The Competition Authority has concluded its long running study of the banking sector, almost three years to the day since its inception. Its final report, published yesterday, contains 25 detailed recommendations which it describes as a roadmap to more competition in the banking industry.
No single recommendation stands out as particularly radical or controversial. Indeed many of the proposals have been anticipated by the industry, which has moved to head them off, particularly in the area of account switching.
It would be tempting, on this basis, to dismiss the report as something of a damp squib given that it was three years in gestation and cost thousands of euro to produce, much of it spent on expensive consultants.
However, wholesale structural reform of the banking sector was never on the authority's agenda. Instead it has sought to put customers in a position where they can move easily from one bank to the other. This in theory will force the banks to compete for their business, driving down prices and improving service in the process. Each recommendation, if implemented, will chip away at barriers that prevent customers moving. Whether the cumulative impact of all the changes has the desired effect remains to be seen.
The approach is closely modelled on the Government's insurance reform programme, which is credited with achieving significant reductions in the cost of insurance. As was the case with insurance reform, the agency, minister or body responsible for implementing each recommendation has been identified by the authority and a timetable for action set out.
But there were other reasons behind the success of the insurance action plan, including the existence of the political will to implement it, primarily on the part of Tánaiste and then industry minister Mary Harney. The insurance industry was also quick to realise that its interests lay in rowing in behind the reforms.
If the recommendations of the Competition Authority are to pay a similar dividend then they too must have a champion in Government and the task will fall to Minister for Finance Brian Cowen. He will have to convince not only his colleagues, but the banks themselves, to embrace the changes.
He will not lack an incentive to buckle down to the role. An election looms and the Government appears conscious - in a way that it has not been heretofore - of a deep well of dissatisfaction among consumers which could yet find its expression in the ballot box.