U.S. v. Visa and U.S. v. Visa and MasterCardMasterCardEric Emch, OECDEric Emch, OECD

eric.emch@oecd.orgeric.emch@oecd.org

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OutlineOutline

I.I. BackgroundBackgroundII.II. The allegations & theory of the The allegations & theory of the

casecaseA.A. Relevant marketsRelevant marketsB.B. DualityDualityC.C. Exclusionary rulesExclusionary rules

III.III. The court’s decisionThe court’s decisionIV.IV. The Visa/MC case and joint venture The Visa/MC case and joint venture

policy generallypolicy generally

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Visa/MC and Joint VenturesVisa/MC and Joint Ventures

• Some issues to consider while Some issues to consider while listening to this presentation:listening to this presentation:– Would Visa and MasterCard have been treated Would Visa and MasterCard have been treated

differently had they each been a unified firm differently had they each been a unified firm rather than a joint venture?rather than a joint venture?

– Should they be treated differently? Why or Should they be treated differently? Why or why not?why not?

– What are the economic and legal implications What are the economic and legal implications of disparate treatment of ongoing joint of disparate treatment of ongoing joint ventures compared to single firms?ventures compared to single firms?

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Background: HistoryBackground: History• In In 19501950, Diner’s club produced the first "general purpose“ , Diner’s club produced the first "general purpose“

charge card, which required the entire bill to be paid with each charge card, which required the entire bill to be paid with each statement it was followed by American Express and Carte statement it was followed by American Express and Carte Blanche Blanche

• 1958: 1958: Bank of America launches the BankAmericard in Fresno, Bank of America launches the BankAmericard in Fresno, Calif., with an innovative “revolving credit” feature. Calif., with an innovative “revolving credit” feature.

• 19661966: MasterCard founded as Interbank Card Association: MasterCard founded as Interbank Card Association• 19701970: Visa is incorporated in the state of Delaware in 1970 as : Visa is incorporated in the state of Delaware in 1970 as

National BankAmericard Inc. (NBI). Changes its name to Visa National BankAmericard Inc. (NBI). Changes its name to Visa in 1976in 1976

• Since Since 19751975, virtually all significant card-issuing banks in , virtually all significant card-issuing banks in United States have become owners of both Visa and United States have become owners of both Visa and MasterCard, though this may change with their IPOs.MasterCard, though this may change with their IPOs.

• Associations experienced rapid growth in 1980s, 90s, and 00s, Associations experienced rapid growth in 1980s, 90s, and 00s, through combined efforts of issuing banks and acquiring banks.through combined efforts of issuing banks and acquiring banks.

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Structure of Visa in 1999Structure of Visa in 1999

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VisaNetwork Services

Member Issuing Banks Member Acquiring Banks

Merchants

Consumers

Visa Joint Venture

“Interchange”

ALLEGATIONS & THEORY OF ALLEGATIONS & THEORY OF THE CASETHE CASE

United States v. Visa and MasterCardUnited States v. Visa and MasterCard

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The ComplaintThe Complaint• Count 1: “Dual Governance”Count 1: “Dual Governance”

– Governors of each association that have significant revenue Governors of each association that have significant revenue stream from other association have reduced incentive to stream from other association have reduced incentive to sponsor competitive initiativessponsor competitive initiatives

• Count 2: Associations’ Exclusionary RulesCount 2: Associations’ Exclusionary Rules– Association rules prohibiting members from issuing cards on Association rules prohibiting members from issuing cards on

a “competitive network” thwart network-level competition by a “competitive network” thwart network-level competition by denying scale to Discover and American Expressdenying scale to Discover and American Express

• Each count had to do with improving network Each count had to do with improving network competition:competition:– Count 1: Competition between the associationsCount 1: Competition between the associations– Count 2: Competition against other networks such as Count 2: Competition against other networks such as

Amex/Discover Amex/Discover

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Relevant MarketsRelevant Markets

• General purpose credit and charge General purpose credit and charge cardscards– Issuer (bank) level servicesIssuer (bank) level services– Not included in the market: proprietary cards, Not included in the market: proprietary cards,

debit cards, cashdebit cards, cash

• General purpose credit and charge General purpose credit and charge card network servicescard network services– Issuers earn margins of 26%, network fees are Issuers earn margins of 26%, network fees are

<2% of issuing costs. US argued that therefore <2% of issuing costs. US argued that therefore there was room for a SSNIP from network there was room for a SSNIP from network monopolist.monopolist.

