I don't think I can say definitively, or conclude definitively, that this was the case. We were investigating their conduct and, as said in the letter to your colleagues, we appreciated their flagging the issue. We had a very good discussion about the issue here at committee. We were already investigating before the committee hearing, and we continued. Then, when they announced that they were going to change the practice in question.... The volume-based tiered pricing of wholesale Interac was the main concern we were looking at, and when they indicated that they were going to change to a flat-fee system that didn't have what appeared like a disparity of fairness for smaller institutions to be able to compete, we made the decision that we weren't going to continue the investigation and that we would monitor their commitment to change to a flat fee.
I understand that some people may not understand how law enforcement sometimes has to prioritize investigations, but that's what we have to do at the bureau all the time. We have to make decisions about which investigations to prioritize. In this situation, we felt that what they were moving towards addressed the key part of the problem, and we were going to monitor their implementation of that. That's where we're at. I can't say, though, that we definitively concluded that there was anti-competitive conduct.
