The strength of weak signals Exofficio cartel investigations

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The strength of weak signals Ex-officio cartel investigations in the banking sector in Italy

The strength of weak signals Ex-officio cartel investigations in the banking sector in Italy Rosella Creatini and Renato Ferrandi Italian Competition Authority Cartel Working Group SG 1 Teleconference on Ex Officio Cartel Investigations October 14, 2014

EX-OFFICIO INVESTIGATION S News Market intelligence triggered by the agency SUBSTANTIATED COMPLAINTS LENIENCY APPLICATIONS

EX-OFFICIO INVESTIGATION S News Market intelligence triggered by the agency SUBSTANTIATED COMPLAINTS LENIENCY APPLICATIONS prompted by the market

In the banking and insurance sectors You can hardly rely on leniency applications O

In the banking and insurance sectors You can hardly rely on leniency applications O Oligopolistic markets, big companies with long experience O Increasing concentration (consolidation process and new requirements) O Strong interaction among competitors, also through trade associations Or substantiated complaints by consumers O Highly technical sectors

EX-OFFICIO INVESTIGATION S News Market intelligence SUBSTANTIATED COMPLAINTS LENIENCY APPLICATIONS

EX-OFFICIO INVESTIGATION S News Market intelligence SUBSTANTIATED COMPLAINTS LENIENCY APPLICATIONS

EX-OFFICIO INVESTIGATION S News Market intelligence What is there in between? SUBSTANTIATED COMPLAINTS LENIENCY

EX-OFFICIO INVESTIGATION S News Market intelligence What is there in between? SUBSTANTIATED COMPLAINTS LENIENCY APPLICATIONS

EX-OFFICIO INVESTIGATION S News Market intelligence DETECTION TOOLS Market studies Circumscribed complaints Requests for

EX-OFFICIO INVESTIGATION S News Market intelligence DETECTION TOOLS Market studies Circumscribed complaints Requests for information SUBSTANTIATED COMPLAINTS LENIENCY APPLICATIONS

Market studies O Provide a better understanding of the sector O Help to identify

Market studies O Provide a better understanding of the sector O Help to identify anomalies and competition concerns O Raise consumer and public administration awareness and attention

Circumscribed complaints O Each consumer has a limited view of the market situation O

Circumscribed complaints O Each consumer has a limited view of the market situation O A public administration may point out suspicious outcomes of one or more tenders only … but several complaints may draw a pattern

Requests for information O Expand circumscribed complaints O In space (other suspicious tenders in

Requests for information O Expand circumscribed complaints O In space (other suspicious tenders in different territories) O In time (evolution over a certain period) … to draw the pattern

Market studies (examples) O Costs of bank accounts and services O Price increases, mainly

Market studies (examples) O Costs of bank accounts and services O Price increases, mainly focused on old clients of big banks O Low churn rate, due to poor transparency, bound with other bank services, time and cost of account closure

Market studies (examples) O Car insurance O High and fast-growing insurance premiums O Low

Market studies (examples) O Car insurance O High and fast-growing insurance premiums O Low availability of quote comparison websites and multi-firm agents

Cases O General cashier services for INAIL (2008) O Complaint from public administration INAIL

Cases O General cashier services for INAIL (2008) O Complaint from public administration INAIL on suspicious tender for provision of general cashier services O One only bid by the four biggest banks in a temporary grouping O RFI about tenders over the years O Temporary grouping already in place since 1996 O 3 failed tenders with no bids, successful tender when one only bid was allowed

O Dawn raids O Relevant market: cashier services for INAIL O Information exchange about

O Dawn raids O Relevant market: cashier services for INAIL O Information exchange about the tenders, economic model showing no need for temporary grouping O Unique and continuous agreement aimed at sharing the market

Cases O Healthcare liability coverage in Campania (2011) O Following a market study highlighting

Cases O Healthcare liability coverage in Campania (2011) O Following a market study highlighting increasing prices for health insurance… O Local health unit complained about anomalous increase in price for insurance services O RFIs to other 8 local health units about tenders over the past 10 years

O Dawn raids O 3 insurance companies coordinated their bids for 18 tenders from

O Dawn raids O 3 insurance companies coordinated their bids for 18 tenders from 2003 to 2008 O Contacts and information exchange, sharing of contracts and lots, co-insurance agreements