Footnotes

Chapter 2 - Background - the Australian banking market

[1]        A brief history of banking in Australia can be found in Chapter 2 of House of Representatives Standing Committee on Finance and Public Administration (1991).

[2]        Mr Nicholas Hossack, ABA, Committee Hansard, 12 March 2009, p 1.

[3]        Examples include 'merchant banks' such as Tricontinental, Nugan Hand, and Rothwells; Pyramid Building Society (in the period before building societies were supervised by APRA), and finance companies such as FCA.

[4]        Reserve Bank of Australia, Financial Stability Review, March 2009, p 25.

[5]        The report Government measures to address confidence concerns in the financial sector – The Financial claims Scheme and the Guarantee Scheme for Large Deposits and Wholesale Funding, was tabled on 17 September 2009.

[6]        See Macfarlane (2009) for an elaboration.

[7]        To keep the trees legible, some small savings banks and building societies have been omitted.

[8]        See House of Representatives Standing Committee on Economics (2008).

[9]        Theodore et al (1932, p 9). A history of Australian banking is given in Chapter Two of House of Representatives Standing Committee on Finance and Public Administration (1991); see especially paragraphs 2.29, 2.41, 2.86, 2.87 and 2.93 on mergers. Chapter Eight is also relevant.

[10]      House of Representatives Standing Committee on Finance and Public Administration (1991, pp 120, 127).

[11]      This conclusion is also reached by House of Representatives Standing Committee on Economics (2008, p 26).

Chapter 3 - The economics of bank mergers

[1]        In addition, in some countries the authorities have driven the merger process under 'master plans' as a means of removing weak banks from the system, preferably before they failed; Mihaljek (2006).

[2]        Hawkins and Mihaljek (2001) show that the credit ratings of large banks are higher than those for small banks with the same inherent strength.

[3]        An econometric study by Bliss and Rosen (2001) supported this widely-held impression. 'Compensation generally increases even if mergers cause the acquiring bank's stock price to decline, as is typical after a merger announcement'; Warren Buffet (1993) holds a sceptical view about the benefits of mergers in general (not just banks), having said: 'I've observed that many acquisition-hungry managers were apparently mesmerized by their childhood reading of the story about the frog-kissing princess.  Remembering her success, they pay dearly for the right to kiss corporate toads, expecting wondrous transfigurations. Initially, disappointing results only deepen their desire to round up new toads...Ultimately, even the most optimistic manager must face reality.  Standing knee-deep in unresponsive toads, he then announces an enormous "restructuring" charge.'

[4]        For example, the smaller banks in Hong Kong formed a strategic alliance to develop new superannuation and life insurance products; Carse (2001). See also White (1998). Banks have long formed syndicates to make large loans.

[5]        Then Westpac CEO, David Morgan (2007, p 3).

[6]        Harper and Skeffington (2006, p. 38).

[7]        Since the global financial crisis wiped out considerable amounts of capital from many foreign banks, the Australian banks would now rank higher based on capital.  As noted above, they also constitute four of only eleven banks within the world's 100 largest rated AA or better.

[8]        Similarly, Harper and Skeffington (2006, pp 38-9) argue 'For example, if all the big four Australian banks merged, the new entity would be less than half the size of large US banks such as Citigroup or Bank of America.

[9]        Fels (1999, p 4).

[10]      Davis (2007, p 276).

[11]      Choice, drawing on results of customer satisfaction surveys by Roy Morgan pollsters, report that larger banks consistently have lower customer satisfaction; Submission 6, p 8.

[12]      Beal and Ralston (1998). Their own analysis of Australian bank mergers suggests a leakage of market share with mergers. It is also consistent with the results in Table 2.2.

[13]      Ms Carol Gordon, National President, Finance Sector Union, Committee Hansard, 13 March 2009, p 6.

[14]      See Beal and Ralston (1998, p 30), Focarelli and Panetta (2003), Hawkins and Mihaljek (2001), Marcus (2001, p 135) and Rhoades (1998) for further discussion.

