Michael Salinger and Sean Durkin worked with The Clearing House, an association of 24 of the largest US banks, to make a presentation to the Antitrust Division about its new Real Time Payment System. The Antitrust Division subsequently issued a business letter indicating that it had no intention of challenging the system or the rules and payments underlying it as antitrust violations.
Assessing umbrella pricing incentives
When collusive agreements involve a subset of firms in an industry, they may create the incentive and ability for firms that are not participants in the cartel...