with less than $ 250 million in total assets. up until 2009, the number of bank branches increased, despite the decline in the number of bank charters. however, since the 2009 financial crisis, the number of - 4branches has declined each year. this decline was particularly pronounced during the pandemic when, between 2020 and 2021, the number of bank branches declined by almost 4 percent as more than 3, 200 branches were closed. before discussing how declines in bank charters and bank branches influence how we think about the competitive impact of mergers in certain markets, it should be noted that how we measure competition today largely springs from a 1963 supreme court decision where the court held that the relevant product market for the purposes of analyzing a bank merger is the “ cluster of products... and services ” that constitute “ commercial banking ” in each banking market. 2 this means that to evaluate banking competition, we essentially require two key inputs : 1. the geographical definition of the banking market, and 2. an understanding of the bank products and services that are provided to most households and small businesses by the banks in those markets. the geographic definition of banking markets is a federal reserve responsibility, and the fed has currently defined more than 1, 400 banking markets nationwide. this geographic definition requires constant analysis and regular updating. one only needs to think of how the growth of the suburbs has increased the distances residents are willing to travel for their jobs and other important services, including banking services, to appreciate how banking markets have changed and will continue to change. as communities change, so do their banking markets. the second part of this evaluation is more daunting because there is currently no way to comprehensively measure the full “ cluster ” of commercial banking products and united states v. philadelphia national bank, 374 u. s. 321, 356 ( 1963 ). - 5services in a given market. this challenge is compounded by the fact that the products and services banks offer also frequently change to meet evolving customer and business demand. historically, we ’ ve used a bank ’ s share of deposits in a market as a proxy for market power for the broader cluster of commercial banking products and services. the idea is that both consumers and small businesses often access commercial banking products through their deposit relationship institution. this approach also has the advantage of being measurable since banks are required to report deposits at the branch level annually through the fdic ’ s annual survey of branch office deposits. 3 to better reflect competition from

or even a moratorium on any deals. to others, these numbers illustrate a narrow view of bank services in a diverse and complex marketplace. therefore, they also highlight the importance of including the full “ cluster of commercial banking products and services ” provided to customers in a banking market, since these numbers only provide information on banks. as any quick scan of the marketplace for financial products and services will tell you, in recent decades, the number of competitors to banks, if anything, has significantly increased, rather than decreased. with that in mind, i ’ d like to discuss what i see as some of the key changes in the competitive landscape for banking products and services. i will also offer some ideas on - 7how i think we can modernize our analysis of competition while still preserving a vibrant and competitive marketplace that promotes innovation and enhances consumer choice. credit unions let ’ s start with the changes that have been taking place in the credit union industry. historically, credit unions were not seen as competitors to banks because they offered fewer small business and commercial lending products and were limited in their customer base because of field of membership restrictions. for this reason, credit union deposits were not factored into the initial competitive screens at all under the 1995 bank merger guidelines. however, in the past few decades, we ’ ve seen credit unions expand their fields of membership. many credit unions now go well beyond the traditional “ common bond ” requirements for membership and increasingly allow membership based on geography. we ’ ve also seen an increase in the percentage of credit unions offering small business loans. the national credit union administration has reported that 94 percent of credit unions with $ 500 million or more in assets offer business loans. total business loans at federally insured credit unions grew at an annualized rate of 14 percent from 2004 through 2015. 6 underscoring just how much credit unions are competing directly with banks, particularly community banks, is the recent increase in acquisitions of community banks by credit unions. 7 credit unions today are much more likely to compete directly with traditional banks offering the full “ cluster ” of banking products and services than they did member business loans ; commercial lending, 81 fed. reg. 13, 529, 13, 530 ( march 14, 2016 ). nineteen credit unions acquired commercial banks in 2019, up from seven in 2018 and three in 2017. - 8in 1995, which supports the argument that our analysis needs to give more weight to competition from credit unions. online deposit gathering another development impacting the competitive landscape for