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totally wide open, barrier-free market. that's the "beauty" of the Overture model (from their perspective, anyway). low barriers to entry mean anyone can play.
so as soon as you make a move to lower rates, some 3rd party will jump in the game and ruin the cartel. even if only for a few days. but a new player every week still screws up any efforts to price fix. :(
Again, this wouldn't work for viagra, car loans, real estate, or anything that dabbles into affiliate programs. I was thinking more of terms like 'camero parts', and 'steinway pianos'.