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General Purpose Card MarketGeneral Purpose Card Market

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VisaNetwork Services

Member Issuing Banks Member Acquiring Banks

Merchants

Consumers

Visa Joint Venture

Visa Joint Venture

Network Services MarketNetwork Services Market

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VisaNetwork Services

Member Issuing Banks Member Acquiring Banks

Merchants

Consumers

Count 1: Dual GovernanceCount 1: Dual Governance

• U.S. attacked “dual governance” of the U.S. attacked “dual governance” of the associationsassociations– Governance = decision-making authorityGovernance = decision-making authority– Includes board of directors and influential Includes board of directors and influential

advisory committeesadvisory committees– Decision-making banks in each association Decision-making banks in each association

typically had substantial portfolios of cards typically had substantial portfolios of cards issues on the network of the other association.issues on the network of the other association.

• Did not attack dual issuance directlyDid not attack dual issuance directly– Theory was that if governing banks has Theory was that if governing banks has

undivided loyalty, divided loyalty of undivided loyalty, divided loyalty of membership was not as harmful to competition membership was not as harmful to competition

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Overlapping Interests of Overlapping Interests of AssociationsAssociations

• From complaintFrom complaint: “The banks that govern Visa earn : “The banks that govern Visa earn substantial profits from issuing MasterCard cards. For substantial profits from issuing MasterCard cards. For example, as of year-end 1997, Visa U.S.A.'s Board of example, as of year-end 1997, Visa U.S.A.'s Board of Directors included representatives of First Union Directors included representatives of First Union Corporation and Associates First Capital Corporation, both Corporation and Associates First Capital Corporation, both of which had issued nearly 40% of their general purpose of which had issued nearly 40% of their general purpose cards on the MasterCard network.”cards on the MasterCard network.”

• ““The banks that govern MasterCard earn an even greater The banks that govern MasterCard earn an even greater percentage of their profits from issuing Visa cards… The percentage of their profits from issuing Visa cards… The most pronounced examples among MasterCard's 1997 most pronounced examples among MasterCard's 1997 board members were Providian Bancorp Inc. and Capital board members were Providian Bancorp Inc. and Capital One Bank, which had issued more than 95% and more than One Bank, which had issued more than 95% and more than 66% of their cards on the Visa network, respectively.”66% of their cards on the Visa network, respectively.”

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Alleged Effects of Dual Alleged Effects of Dual Governance Governance

• From complaint:From complaint:

““Because of these significant overlapping Because of these significant overlapping financial interests, the banks that govern each financial interests, the banks that govern each association have rejected investments in, and association have rejected investments in, and implementation of, competitive initiatives that implementation of, competitive initiatives that might lead consumers to switch from one might lead consumers to switch from one association's brand of card to the other's. From association's brand of card to the other's. From the banks' perspective, these innovations would the banks' perspective, these innovations would merely shift their profits from cards issued on merely shift their profits from cards issued on one of their networks to cards issued on the one of their networks to cards issued on the other.”other.”

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Associations Themselves Had Associations Themselves Had Noted Negative EffectsNoted Negative Effects

• In 1992, Visa International's Executive Vice President and General Counsel testified (in a different case) that "it is very difficult for us to take a step, an aggressive step that hurts MasterCard because the same banks who sit there on the board, who are in Visa are also in MasterCard." In response to the question whether "duality has led to a decrease in intersystem competition between Visa and MasterCard," he replied, "Absolutely,"

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Alleged Effects of Dual Alleged Effects of Dual GovernanceGovernance

• Restraint in share-shifting competitive Restraint in share-shifting competitive initiatives by each association directed initiatives by each association directed against the other, it’s largest competitoragainst the other, it’s largest competitor

• Examples cited by government of how Examples cited by government of how dual governance restrained competition:dual governance restrained competition:– Smart CardsSmart Cards– Internet EncryptionInternet Encryption– Premium CardsPremium Cards– AdvertisingAdvertising

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Effects on AdvertisingEffects on Advertising

• 19921992– Consultant: MC must name VisaConsultant: MC must name Visa– Member reaction vetoedMember reaction vetoed

• 19961996– In Canada (non-dual), MC names VisaIn Canada (non-dual), MC names Visa

• 19971997– ““Can’t … discuss or refer to … Visa”Can’t … discuss or refer to … Visa”

{note to self: get full quote, reference}{note to self: get full quote, reference}

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Government’s Proposed ReliefGovernment’s Proposed Relief

• ReliefRelief– Require dedication of board members (100% Require dedication of board members (100%

going forward, 80% overall).going forward, 80% overall).

