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higher fee than it would be on its old account.
f Automated Teller Machines (ATMs)
32. Lloyds and Midland would have 25.5 per cent of all ATMs in the UK. There are three networks which are interusable, and
When a Lloyds and Midland presently belong to diferent ones. card is used, the bank or building society which owns the particular machine charges an 'interchange fee' to the bank or building society where the withdrawer's account is held. HSBC has argued that since a merged Lloyds and Midland would carry a lot of weight, whichever system the merged bank chose to join, it would be able to push up interchange fees, threatening to leave the system if the other banks and building socieies did not agree. Since Barclays is on the same network as Lloyds and National Westminster is on the same network as Midland, it is not at present clear how much strength there is in this point.
g Factoring and invoice discounting
33. Factoring involves the purchase by a factor of the trade debts owed to the business. Lloyds and Midland are both active in this market with a share in 1991 of 49.2 per cent, the next largest player being Lombard Natwest Commercial Services, a subsidiary of National Westminster, with 17 per cent. Entry barriers have not been evaluated, but Lloyds has accepted that it would have too high a share of this market, and offerd a divestment undertaking.
h Trustee services for unit trusts
34.
Trustees are appointed by unit trust managers to administer certain functions. Lloyds and MIdland would be the largest provider of these services with 25.7 per cent, followed by Chase Manhatten with 17.9 per cent and Royal Bank of Scotland with 15.5 per cent. Market entry is limited by the rule that a trustee must not be the manager of a fund.
i Travellers cheques
35. Midland, through its Thomas Cook subsidiary (which it manages on an "arm's length" basis) has 32 per cent of the UK issue of travellers cheques; Lloyds sells American Express
There are travellers cheques, but does not issue its own.
are other means of obtaining foreign currency- through Eurocheques, use of credit cards and ATMs.
Other markets
36. Both banks are present in a number of other markets, such as merchant banking, stockbroking, investment management, pensions, but it does not appear that competition concerns arise in these.
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