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likely to be administratively quite inconvenient for the customer, and in recessionary times a business customer who changes banks may find it difficult get a new loan. Midland also make broadly similar observations in regard to the medium-business sector (turnover £1m.-250m.p.a) although they suggest this sector may be more competitive because of customers' increased account size and administrative capacity- so that, for example, they can operate accounts with several banks.
50. Midland also express concern about factoring and "merchant aquisitions", on similar lines to HSBC. In addition, they
suggest there are grounds for concern in the area of non- mortgage lending to personal customers. They point out that on official statistics, in 1991 80 per cent of outstanding consumer credit was from banks, predominantly overdrafts, ordinary bank loans, and finance house loans (many of which are subsidiaries of banks). They suggest that building societies are not a major competitor in this sector, especially for the typical unsecured loan, which is for about £3,000 (building sopciety loans tend to be much larger). 4 per cent of building society accounts had overdraft facilities, and few societies show significant amounts of unsecured loans on their books. Lloyds/Midland would have around 30 per cent of this market, they sugggest, and the only effctive competitors are the other branch banks.
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51. Midland do not regard divestment undertakings as a satisfactory remedy for the detriments they perceive, advancing broadly similar arguments to those of HSBC, adding that they find it difficult to see how the DGFT could fuflfil his obligation under s.75, because of the impossibility of predicting with any certainty what the effect on competition of a particular divestment package would be. They also reject all the arguments for a reference of the HSBC bid, again using similar arguments to HSBC; they add that an HSBC-Midland merger, far from decreasing competition, would be likely to increase it, because it would further strengthen Midland's capital position and its presence overseas.
VIEWS OF THIRD PARTIES
52. The Office has sought views from a range of bodies thought likely to have an interest in the matter. In addition, the extensive press coverage of the matter has prompted some unsolicited views from third parties, either direct to the Office or via DTI or other Government Departments. Accordingly it is not thought likely that significant third party interests who wish to do so have yet to comment. Comments have been received to date from the following organisations: the Consumers Association (CA); the National Consumer Council (NCC); the Federation of Small Businesses (FSB); the Forum of Private Business (FPB); the Union of Independent Companies (UIC); the Wallcovering, Fabric and Decor Retailers Association (WFDRA); the British Retail Consortium (BRC); the Retail Motor Industry Federation (RMIF);
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