rise to prominence and were not necessarily even illegal. Rebates and drawbacks were in fact ways of sharing the efficiency gains that flowed from the dependable high-volume rail traffic Rockefeller was able to guarantee as well as from other investments that he undertook that lowered the railroads' costs. [ABSTRACT FROM AUTHOR]

The US residential broadband market is commonly characterized as a duopoly consisting of telephone carriers (digital subscriber lines) and cable TV operators (cable modems). The implication is drawn that market power obtains; this, in turn, drives recommendations for new competition policy remedies. Yet, market power cannot be directly deduced from market shares or price-cost margins. We develop an economic analysis that examines both static and dynamic factors in considering market power, finding that fixed broadband providers do not appear to generate supra-competitive returns. Public policies to regulate broadband providers should be informed by these marketplace conditions. [ABSTRACT FROM AUTHOR]

This paper investigates the exercise of market power by a large buyer who emerges via growth, merger, or group purchasing. It explores the efficiency and redistributive effects of such an event when a competitive fringe of small buyers remains in the market. Terms of trade, including those for small buyers, depend on structural conditions on the supply side of the market and the nature of interactions between the newly emerged dominant buyer and suppliers. Predicted aggregate welfare effects have implications for antitrust. [ABSTRACT FROM AUTHOR]

Unlike many other mergers in developed countries, which might have been assessed and their effects estimated by antitrust authorities before being granted antitrust immunity, the airline mergers that swept China’s airline industry in 2002 occurred with no antitrust challenge. These mergers provide the opportunity to study important market power issues in China’s airline markets. Given that increased concentration and multimarket contact are the main legacies of an airline merger, the effects of mergers on these variables can raise the potential for the exercise of market power. However, an examination of the period 2002–2004 during which the Chinese airline mergers occurred shows that the resulting increased concentration and enhanced multimarket contact did not have important consequences for airfares in Chinese city-pair markets. The presence of Hainan Airlines appears to have played an important role in suppressing the airfares charged by China Eastern and China Southern. [ABSTRACT FROM AUTHOR]

Indirect assessments of market conduct have become widespread in the New Empirical Industrial Organization—NEIO literature. Recently, Steen and Salvanes (1999, Int J Ind Organ 17:147–177) provided a flexible dynamic econometric formulation of the approach advanced by Bresnahan (1982, Econ Lett 19:87–92) and Lau (1982, Econ Lett 10:93–99). The present paper considers a similar approach applied to regional cement markets in Brazil under more favorable data availability, and attempts to address part of the concerns that usually emerge with respect to the NEIO literature. In particular, issues pertaining to structural stability and the control for the number of competing firms are addressed. The evidence clearly indicates non-negligible and distinct market power in different regions and also distinct conduct patterns in the short and long run. [ABSTRACT FROM AUTHOR]

Earlier research exploring rural bank entry decisions suggests that market size and its growth seem to be major explanatory factors. In addition, the role of leading bank holding companies is found to be important in stimulating entry of smaller rivals. This article finds that credit union entry responds in a similar way, and in addition that the state-level financial regulatory climate matters. An ordered-probit analysis of credit union numbers yields the intuitive result that credit unions possess little market power (even in rural markets where they might be expected to play a significant role), and what little there is can likely be eliminated by a third credit union in the market. [ABSTRACT FROM AUTHOR]