[15]      ABA, Submission 14, p 7.

[16]      When a higher-order polynomial was used to fit the trend line, it curved up towards the end, suggesting there were diseconomies of scale once intermediaries reached the size of the major banks.

[17]      Hawkins and Mihaljek (2001, p 17).

[18]      Hawkins and Mihaljek (2001, p 34). McAllister and McManus (1993) found increasing returns to scale up to about US$500 million in assets and constant returns thereafter. Berger et al (2000) found that average costs were usually minimised somewhere between US$100 million and US$10 billion in assets. IMF (2001) found some evidence of scale economies for banks with assets between US$1 billion and US$10 billion. Similarly the Group of Ten (2001, p 253) concluded: 'most research on the existence of scale economies in retail commercial banking finds a relatively flat U-shaped average cost curve, with a minimum somewhere around US$10 billion of assets, depending on the sample, country and time period analysed.'

[19]      Wu (2008, p. 144).

[20]      Valentine and Ford (2001, p 51).

[21]      Harper (2000, p 69).

[22]      Buckley and Rayna (2001, p 205). Houston and Ryagaent (1994) reach similar conclusions.

[23]      Kent and Debelle (1999, p 18). Similar conclusions were reached by Brown and Brown (1995).

[24]      Carletti, Hartmann and Spagnolo (2002, p 41).

[25]      Davis (2007, pp 269-70).

[26]      Allen and Liu (2005, p 2).

[27]      Amel, Barnes, Panetta and Salleo (2004).

[28]      Wu (2008, p 154).

[29]      Neal (2004, p 187). An earlier empirical study of Australian banks by Walker (1995, p 114) found 'constant returns to scale for long run costs'.

[30]      Mr Ram Kangatharan, Chief Financial Officer, Bank of Queensland, Committee Hansard, 1 July, p 3.

[31]      Group of Ten (2001, p 254).

[32]      Houston, James and Ryngaest (2001).

[33]      Madura and Wiant (1994).

[34]      See, for example, Berger et al (1999).

[35]      Kent and Debelle (1999, p 33).

[36]      See House of Representatives Standing Committee on Economics (2008).

[37]      Australian Bankers' Association, Submission 14, p 6.

[38]      See paragraph 6.2 below.

[39]      ACCC, Public competition assessment, 'Westpac Banking Corporation – proposed acquisition of St George Bank Limited', 13 August 2008, paras 68 and 71, reproduced in ACCC, Submission 4.

[40]      Choice, Submission 6, p 7.

[41]      Dr Evan Jones, Submission 5, p 10.

[42]      Australian Bankers' Association, Submission 14, pp 5-6.

[43]      Australian Bankers' Association, Submission 14, p 16.

Chapter 4 - Recent Australian bank mergers

[1]        At various times ANZ and NAB had taken significant shareholdings in St George but did not proceed to making a takeover offer.

[2]        Gail Kelly, quoted in The Australian, 13 May 2008.

[3]        Dr Evan Jones, Submission  5, p 11.

[4]        Australian Financial Review, 18 December 2008.

[5]        Strictly speaking, 'points of presence offering a branch level of service', which APRA defines as offering the following services: 'accepts cash and other deposits (including business deposits) and provides change; facilitates the keeping of accounts for customer access, including the provision of account balances; opens and closes accounts; can facilitate or arrange the assessment of the credit risk of existing and potential customers; and offers additional services in the one establishment such as financial services, business banking and specialist lending.'

[6]        Australian Financial Review, 18 December 2008.

[7]        Westpac's Chairman has discussed the 'conflict of interest' arising from Ms Kelly's shares in St George in an interview on ABC's PM, 13 May 2008.

