The ACCC needs to assess the merger against a baseline e.g. What would a merger with ANZ look like, and what are realistic alternatives at present. These credible alternatives include "no change" or "merger with BEN".
This is why SUN was so vocal about wanting nothing to do with BEN, because they were hoping that ACCC wouldn't consider this as a credible baseline but ACCC looked right through that because there are internal SUN documents that show that consideration was given to a BEN merger.
Ann: AXX: ACCC deny authorisation for ANZ to acquire Suncorp Bank, page-6
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