CFA called on the  Federal Reserve to pause the review of the proposed Morgan Stanley-E*Trade merger during the COVID-19 pandemic. When the review begins in the new “normal” of the post-pandemic world, all agencies with oversight over mergers must apply rigorous analysis to the numerous concerns around vertical integration and heed calls to significantly ramp up antitrust scrutiny.

The comments argue that lax antitrust enforcement throughout the last few decades has led to growing concerns about increasing abuse of market power resulting not only from horizontal concentration (mergers of head-to-head competitors) but also from vertical integration of complementary services. The Morgan Stanley-E*Trade merger would be a particularly egregious example of the latter.