Westpac advised the Committee that Ms Kelly has honoured standard confidentiality obligations under her contract with St George; Westpac, answers to questions taken on notice, 27 August 2009. They also said that 'she was kept completely separate to all the dealings around the acquisition. In fact, there was a subcommittee of the board, as you would expect, looking at it and a separate management team looking at that acquisition, and Gail had no role to play in that'; Mr Brad Cooper, Westpac, Proof Committee Hansard, 10 August 2009, p 39. They had no comment on her St George shareholdings.

[8]        The poll of 1,000 people was conducted by McNair-Integrity in June 2008; Finance Sector Union, Submission 12, p 3.

[9]        Strictly speaking, 'points of presence offering a branch level of service', which APRA defines as offering the following services: 'accepts cash and other deposits (including business deposits) and provides change; facilitates the keeping of accounts for customer access, including the provision of account balances; opens and closes accounts; can facilitate or arrange the assessment of the credit risk of existing and potential customers; and offers additional services in the one establishment such as financial services, business banking and specialist lending.'

[10]      Mr Ian Narev, Commonwealth Bank of Australia, Committee Hansard, 12 March 2009, p 19.

[11]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 27.

[12]      Associate Professor Frank Zumbo, Committee Hansard, 10 August 2009, p 72.

[13]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 28.

[14]      Mr Ram Kangatharan, Chief Financial Officer, Bank of Queensland, Proof Committee Hansard (for Bank Funding Guarantees inquiry), 14 August 2009, p 31.

[15]      Westpac, Submission 11, p 2.

[16]      ACCC, Public competition assessment, 'Westpac Banking Corporation – proposed acquisition of St George Bank Limited', 13 August 2008, para 56, reproduced in ACCC, Submission 4.

[17]      Then shadow treasurer Malcolm Turnbull MP, interviewed 12 May 2008.

[18]      Mr Ian Narev, Commonwealth Bank of Australia, Committee Hansard, 12 March 2009, p 18.

[19]      Mr Jon Sutton, Managing Director, Bank of Western Australia, Proof Committee Hansard, 2 July 2009, p.2.

[20]      Mr Cooper, Westpac, Proof Committee Hansard, 10 August 2009, p 36.

[21]      Mr Cooper, Westpac, Proof Committee Hansard, 10 August 2009, p 38.

[22]      Mr Cooper, Westpac, Proof Committee Hansard, 10 August 2009, p 37.

[23]      Mr Ram Kangatharan, Chief Financial Officer, Bank of Queensland, Committee Hansard, 1 July 2009, p 4.

[24]      Mr Cooper, Westpac, Proof Committee Hansard, 10 August 2009, p 37.

[25]      Mr Cooper, Westpac, Proof Committee Hansard, 10 August 2009, p 37.

[26]      Abacus, Submission 18, p 2.

[27]      Mr David Foster, Group Executive, Suncorp Bank, Proof Committee Hansard, 10 August 2009, p 57.

[28]      Choice, Submission 6, p 5.

[29]      Brotherhood of St Laurence, Submission 8, pp 3-4.

[30]      Finance Sector Union, Submission 12, p 1.

[31]      Ralston and Beal (1997) report that a survey showed that 88 per cent of people shopped less in the local town after the bank branch closed. See also the discussion in Joint Committee on Corporations and Financial Services (2004, pp 35-7), who remark 'the loss of a bank branch threatens to undermine the economic life and confidence of the community'.

[32]      Berger et al (1998).

[33]      Craig and Hardee (2007).

[34]      Peek and Rosengren (1998).

[35]      Mr Jim Murphy, Executive Director, Treasury, Committee Hansard, 12 March 2009, p 30.

[36]      Mr Jim Murphy, Treasury, Committee Hansard, 12 March 2009, p 28.

[37]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 27.

[38]      Ms Carol Gordon, National President, Finance Sector Union, Proof Committee Hansard, 13 March 2009, p 10.   

[39]      Mr Ram Kangatharan, Chief Financial Officer, Bank of Queensland, Committee Hansard, 1 July, pp 4-5.

[40]      Law Council of Australia, Submission 15, p 2.