• Why Not Seek Complete Exclusivity?Why Not Seek Complete Exclusivity?– Dual issuance pro-competitiveDual issuance pro-competitive– Benefits from banks offering a variety of cardsBenefits from banks offering a variety of cards– Facilitates network competition, especially in Facilitates network competition, especially in

harmony with count 2.harmony with count 2.

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Increasing Dedication Since Increasing Dedication Since Complaint FiledComplaint Filed

• Visa by-law requiring Board members to Visa by-law requiring Board members to maintain a 70% skewmaintain a 70% skew

• Prevalence of dedication agreements of Prevalence of dedication agreements of board members requiring skewboard members requiring skew

• This was very relevant to the court’s This was very relevant to the court’s ultimate decision on the duality countultimate decision on the duality count

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Count 2: Exclusionary RulesCount 2: Exclusionary Rules

• A brief history of the exclusionary rulesA brief history of the exclusionary rules– Visa’s rule 210(e), passed in 1991, provides that “the Visa’s rule 210(e), passed in 1991, provides that “the

membership of any member shall automatically terminate in membership of any member shall automatically terminate in the event it … issues, directly or indirectly, Discover Cards or the event it … issues, directly or indirectly, Discover Cards or American Express Cards, or any other card deemed American Express Cards, or any other card deemed competitive by the Board of Directors.”competitive by the Board of Directors.”

– American Express begins partnering with foreign banks American Express begins partnering with foreign banks attempts to partner with American banks.attempts to partner with American banks.

– Visa International considers global rule, but not adopted after Visa International considers global rule, but not adopted after doubts about the legality of such a rule expressed by DG-doubts about the legality of such a rule expressed by DG-COMP.COMP.

– American Express begins encouraging major MasterCard American Express begins encouraging major MasterCard banks to issue AMEX cards, holding discussions with some. banks to issue AMEX cards, holding discussions with some. MasterCard adopts its Competitive Programs Policy (CPP), MasterCard adopts its Competitive Programs Policy (CPP), similar to Visa’s rule 210(e). Six board members voted against.similar to Visa’s rule 210(e). Six board members voted against.

– Discussions between Amex and MC member banks cease in Discussions between Amex and MC member banks cease in wake of CPP/210ewake of CPP/210e

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Exclusionary RulesExclusionary Rules

• Government alleges rules are Government alleges rules are anticompetitive because:anticompetitive because:– Inhibit network competition by denying scale Inhibit network competition by denying scale

to competitors (Amex, Discover)to competitors (Amex, Discover)– Deny consumers benefits of new combinations Deny consumers benefits of new combinations

of network services and issuer attributesof network services and issuer attributes– Pro-competitive justifications not validPro-competitive justifications not valid

• Not required for association “cohesion”Not required for association “cohesion”• No valid free-riding concernsNo valid free-riding concerns

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Evidence on Evidence on Exclusionary RulesExclusionary Rules

• Several banks testified that they would have Several banks testified that they would have partnered with American Express but for the partnered with American Express but for the rulesrules

• Evidence that scale of American Express and Evidence that scale of American Express and Discover inhibited merchant acceptance which Discover inhibited merchant acceptance which inhibited card issuanceinhibited card issuance

• Experience overseas showed that associations Experience overseas showed that associations didn’t unravel simply because some partnered didn’t unravel simply because some partnered with Amexwith Amex

• DOJ alleged partnerships with banks would DOJ alleged partnerships with banks would create unique new products: banks not simply create unique new products: banks not simply distributorsdistributors

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Government’s Proposed ReliefGovernment’s Proposed Relief

• Abolish 210e/CPP and prohibit similar Abolish 210e/CPP and prohibit similar bylaws in the future applying to debit and bylaws in the future applying to debit and creditcredit

• Allow issuers to rescind dedication Allow issuers to rescind dedication agreements with Visa/MC signed before agreements with Visa/MC signed before the final judgement went into effectthe final judgement went into effect

