Assessing information exchange among competitors in financial services markets

The exchange of certain types of information among competitors can trigger competition law concerns, as it may heighten the risk of market coordination or lead to the exclusion of competitors not involved in the exchange. Yet, under certain conditions information sharing may also offer benefits. This article discusses two key examples in financial services where evaluating information exchange requires a detailed understanding of the unique dynamics within those markets: the 2010 Office of Fair Trading investigation into information sharing among motor insurance companies which serves as a landmark for assessing the pro-competitive benefits of information exchange in financial products, and the 2019 Financial Conduct Authority competition investigation into information exchange among asset managers during initial public offerings. The IPO case is an important case that highlights the complexity involved in determining the boundary between beneficial and harmful information exchange.