[41]      Westpac, answers to questions taken on notice, 27 August 2009.

[42]      Kent and Debelle (1999, p 31).

[43]      Carletti, Hartmann and Spagnolo (2002, p 44).

[44]      Dvais (2007, pp 270-1).

[45]      Associate Professor Frank Zumbo, Submission 19, p 1.

[46]      Associate Professor Frank Zumbo, Proof Committee Hansard, 10 August 2009, pp 69- 70.

[47]      Commonwealth Bank, Submission 2, p 2.

[48]      Choice, Submission 6, pp 5-6. A similar view has been expressed by Professor Allan Fels, ABC News, 13 May 2008.

Chapter 5 - Regulation of Australian bank mergers

[1]        When the Martin Report was tabled in 1991, the Trade Practices Act was based on 'market dominance' rather than 'substantial lessening of competition' and that committee was concerned that this was too permissive of bank mergers and may not even be sufficient to prevent the emergence of a duopoly; House of Representatives Standing Committee on Finance and Public Administration (1991, pp 118-28).

[2]        ACCC, Submission 4, p 3.

[3]        Associate Professor Frank Zumbo, Proof Committee Hansard, 10 August 2009, p 71.

[4]        Australian Competition and Consumer Commission, Submission 4a, p 3.

[5]        Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 23.

[6]        A similar approach is used overseas, for example, in Switzerland during the merger of UBS and SBC.

[7]        Dr Evan Jones, Submission 5, p 3; ACCC, Submission 4a, pp 11-12.

[8]        The approval of Westpac's takeover of Bank of Melbourne was arguably the first step away from the 'Fels policy'.

[9]        Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 25.

[10]      Finance Sector Union, Submission 12, p 8.

[11]      Hon Dr Bob Such MP, Submission 21, p 2.

[12]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 22.

[13]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 22.

[14]      ACCC, Submission 4a, p 3.

[15]      Australian Bankers' Association, Submission14, p 10; Law Council of Australia, Submission 15, pp 8, 10.

[16]      Law Council of Australia, Submission 15a, p 2.

[17]      Law Council of Australia, Submission 15, p 7.

[18]      Associate Professor Frank Zumbo, Submission 19, p 8.

[19]      Choice, Submission 6, p 12.

[20]      Associate Professor Frank Zumbo, Proof Committee Hansard, 10 August 2009, pp 73-4.

[21]      Mr Ram Kangatharan, Chief Financial Officer, Bank of Queensland, Committee Hansard, 1 July, p 6.

[22]      Australian Bankers' Association, Submission 14, p 9.

[23]      Law Council, Submission 15, p 8.

[24]      'Creeping acquisitions' refers to a series of small takeovers, each of which individually not significantly reducing competition but having that effect when taken together.

[25]      Elissa Freeman, Choice, Proof Committee Hansard, 10 August 2009, p 6.

[26]      Mr Dave Poddar, Law Council of Australia, Proof Committee Hansard, 10 August 2009, p 50; See also Law Council of Australia, Submission 15a, Attachments A and B.

[27]      Senate Standing Committee on Economics (2008).

[28]      ACCC, Public competition assessment, 'Westpac Banking Corporation – proposed acquisition of St George Bank Limited', 13 August 2008, reproduced in ACCC, Submission 4.

[29]      ACCC, Submission 4, pp 10-11.

[30]      ACCC, Public competition assessment, 'Westpac Banking Corporation – proposed acquisition of St George Bank Limited', 13 August 2008, para 63 and preceding table, reproduced in ACCC, Submission 4.

[31]      Associate Professor Frank Zumbo, Proof Committee Hansard, 10 August 2009, p 72.

[32]      Brotherhood of St Laurence, Submission 8, p 4.

[33]      Brotherhood of St Laurence, Submission 8, p 5.

[34]      Mr Leon Carter, Finance Sector Union, Committee Hansard, 13 March 2009, p 3.