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COURT DECISIONCOURT DECISIONU.S. v. Visa and MasterCardU.S. v. Visa and MasterCard

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Decision on DualityDecision on Duality

• The court concludes that with the exception The court concludes that with the exception of the associations’ failure to name each of the associations’ failure to name each other in advertising…The government’s other in advertising…The government’s examples fail to prove dual governance has examples fail to prove dual governance has significantly diminished competitionsignificantly diminished competition– Defendants’ admissions relate to dual issuance, or are Defendants’ admissions relate to dual issuance, or are

dated or too generaldated or too general– Active competition between Visa and MasterCardActive competition between Visa and MasterCard– Lots of innovation in the industryLots of innovation in the industry– Influence of major dual issuers may be cause of blunted Influence of major dual issuers may be cause of blunted

innovation competitioninnovation competition– Duality may be moot with move towards dedication Duality may be moot with move towards dedication

agreementsagreements

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Decision on Decision on Exclusionary RulesExclusionary Rules

• Associations’ exclusionary rules are Associations’ exclusionary rules are anticompetitiveanticompetitive– Inhibit network competition by denying Inhibit network competition by denying

scale to competitors (Amex, Discover)scale to competitors (Amex, Discover)– Deny consumers benefits of new Deny consumers benefits of new

combinations of network services and combinations of network services and issuer attributesissuer attributes

– Pro-competitive justifications not validPro-competitive justifications not valid• Not required for association “cohesion”Not required for association “cohesion”• No valid free-riding concernsNo valid free-riding concerns

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Decision on Decision on Exclusionary Rules (2)Exclusionary Rules (2)

• Exclusionary rules effectively prevented banks Exclusionary rules effectively prevented banks from issuing American Express or Discover cardsfrom issuing American Express or Discover cards

• Limited access to banks reduced the “competitive Limited access to banks reduced the “competitive vitality” of American Express and Discover as vitality” of American Express and Discover as network competitors.network competitors.

• ““Network services output is necessarily decreased and network Network services output is necessarily decreased and network price competition restrained by the exclusionary rules because price competition restrained by the exclusionary rules because banks cannot access the American Express and Discover networks; banks cannot access the American Express and Discover networks; conversely American Express and Discover cannot access the conversely American Express and Discover cannot access the issuing competencies and segmented marketing expertise of the issuing competencies and segmented marketing expertise of the banks, nor their more profitable relationship customers with banks, nor their more profitable relationship customers with checking accounts…”checking accounts…”

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Relief on Exclusionary RulesRelief on Exclusionary Rules

• Visa and MC shall repeal 210e/CPP as applied to Visa and MC shall repeal 210e/CPP as applied to issuersissuers

• ““Each Defendant is enjoined from enacting, Each Defendant is enjoined from enacting, maintaining, or enforcing any by-law, rule, policy, or maintaining, or enforcing any by-law, rule, policy, or practice that prohibits its issuers from issuing general practice that prohibits its issuers from issuing general purpose or debit cards in the United States on any purpose or debit cards in the United States on any other general purpose card network.other general purpose card network.

• Dedication agreements previously signed can be Dedication agreements previously signed can be terminated without penalty up to two years after terminated without penalty up to two years after judgement goes into effect if a bank wants to partner judgement goes into effect if a bank wants to partner with American Express or Discoverwith American Express or Discover

• Limitations: Judgement does not prohibit individually-Limitations: Judgement does not prohibit individually-negotiated agreement for exclusivitynegotiated agreement for exclusivity

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MC/VISA CASE AND JOINT MC/VISA CASE AND JOINT VENTURE POLICYVENTURE POLICY

U.S. v. Visa and MasterCardU.S. v. Visa and MasterCard

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Case PostscriptCase Postscript

• Parties were granted a stay on the decision, Parties were granted a stay on the decision, appealed and lost at the Court of Appeals. Final appealed and lost at the Court of Appeals. Final appeal for the Supreme Court to hear case but appeal for the Supreme Court to hear case but Supreme Court refused.Supreme Court refused.– Final judgement went into effect in 2004Final judgement went into effect in 2004– American Express has since started issuing cards American Express has since started issuing cards

partnering with Citibank and Bank of America, among partnering with Citibank and Bank of America, among othersothers

