AnalysisConcentration Watch · Issue 1
Concentration Watch: 41 in-depth merger reviews among 1,944 eligible deals
The first issue of our weekly column: a 2.1 percent Second Request rate in fiscal 2025, three proposed settlements and a court-ordered remedy in the enforcement ledger since September, and the three numbers we will keep returning to.
The number of the week: 41
That is how many Second Requests the FTC and the Antitrust Division issued in fiscal 2025, out of 1,944 transactions eligible for one. A Second Request is the agencies' only tool for an in-depth look at a merger before it closes. 2.1% of deals got one. In fiscal 2016 the rate was 3.0%; the period's high was 3.0% and its low 1.6% in fiscal 2022. In no year did more than one eligible deal in thirty get an in-depth review.
The agencies would say, correctly, that most reported deals raise no competitive issue. The question the column will keep asking is whether a review rate of two percent can be the right answer in a decade when the county banking map, the Census industry tables, and the agencies' own market studies all point the same way.
| # | Name | Transactions reported | Adjusted | Second Requests | Rate |
|---|---|---|---|---|---|
| 1 | FY 2016 | 1,832 | 1,772 | 54 | 3.0% |
| 2 | FY 2017 | 2,052 | 1,992 | 51 | 2.6% |
| 3 | FY 2018 | 2,111 | 2,028 | 45 | 2.2% |
| 4 | FY 2019 | 2,089 | 2,030 | 61 | 3.0% |
| 5 | FY 2020 | 1,637 | 1,580 | 48 | 3.0% |
| 6 | FY 2021 | 3,520 | 3,413 | 66 | 1.9% |
| 7 | FY 2022 | 3,152 | 3,029 | 47 | 1.6% |
| 8 | FY 2023 | 1,805 | 1,735 | 37 | 2.1% |
| 9 | FY 2024 | 2,031 | 1,973 | 59 | 3.0% |
| 10 | FY 2025 | 2,006 | 1,944 | 41 | 2.1% |
On the docket
The enforcement ledger has added 4 dated official records since September 2025, the most recent on Jul 14, 2026: FTC announces proposed consent agreement with Caremark. The pharmacy benefit manager matter is the one to watch. Two of the three largest PBMs have now signed proposed consent agreements with the FTC over formulary design and rebate practices; the third has not. Whether the settlements change what patients pay at the counter is a question the ledger cannot answer yet, and we will say so until it can.
| # | Name | Date | Agency or court | Stage |
|---|---|---|---|---|
| 1 | FTC announces proposed consent agreement with Caremark | 2026-07-14 | Federal Trade Commission | remedy |
| 2 | FTC announces proposed consent agreement with Express Scripts | 2026-02-04 | Federal Trade Commission | remedy |
| 3 | DOJ files proposed settlement with RealPage | 2025-11-24 | U.S. Department of Justice | remedy |
| 4 | Court orders search distribution and data-access remedies | 2025-09-02 | U.S. District Court for the District of Columbia | remedy |
| 5 | FTC reports on cloud-provider and generative AI partnerships | 2025-01-17 | Federal Trade Commission | monitoring |
| 6 | FCC releases 2024 Communications Marketplace Report | 2024-12-31 | Federal Communications Commission | monitoring |
Three numbers we will keep coming back to
187: the number of U.S. counties with exactly one bank organization. 1,792 of 3,104: counties above the 2,500 HHI line. 12: industries where four firms take at least 90 cents of every dollar. Each has its own data story this week, and each will be updated when the next FDIC or Census vintage arrives. The column's job is to notice when they move.
What to watch
The fiscal 2026 Hart-Scott-Rodino report, when it arrives, will show whether the new premerger form that took effect in 2025 changed the number of filings or the Second Request rate. The next FDIC Summary of Deposits vintage lands in the autumn and will settle whether Delaware's statewide concentration stays where the Discover acquisition put it. And the third PBM.
Next issue: which bank leads the most counties, and whether that has changed since 2015.
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Concentration Watch is published here weekly and carried in the site's RSS feed; an email edition opens once the list is set up. If you report on any of these markets and want the underlying table for a place or industry, write to us; commissioned analyses and data licensing are how this work is paid for.
How we counted
Second Request counts and adjusted transaction totals are from the FTC and DOJ annual Hart-Scott-Rodino reports, fiscal 2016 to 2025. Enforcement records are the dated official documents in Antitrust Radar's ledger with their procedural stage as recorded. Banking and industry figures are those in this week's data stories.
HSR transactions are premerger notifications, not every U.S. merger. A Second Request is an investigation, not a finding, and the adjusted denominator excludes matters that could not receive one.
Analysis pieces state Antitrust Radar's editorial position. Every figure is computed from the site's published datasets at build time and links to the page that holds it. Concentration measures identify where to look; they do not by themselves establish market power, harm, or unlawful conduct.