[35]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 26.

[36]      Ms Elissa Freeman, Choice, Proof Committee Hansard, 10 August 2009, p 2; Choice, Submission 6, pp 10-11.

[37]      FSU, Submission 12, p 2.

[38]      Associate Professor Frank Zumbo, Proof Committee Hansard, 10 August 2009, p 72.

[39]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, pp 19-20.

[40]      Australian Competition and Consumer Commission, Submission 4a, pp 4-5.

[41]      ACCC, Submission 4a, p 9.

[42]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 21.

[43]      ACCC, Submission 4a, p 11.

[44]      Mr Dave Poddar, Law Council of Australia, Proof Committee Hansard, 10 August 2009, p 45.

[45]      Ms Ellissa Freeman, Choice, Committee Hansard, 10 August 2009, p 2.

[46]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, p 20. See also ACCC, Submission 4a, pp 9-10.

[47]      Ms Elissa Freeman, Choice, Proof Committee Hansard, 10 August 2009, pp 8-9; Mr Gerard Brody, Brotherhood of St Laurence, Proof Committee Hansard, 10 August 2009, p 22.

[48]      Choice, Submission 6, p 3.

[49]      Mr Wing, ACCC, Committee Hansard, 13 March 2009, p 29.

[50]      Mr Mark Degotardi, Abacus, Proof Committee Hansard, 10 August 2009, p 16.

[51]      Mr Gerard Brody, Brotherhood of St Laurence, Proof Committee Hansard, 10 August 2009, p 23.

[52]      Bakir (2005) notes it was the only recommendation rejected, and he was surprised as he thought 'arguably one of the government's initial aims [in setting up the inquiry] was to legitimize the repeal of the six pillars policy'.

[53]      Hon Wayne Swan MP, 'Rudd Government committed to four pillars policy', Treasurer's Press Release, no 062, 2 June 2008.

[54]      Choice, Submission 6, p 5.

[55]      Associate Professor Frank Zumbo, Proof Committee Hansard, 10 August 2009, p 70.

[56]      Macfarlane (2009), cited by Dr David Morrison, Submission 17, p 2.

[57]      Cited by Bakir (2005, p 252). More recently, former RBA Governor Ian Macfarlane (2009) said of the 'four pillars' policy, that it 'is supported by the general public as far as we can tell'.

[58]      Mr Nick Hossack, ABA, Committee Hansard, 12 March 2009, p 6.

[59]      Mr Dave Poddar, Law Council, Proof Committee Hansard. See also Law Council, Submission 15, p 11.

[60]      Then CEO of Westpac, David Morgan ( 2007, p 3).

[61]      Bakir (2005).

[62]      Treasurer's press release 08/116.

[63]      Treasurer's press release 08/116; reproduced in Westpac, Submission 11, p 4 and ABA Submission 14, pp 20-21.

[64]      Treasurer's press release 08/144, 18 December 2008, attachment A, reproduced in Commonwealth Bank, Submission 2, pp 5-6 and ABA Submission 14, p 20.

[65]      ABA, Submission 14, p 9.

[66]      ACCC, Submission 4, p 11.

[67]      Finance Sector Union, Submission 12, p 6.

[68]      Australian Bankers' Association, Submission 14, p 9.

[69]      Mr Leon Carter, National Secretary, Finance Sector Union, Committee Hansard, 13 March 2009, p 3.

[70]      Treasurer's press release 08/116; reproduced in Westpac, Submission 11, p 4.

[71]      Choice, Submission 6, p 4.

[72]      Brotherhood of St Laurence, Submission 8, p 4.

[73]      Choice, Submission 6, p 4.

[74]      Finance Sector Union, Submission 12, p 2.

[75]      Mr Tim Grimwade, ACCC, Committee Hansard, 13 March 2009, pp 21-2.

[76]      APRA, Submission 16, p 4.

[77]      Ms Elissa Freeman, Choice, Proof Committee Hansard, 10 August 2009, p 10.

