Comments on the Partial Amendment Bill to the Monopoly Regulation and Fair Trade Act

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CFE

- Korea Fair Trade Commission Public Notice No. 2004-6, dated 2004.05.07. -

On May 7, 2004, pursuant to Article 41 of the Administrative Procedures Act, the Korea Fair Trade Commission (KFTC) gave advance notice of proposed legislation to amend the Monopoly Regulation and Fair Trade Act in connection with the Three-Year Market Reform Roadmap (KFTC Public Notice No. 2004-6). As is well known, the main points of this amendment are the “retention of the total investment ceiling system,” the “reduction of voting rights for financial affiliates,” and the “extension of the account tracking authority.” Below, I critically examine the validity of these amendments, focusing on their key issues.

1. The Content of the Total Investment Ceiling System and Its Evolution

The total investment ceiling system is a regulation that restricts affiliates belonging to large business groups with total assets of 5 trillion won or more from acquiring or holding shares in other domestic companies in excess of 25% of their net assets. The total investment regulation was first introduced in December 1986, at which time it prohibited investments exceeding 40% of net assets. In 1994, the regulation was tightened, lowering the investment ceiling to 25% of net assets. It was then abolished in 1998 in order to defend against hostile M&As by foreign firms and to resolve the problem of reverse discrimination against domestic firms relative to foreign firms, but was revived in 2001. In 2002, items recognizing “exceptions” and “exclusions from application” were added, leading to the present system. As of April 2004, 331 affiliates in 18 business groups were subject to the total investment ceiling regulation. As such, the total investment ceiling system has gone through many twists and turns and remains the subject of constant controversy.

2. Are the KFTC’s Arguments for Maintaining the Total Investment Ceiling System Valid?

In a recently distributed document (“Several Misunderstandings about the Total Investment Ceiling System,” KFTC Competition Issue 04-04, 2004.5.3), the KFTC strongly argues that maintaining the total investment ceiling system is unavoidable on the basis of the following three arguments: (i) curbing reckless expansion of control and deepening distortion of ownership-control structures through investments among affiliates of large business groups; (ii) blocking unfair competition with independent small and medium-sized firms and mid-sized firms caused by abuse of the power of business groups; and (iii) preventing simultaneous insolvency within business groups caused by complex investment links.

To assess coolly the regulatory benefits of the total investment ceiling system, it is necessary to consider whether the policy objectives it seeks to achieve are valid, whether it is an effective policy tool for achieving those objectives, and whether the same objectives can be achieved through other policy instruments.

2.1 Preventing Reckless Expansion of Control Through Investments Among Affiliates

The claim that the total investment ceiling system is intended to prevent “reckless expansion of control” through fictitious capital means, put differently, that “the exercise of voting rights exceeding the controlling shareholder’s actual ownership” should not be tolerated. The KFTC appears to have made the policy judgment that the divergence between ownership and control created through fictitious capital is the source not only of owner overreach but also of corporate risk.

However, the corporate system is a mechanism that enables a business operator to attract small amounts of capital with a modest amount of seed money, so unless the controlling shareholder brings in professional managers, he will exercise managerial control exceeding the capital he himself has invested. Thus, ownership and control are bound to diverge to some extent. In the case of Korea’s large corporations, while the controlling owner’s shareholding fell in the course of the expansion of the business’s original base or main driving force, the identity of the business operator itself did not change. It is natural that managerial control should rest with the principal business operator. Therefore, the absolute level of the shareholding that supports the exercise of control is not the essence of the issue.

What is important is managerial performance.

In the United States, Bill Gates’s stake in Microsoft is 11%, while Jacobs’s stake in Qualcomm is only 3%. The policy perception that investments among affiliates have distorted ownership structures is also problematic. In general, except in the case of a newly established firm, ownership structures are not the product of someone’s elaborate calculations and plans. Rather, they are the result of investors’ decisions made over a long period under changing market conditions. Accordingly, it is more reasonable to view investments as having been made to defend control over affiliates rather than to expand control recklessly. It is natural for firms to devote themselves to defending management control. In Europe, countries such as Sweden, Finland, and Germany have introduced dual-class voting shares in order to stabilize control and prevent the outflow of national wealth. The major shareholders of Ford in the United States also exercise voting rights more than ten times their ownership stake. From another perspective, where differentiated voting rights for controlling shareholders are not recognized, investments among affiliates may be a self-help measure.

Given the Korean reality in which controlling shareholders exist, the essential problem of large corporations is the constant possibility that controlling shareholders may act against the interests of minority shareholders and creditors. Accordingly, the core issue is how to block the self-interested behavior of controlling shareholders—tunneling. Because this conflict-of-interest problem is fundamentally a matter among stakeholders, it is more efficient to address it through strengthened disclosure of transactions involving controlling shareholders, the blocking of unfair internal transactions, internal control mechanisms, and securities class actions, rather than through investment regulation. In other words, regulating investments does not improve corporate governance or increase management transparency. Therefore, the “regulatory benefit” of the total investment ceiling—which is at best an indirect device for regulating self-interested conduct and has little direct relation to improving governance and transparent management—cannot be considered large.