– Meanwhile, there has been a proliferation of lawsuits Meanwhile, there has been a proliferation of lawsuits against the associations, includingagainst the associations, including• Merchant class action against existence of interchangeMerchant class action against existence of interchange• ““Wal-Mart” class action against tie of credit and debit Wal-Mart” class action against tie of credit and debit

(settled)(settled)• American Express and Discover private suits for American Express and Discover private suits for

anticompetitive behaviour (Amex settled)anticompetitive behaviour (Amex settled)

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Visa and MC RestructureVisa and MC Restructure

• Shortly after initial trial, MasterCard announces Shortly after initial trial, MasterCard announces a plan to change its structure from a not-for-a plan to change its structure from a not-for-profit association to a for-profit, privately held profit association to a for-profit, privately held companycompany– Multi-stage process culminating in IPO in mid-2006Multi-stage process culminating in IPO in mid-2006– Banks still hold majority of sharesBanks still hold majority of shares

• In 2006, Visa announces similar plansIn 2006, Visa announces similar plans– IPO scheduled for early 2008IPO scheduled for early 2008

• One oft-cited reason is to lessen liability from One oft-cited reason is to lessen liability from competition lawcompetition law

• Is this a good thing?Is this a good thing?

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The DOJ Legal Line of AttackThe DOJ Legal Line of Attack

• Alleged violations of Section 1 of Sherman Act (like Alleged violations of Section 1 of Sherman Act (like EU Art. 82), having to do with conspiracies EU Art. 82), having to do with conspiracies between associations and among member banks in between associations and among member banks in associations.associations.

• Defendants tried to frame the case, legally, as a Defendants tried to frame the case, legally, as a Section 2 exclusive dealing case – higher burden of Section 2 exclusive dealing case – higher burden of proof for plaintiff.proof for plaintiff.

• Effectively, then, part of DOJ case depended on JV Effectively, then, part of DOJ case depended on JV structure of associations, and would not have been structure of associations, and would not have been argued the same way had they been single firmsargued the same way had they been single firms

• What can a single firm do that a joint venture can’t, What can a single firm do that a joint venture can’t, and why?and why?

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Defense ComplaintsDefense Complaints

• Defense allegesDefense alleges: By pleading this as a Section 1 case, DOJ : By pleading this as a Section 1 case, DOJ penalizes the joint venture form, which has served the industry penalizes the joint venture form, which has served the industry well.well.

• Should allow a joint venture the same rights as a unified firm, Should allow a joint venture the same rights as a unified firm, including the right to refuse to deal under most circumstances. including the right to refuse to deal under most circumstances. After all, Amex can choose to partner with whomever it wants.After all, Amex can choose to partner with whomever it wants.

• DOJ counterDOJ counter: competitors in an industry are not allowed to use : competitors in an industry are not allowed to use a joint venture as cover for anticompetitive horizontal a joint venture as cover for anticompetitive horizontal agreements. They are not allowed to get together and effectively agreements. They are not allowed to get together and effectively vote on how to compete with one another, even under cover of a vote on how to compete with one another, even under cover of a JV.JV.

• Competition law would not allow a full merger or even partial Competition law would not allow a full merger or even partial merger of major issuing banks, so should not allow joint venture merger of major issuing banks, so should not allow joint venture of banks to necessarily have all of the freedoms of a merged firm.of banks to necessarily have all of the freedoms of a merged firm.

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Texaco Inc. v. Dagher et. al. Texaco Inc. v. Dagher et. al. (2006)(2006)

• U.S. Supreme Court weighed recently in on how antitrust U.S. Supreme Court weighed recently in on how antitrust should treat joint ventures, and sets what seem to be should treat joint ventures, and sets what seem to be reasonable bounds, in reasonable bounds, in Texaco v. Dagher Texaco v. Dagher casecase..

• Texaco and Shell Oil collaborated in a joint venture, Texaco and Shell Oil collaborated in a joint venture, Equilon Enterprises, to refine and sell gasoline under Equilon Enterprises, to refine and sell gasoline under both brand names. Joint venture was approved by FTC.both brand names. Joint venture was approved by FTC.

• Equilon set a single price for both brands. Service Equilon set a single price for both brands. Service station owners sued, alleging illegal price fixing as a station owners sued, alleging illegal price fixing as a per per se se violation of Section 1. District Courts rules for violation of Section 1. District Courts rules for defendants but overturned by appellate court.defendants but overturned by appellate court.