[78]      Ms Roseman, Law Council of Australia, Proof Committee Hansard, 10 August 2009, p 50.

[79]      APRA, Submission 16, p 1.

[80]      APRA, Submission 16, p 1.

[81]      Dr John Laker, APRA Chair, Estimates Hansard, 4 June 2008, p 179.

Chapter 6 - Employment and 'offshoring'

[1]        Mr Nicholas Hossack, Australian Bankers' Association, Committee Hansard, 12 March 2009, p 17.

[2]        ABA, Submission 14, p 8.

[3]        Ms Linda Blackmore, Member, Finance Sector Union, Committee Hansard, 13 March 2009, p 4.

[4]        Ms Carol Gordon, National President, Finance Sector Union, Committee Hansard, 13 March 2009, p 6.

[5]        Mr Brad Cooper, Westpac, Proof Committee Hansard, 10 August 2009, p 30.

[6]        Mr Brad Cooper, Westpac, Proof Committee Hansard, 10 August 2009, pp 31-2.

[7]        Mr John Curtis, quoted in Business Spectator, 13 November 2008.

[8]        FSU Submission 12, p 5. They estimate that 8,000 jobs were lost when the Commonwealth Bank merged with the State Bank of Victoria; 1,400 when Westpac took over Bank of Melbourne and 4,500 when Commonwealth took over Colonial.

[9]        For example, The Australian, 18 December 2008.

[10]      FSU, Submission 12, Attachment 9, gives an example of bank employees being instructed not to tell customers that files are being processed in Pune (western India).

[11]      Finance Sector Union, Submission 12, p 12. Similarly, the Hon Dr Bob Such MP has suggested 'bank customers should be advised in simple terms of the extent to which services have been 'off-shored' so that they can decide whether to do business with the bank or not'; Submission 21, p 2.

[12]      Mr Leon Carter, National Secretary, Finance Sector Union, Committee Hansard, 13 March 2009, p 4; Finance Sector Union et al 2006, p 4, reproduced as Appendix 8 in FSU, Submission 12.

[13]      Finance Sector Union et al 2006, p 6, reproduced as Appendix 8 in FSU, Submission 12.

[14]      Finance Sector Union et al 2006, p 8, reproduced as Appendix 8 in FSU, Submission 12.

[15]      APRA, Submission 16, p 5.

[16]      Finance Sector Union et al 2006, p 9, reproduced as Appendix 8 in FSU, Submission 12; Brisbane Times, 24 June 2008; Finance Sector Union media release, 16 May 2007,

[17]      Mr Leon Carter, National Secretary, Finance Sector Union, Committee Hansard, 13 March 2009, p 7.

[18]      The Age, 17 December 2008.

[19]      ABA, Submission 14, p 13.

[20]      ABA, Submission 14, p 13.

[21]      Mr Nicholas Hossack, ABA, Committee Hansard, p 8.

[22]      Ms Elizabeth Harvey, Submission 1, p 1.

[23]      A bank employee, Confidential Submission 7, pp 1-2.

[24]      Mr Mark Wilkins, Submission 9, p 1.

[25]      Mr John Minuti, Submission 10, p 1.

[26]      Mr Mark Wilkins, Member, Finance Sector Union, Committee Hansard, 13 March 2009, p 4.

[27]      Ms Carmel Bourke, Member, Finance Sector Union, Committee Hansard, 13 March 2009, p 5.

[28]      Commonwealth Bank, Submission 2, p 3.

[29]      Finance Sector Union, Submission 12, p 10.

[30]      ABA, Submission 14, p 14.

[31]      OECD (2007, p 8).

[32]      Business Council of Australia (2004, p 11).

[33]      Deutsche Bank in 2004 made Sydney one of two global processing hubs for foreign exchange and UBS selected Sydney for its global IT support centre; Business Council of Australia (2004, p 11).

[34]      Business Council of Australia (2004, p 10).