The KFTC appears to have designed a kind of incentive to eliminate fictitious capital in business groups. It has established grounds for excluding from designation under the total investment ceiling regulation those business groups whose gap between the controlling shareholder’s actual equity stake and voting rights is small. In other words, it intends to convert the graduation standard for the total investment ceiling system into the controlling shareholder’s “voting right multiplier.” The voting right multiplier is “the controlling shareholder’s voting rights divided by actual ownership,” and the lower the multiplier, the smaller the divergence between ownership and control. Although the concept of a voting right multiplier appears sophisticated, it contains problems. For example, while 51% voting rights and 100% voting rights make no difference in terms of control over a specific company, the voting right multiplier can still differ. Specifically, suppose the combinations of voting rights and actual ownership are (45%, 15%) and (80%, 20%), respectively. In both cases, voting rights of 45% and 80% are practically sufficient to control the firms. Yet the voting right multiplier is larger in the latter case, where actual ownership is greater [(80/20)=4.0], than in the former, where actual ownership is smaller [(45/15)=3.0]. Moreover, in the case of unlisted firms whose voting rights are 100% or close to 100%, the voting right multiplier must necessarily be larger than for listed firms. Therefore, all else equal, the greater the proportion of unlisted firms in a business group, the larger the voting right multiplier becomes. In the end, there are inevitable limits to evaluating a firm’s governance structure by means of the voting right multiplier.

2.2 Blocking Unfair Competition with Independent Small and Mid-Sized Firms and Preventing Simultaneous Insolvency Within Business Groups

Blocking unfair competition with independent small and medium-sized firms and mid-sized firms is certainly a necessary policy task for establishing a fair market competitive order, but it is not directly related to competition policy or investment regulation. This is because existing provisions in the Monopoly Regulation and Fair Trade Act on abuse of market-dominant position, prevention of unfair internal transactions, and regulation of subcontracting contracts are sufficient to address the issue. Paradoxically, investment regulation may, contrary to its original intent, restrict competition among firms. This is because a firm may be subjected to “discriminatory treatment” simply because it is an affiliate of a large business group, even if its market power is not great. For example, there are three major firms in the TV home shopping industry, but only Home Shopping A is subject to the total investment ceiling. Yet Home Shopping A does not have greater market power than the others. In this way, investment regulation may restrict competition among firms and thus run counter to the enhancement of consumer welfare.

Preventing simultaneous insolvency within business groups refers to the claim that when a business group attempts to support a distressed affiliate through investments among affiliates, investment regulation can serve as a useful tool to block such links. However, more effective policies than the total investment ceiling regulation for preventing simultaneous insolvency among affiliates are the elimination of debt payment guarantees and the prohibition of new guarantees. As part of corporate restructuring, an amendment to the Monopoly Regulation and Fair Trade Act in February 1998 created a prohibition on debt guarantees among affiliates, and measures had already been taken to eliminate all existing debt guarantees by March 2000. Therefore, at this stage there appears to be little room for the total investment ceiling regulation to make any additional contribution to preventing simultaneous insolvency.

Moreover, as minority shareholder rights have been substantially “realized” in practice, it is no longer possible to make investments simply to support an affiliate that has lost competitiveness. Such an affiliate will become subject to restructuring under market pressure.

3. Has the Total Investment Ceiling Regulation Actually Weakened Investment?

The hottest core issue surrounding the maintenance of the total investment ceiling regulation is whether it has actually reduced real investment. In a separate booklet (KFTC Competition Issue 04-04), the KFTC rebuts the business community’s claim that the total investment ceiling regulation inhibits investment. The essence of its rebuttal is that investment and equity investment are different concepts, and that empirical analysis supports the conclusion that the investment regulation does not restrict corporate investment.

As the KFTC argues, “investment” in the sense of an increase in capital stock—such as the construction or expansion of facilities—and “equity investment” as the financial act of acquiring shares are different concepts. However, in the end, equity investment and investment cannot be completely separate. This is because one may well ask what benefit there is in merely controlling a company through an equity investment. To raise corporate value, firms cannot avoid making facility investment and R&D investment. Even in the case of acquiring a distressed company (an equity investment act), large-scale investment is inevitably required in order to normalize that company. In another case, when capital on a scale too large for one affiliate to bear is required, affiliates may invest together and undertake investment through loans from financial institutions and so forth. Therefore, equity investment precedes investment and, after a certain time lag, will be connected to productive investment.

The KFTC cites KDI’s empirical analysis (2003) and argues that there is no meaningful “positive correlation” between equity investment and investment. According to KDI’s findings, equity investment and investment are separate matters. However, because investment is a kind of risk-taking based on expectations about the future, the extent to which equity investment leads to actual investment must vary depending on the specific investment project and economic conditions. In other words, a mechanical linkage between equity investment and investment cannot be assumed. In addition, because the “empirical analysis period” in that study coincides with the period during which the constraint of the total investment ceiling regulation applied from the firm’s standpoint (1997–2002), there are limits to tracing the effect of the regulation on firms’ equity investment and investment behavior.

