Case details

Print
Anticompetitive practices
Case reference
PRC/2015/9
Entities involved
  • ASFAC - Associação de Instituições de Crédito Especializado
  • Banco Santander Consumer Portugal, S.A.
  • Banco Santander Totta, SA
  • Caixa Económica Montepio Geral
  • Volkswagen Bank GmBH –Sucursal em Portugal
Natural persons involved
No
Sector
  • Banking, Financial and Insurance activities
Activity (NACE)
  • K64 - Financial service activities, except insurance and pension funding
Investigated practice
  • Decision of association of undertakings
Legal provisions
  • European-TFEU-Article 101
  • National-Law 19/2012-Article 9
Case origin
Ex-officio
Dawn raids
Yes
Cooperation with sector regulators
  • BdP - Bank of Portugal
Status
Closed
AdC’s decision
Commitment decision
Settlement
Sanction imposed
Summary of the case

On 23/04/015 the Competition Authority (AdC) opened an infringement procedure against the Association of Specialised Credit Institutions (ASFAC) and its member companies for suspected infringements of competition rules.
The investigation revealed the existence of a system of exchange of sensitive strategic information on products and services in the markets of leasing, ALD, classic credit, revolving credit (revolving) and supplier credit (stock), directly promoted by ASFAC, involving associated companies.

Taking into account the content, the relevance, the level of disaggregation and the target of the information exchanged, the AdC considered that the information exchange system institutionalized by ASFAC could be capable of enhancing a restrictive effect on competition, through a possible reduction of uncertainty in the market, allowing the participants to act in possession of sensitive information of their competitors, as well as the frequent monitoring of their strategic behaviour.

In order to respond to the competition concerns expressed by AdC, ASFAC presented a set of commitments, committing to introduce changes in its information disclosure system, by increasing the age of the individualised data it makes available to its associates, as well as introducing changes to the rules of reciprocity in the collection and disclosure of information.
After a public consultation regarding the content of the commitments submitted, the AdC concluded that it was in a position to accept the commitments presented, making their compliance mandatory for ASFAC, as a way to ensure the application of the rules for the promotion and defence of competition in the market sectors represented by ASFAC.

In October 2017, the AdC Board determined the closure of case PRC/2015/9 upon the acceptance of commitments of the imposition of conditions, pursuant to Article 24(3)(d) of Law No. 19/2012 of 8 May.

Timeline
Judicial phase chronology - Interlocutory appeals
Click here to see your activities