Joint Letter: Promote Tradition of Separating Banking and Commerce Regarding Dominant Platforms


The Americans for Financial Reform Education Fund (AFR Education Fund) and Demand Progress Education Fund (DPEF) appreciate the opportunity to comment on antitrust policy and the digital marketplace. AFR Education Fund is a coalition of more than 200 national, state, and local groups who have come together to advocate for reform of the financial industry. Members of AFR Education Fund include consumer, civil rights, investor, retiree, community, labor, faith based, and business groups. DPEF is a fiscally-sponsored project of New Venture Fund, a 501(c)3 organization. DPEF and our more than two million affiliated activists seek to protect the democratic character of the internet — and wield it to render government accountable and contest concentrated corporate power.

We applaud the Committee on its investigation into the relationship between dominant platforms and online competition. Both DPEF and AFR Education Fund support the partition of banking and commerce as a key regulatory principle, as it reduces systemic risks, strengthens consumer protections, and prevents undue concentrations of corporate power. Along with our allies, DPEF specifically supports the break-up of “Big Tech” monopolies, such as Amazon, and Facebook, as well as reforms that would prevent other companies from amassing similar power.

Historically, commercial firms that also engage in financial services tend to use such enterprises to fund risky business activities, heightening the moral hazard of bailout, while simultaneously failing to deal fairly with customers or competitors. Recently, sophisticated commercial firms have once again attempted to breach this separation, whether through mergers and acquisitions, applications for special banking charters, or general arbitrage.

We are especially concerned about the activities of dominant technology platforms, which already use their “platform privilege” not only to analyze users, but to acquire and appropriate from competitors that rely on the infrastructure they supply. For example, European regulators have fined Google for using its monopoly over desktop and mobile search to prioritize its own products. Amazon uses its own digital marketplace to bury competitors in terms of search, product review, advertising, and marketing.

The full letter can be found here.