The Office of the Comptroller of the Currency said Friday that the agency’s key antitrust compliance metric may be increasingly unable to capture relevant measures of market competition due to the growth in nonbank and online banking services.

In remarks to a crowd at a bank merger symposium, OCC Senior Deputy Comptroller and Chief Counsel Benjamin McDonough said the OCC believes it is worth evaluating how the merger review process may need a reboot, given rising concerns around anti-competitiveness, systemic risks, and potential harm to consumers.

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Sarah Miller, executive director and founder of the American Economic Liberties Project said during the symposium that bank mergers, in addition to hurting economic competition, hurt American consumers in ways that can be hard to quantify.

“When banks merge, they close branches, limiting Americans’ financial access and contributing to the rise of banking deserts,” Miller said. “These closures are frequently clustered in poor communities and often push people out of the banking system and into the arms of predatory financial companies like check cashers and payday lenders.”

“In communities affected by bank mergers, research indicates that households are more likely to accrue unpaid debt, have that debt go to collections, and even be evicted,” Miller continued. “That consolidation has been credibly associated with a rise in burglary and property crime. It has been shown to depress real estate values and inhibit local construction throttling economic development, and correlated to rise in unemployment, declines in median income, and worsening income inequality.”