in the late 1990s, the Bank of the Southwest (BSW), a regional financial institution located in the southwestern United States, decided it was not getting its fair share of the equity loan business. Residential housing prices were climbing at a steady rate in virtually all of its markets, and credit card debt also was rising. Many customers were converting credit card debt into lower-interest-rate home equity loans, but research showed that fewer than 25 percent of BSW customers who converted were doing so through the bank’s equity loan facility. BSW was getting only 2 percent of the conversions to equity loans in the market, even though it had a banking market share in its largest markets of between 11 and 23 percen