• Supreme court overturned again, finding that it is not Supreme court overturned again, finding that it is not per per se se illegal for a lawful, economically integrated joint illegal for a lawful, economically integrated joint venture to set the prices at which the JV sells its productsventure to set the prices at which the JV sells its products

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Ancillary Restraints DoctrineAncillary Restraints Doctrine

• Under the ancillary restraints doctrine, courts must determine whether a restriction that is part of a joint venture or association is a naked restraint on trade, or one that is ancillary to the legitimate and competitive purposes of the association. The former can be condemned as anticompetitive.

• Supreme Court “That doctrine governs the validity of restrictions imposed by a legitimate business collaboration, such as a business association or joint venture, on nonventure activities.” (emphasis added)

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““Core” vs. “Non-core” JV Core” vs. “Non-core” JV ActivitiesActivities

Supreme Court decision seems to divide JV Supreme Court decision seems to divide JV activities into two categories: core and non-coreactivities into two categories: core and non-core•““Core activities” : treat same as single firmCore activities” : treat same as single firm•““Non-core activities”: Ancillary restraints Non-core activities”: Ancillary restraints doctrine applies. May weight potential harms doctrine applies. May weight potential harms against pro-competitive justificationsagainst pro-competitive justifications•Seems to allow two routes for challenging joint Seems to allow two routes for challenging joint venture’s activitiesventure’s activities

– Challenge a non-core activity that is not ancillary Challenge a non-core activity that is not ancillary – Challenge the entire JV as anticompetitiveChallenge the entire JV as anticompetitive

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Final ThoughtsFinal Thoughts

• Though Though DagherDagher case was decided after DOJ case in case was decided after DOJ case in Visa/MC, the DOJ case seems to fit within this Visa/MC, the DOJ case seems to fit within this frameworkframework– Alleges exclusionary rules were not core activities and had Alleges exclusionary rules were not core activities and had

no pro-competitive justificationno pro-competitive justification

• This seems to provide an answer to the question of This seems to provide an answer to the question of when are JV’s treated like single firms: legitimate when are JV’s treated like single firms: legitimate JV’s are allowed to perform “core activities” like JV’s are allowed to perform “core activities” like single firmssingle firms

• At the same time, other activities of JV are not At the same time, other activities of JV are not protected in the same way, which prevents a JV from protected in the same way, which prevents a JV from becoming a shelter for anticompetitive agreements.becoming a shelter for anticompetitive agreements.

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Some ReferencesSome References

• Complaint, Complaint, U.S. v. Visa USA, Visa International, and MasterCard U.S. v. Visa USA, Visa International, and MasterCard Int’l. Int’l. Available at http://www.usdoj.gov/atr/cases/f1900/1973.htmAvailable at http://www.usdoj.gov/atr/cases/f1900/1973.htm

• United States v. Visa U.S.A., Inc., et. al. 98 Civ. 7076 United States v. Visa U.S.A., Inc., et. al. 98 Civ. 7076 (S.D.N.Y. (S.D.N.Y. October 9, 2001)) October 9, 2001)) Available at Available at http://www.usdoj.gov/atr/cases/f9800/9857.htmhttp://www.usdoj.gov/atr/cases/f9800/9857.htm

• Texaco Inc. v. Dagher et alTexaco Inc. v. Dagher et al., 547 U.S. (2006)., 547 U.S. (2006)• ““Antitrust Guidelines for Collaborations among Competitors,” Antitrust Guidelines for Collaborations among Competitors,”

issued by the Federal Trade Commission and the U.S. Department issued by the Federal Trade Commission and the U.S. Department of Justice, April 2000. Available at of Justice, April 2000. Available at http://www.ftc.gov/os/2000/04/ftcdojguidelines.pdfhttp://www.ftc.gov/os/2000/04/ftcdojguidelines.pdf

• ““Competition and Efficient Uses of Payment Cards,”” proceedings Competition and Efficient Uses of Payment Cards,”” proceedings of June 2006 OECD competition committee roundtable. OECD of June 2006 OECD competition committee roundtable. OECD Document Document DAF/COMP(2006)32 . Available at:DAF/COMP(2006)32 . Available at: http://www.oecd.org/dataoecd/0/30/39531653.pdfhttp://www.oecd.org/dataoecd/0/30/39531653.pdf

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