UK Finance welcomes the opportunity to respond to the CMA’s consultation on its draft revised merger efficiencies guidance. We are pleased that the draft guidance reflects recommendations that we and other stakeholders called for. 

We set out below the key positive developments we see in the draft guidance together with some areas where we think further clarifications could strengthen the draft guidance. As with our earlier response to the CMA’s call for evidence, this response was prepared with support from Linklaters.