[35]      ABA, Submission 14, p 15.

[36]      ABA, Submission 14, p 15.

[37]      A bank employee, Submission 13, p 1.

[38]      Mr Mark Wilkins, Submission 9, p 1.

[39]      Ms Julie Franks, Submission 3, p 1.

[40]      Finance Sector Union, Submission 12, p 12.

[41]      Mr Leon Carter, National Secretary, Finance Sector Union, Committee Hansard, 13 March 2009, p 9.

[42]      Cited in ABA, Submission 14, p 13. See also APRA, Submission 16, pp 4-5.

Labor Senators' Dissenting Report

[1]        The measures are discussed more fully in the committee's report, Government measures to address confidence concerns in the financial sector - The Financial Claims Scheme and the Guarantee Scheme for Large Deposits and Wholesale Funding.

[2]        Mr Nicholas Hossack, Proof Committee Hansard, 12 March 2009, p 4.

[3]        Mr Nicholas Hossack, Proof Committee Hansard, 12 March 2009, p 5.

[4]        Abacus, Submission 18, p 1.

[5]        Mr Tim Grimwade, Proof Committee Hansard, 13 March 2009, p 19.

[6]        Mr James Murphy, Proof Committee Hansard, 12 March 2009, p 26.

[7]        Mr James Murphy, Proof Committee Hansard, 12 March 2009, p 26.

[8]        Australian Bankers' Association, Submission 14, p 9.

[9]        Mr Leon Carter, National Secretary, Finance Sector Union, Committee Hansard, 13 March  2009, p 7.

Minority Report by Senator Xenophon

[1]        Australian Prudential Regulation Authority, Banking Statistics, October 2008

[2]        Finance Sector Union, Submission 12, pg 13

[3]        Reserve Bank of Australia, Glossary, http://www.rba.gov.au/Glossary/detail.asp?term=Four%20Pillars%20Policy

[4]        Finance Sector Union, Submission 12, pg 3

[5]        Garry Goodard and Greg Walker, Competition Analysis of Bank Mergers in Australia, Journal of Law and Financial Management, 2002

[6]        Australian Competition and Consumer Commission, Submission 4, pg 5

[7]        Australian Competition and Consumer Commission, Submission 4, pg 3

[8]        Matthew Drummond, Australian Financial Review, Samuel warns on bank mergers, 14 April 2009

[9]        Australian Competition and Consumer Commission, Submission 4, pg 9

[10]      CHOICE, Submission6, pg 5

[11]      Finance Sector Union, Submission 12, pg 5

[12]      Law Council of Australia, Proof Committee Hansard, pg 43 (10 August 2009)

[13]      Treasury’s Press Release 08/144 (18 December 2008), reproduced in Submission 14 (Australian Banker's Association), pg 20

[14]      Australian Competition and Consumer Commission, Submission 4, pg 11

[15]      Australian Competition and Consumer Commission, Submission 4, pg 6

[16]      Brotherhood of St Laurence, Submission8, pg 4

[17]      Australian Competition and Consumer Commission, Submission 4, pg 6

[18]      Australian Competition and Consumer Commission, Submission 4, pg 6

[19]      Law Council of Australia, Submission 15, pg 7       

[20]      Law Council of Australia, Submission 15, pg 7       

[21]      CHOICE, Submission 6, pg 12       

[22]      Finance Sector Union, Submission 12, pg 3       

[23]      Australian Competition and Consumer Commission, Submission 4, pg 3

[24]      Abacus-Australian Mutuals, Submission 18, pg 2

[25]      Associate Professor Frank Zumbo, Submission 19, pg 2

[26]      CHOICE, Submission 6, pg 12

[27]      CHOICE, Submission 6, pg 12

[28]      Finance Sector Union, Submission 12, Appendix 8, pg 9

[29]      Australian Banker's Association, Submission 14, pg 13

[30]      Finance Sector Union, Submission 12, pg 2