Moreover, the special circumstances during the period when the total investment ceiling regulation was abolished (1998–1999) must also be considered. The reason equity investment was not linked to new investment in tangible fixed assets at the time was that during the IMF foreign exchange crisis, firms faced the external constraint of a “200% debt ratio.” Firms were preoccupied not with reducing debt in order to lower the debt ratio, but with increasing capital through financial investment in order to fit their debt ratio to the required standard.

Because the recent slump in investment has multiple causes, the reason cannot be attributed solely to the total investment ceiling regulation. Nevertheless, from a commonsense perspective, it is also true that investment regulation runs counter to creating a favorable environment for promoting investment. In principle, companies belonging to large business groups invest in other firms, including affiliates, not only to strengthen control over affiliates but also for the purpose of productive investment aimed at increasing corporate value through restructuring, entry into new businesses, and strategic alliances. However, because the total investment ceiling regulation is an ex ante and uniform regulation that does not distinguish the nature of investments, it contains the risk of regulating even productive equity investments.

Another dysfunction of investment regulation is that it is highly likely to distort corporate organization. The clearest type of investment activity that can avoid investment regulation is when a company itself finances the capital needed to expand its existing business areas or establish a new business division. However, when a company seeks to enter a different industry, it may be more efficient to externalize the organization—that is, to establish an independent company. Even where forming an independent company is more efficient, if the total investment ceiling regulation forces the company to choose the business-division format, then that regulation may distort corporate organization. Of course, if investments in related industries within the same sector are recognized as an “exclusion from application,” the distortion of corporate organization can be minimized. However, if the criterion for determining related industries in the same sector is based on the Korean Standard Industrial Classification, it may fail to encompass new industrial restructuring resulting from “technological convergence across different industries.”

4. Is the Total Investment Ceiling in the Roadmap a Temporary Regulation?

The KFTC’s position is that after observing the situation for three years, it may lift the total investment ceiling regulation if governance improves and evidence of transparent management appears. From one perspective, therefore, the total investment ceiling regulation may look like a regulation with a conditional sunset clause. However, the issue is not so simple. The first question is how to “objectify” evidence of transparent management and improved governance.

In a separate document (KFTC Competition Issue 2004-04), the KFTC diagnoses the situation as follows: it is generally assessed that Korea remains far from the transparent and fair system trusted by the market because internal and external corporate control systems capable of checking the irrational management practices of controlling shareholders in large business groups have not yet taken root. Therefore, it argues, it is necessary to maintain the total investment ceiling system until the “market-based self-monitoring system” functions effectively. In short, it is “premature” to lift the total investment ceiling. But the “prematurity argument” implies the institutionalization of the regulation on a permanent basis. If there is one gain, it is the acknowledgment that inappropriate and reckless investments can be filtered out not by the government but by the market’s own autonomous mechanisms. What is clear, however, is that the longer the total investment ceiling regulation—which directly affects private firms’ equity investment, investment, and corporate organization—is maintained, the more difficult it becomes for the market’s self-monitoring function to begin operating at an early stage. It is worth recalling Hayek’s insight that only when the private sphere is demarcated and respected can competition be promoted and the market evolve.

5. Is It Justified to Reduce the Voting Rights Limit of Financial Affiliates?

The Monopoly Regulation and Fair Trade Act limits the exercise of voting rights by financial affiliates belonging to business groups subject to mutual investment restrictions to 30%, together with specially related persons, and only with respect to such matters as “the appointment and dismissal of officers, amendments to the articles of incorporation, mergers, and business transfers.” One of the main points of the current amendment bill is to reduce this limit to 15%. The business community argues that if the voting rights limit of financial affiliates is reduced, even sound firms could become targets of takeover and merger attacks by foreign funds. The KFTC responds that the exercise of voting rights based on customers’ money was wrong from the outset. This view is based on the perception that industrial capital and financial capital should be separated.

According to an official at leading Korean electronics firm A, the distribution of shares in the company shows that while the controlling shareholder and non-financial affiliates hold 7.2% and affiliated financial firms hold 8.3%, the top 10 foreign investors hold as much as 22%; therefore, if foreigners were to attempt a hostile M&A, it would be difficult to find an appropriate defense measure.

Of course, there is also the opposing view that, given A Company’s recent management performance, the idea of a hostile M&A attempt against a sound firm is absurd. However, even sound firms may at times have vulnerabilities in their ownership structure. For example, SK Corp., which came under attack from Sovereign, is one of Korea’s representative blue-chip companies. SK Corp. was caught off guard because the “share swap”

used to circumvent the total investment ceiling regulation came to nothing, leaving exposed the weak capital link (equity stake) between the controlling shareholder and SK Corp.

After the attack by Sovereign, SK Corp. has made visible efforts to improve governance in order to defend management control. Even so, SK Corp. must continually bear the burden of defending control. Sovereign has already earned considerable potential investment gains. Foreign funds can play a positive role by helping market discipline—the market for corporate control—to function. But the ultimate objective of foreign funds is to earn “investment profits.” There is no reason to provide foreign investment funds with a “jackpot opportunity” through regulations that discriminate against domestic firms. Structural reform of the chaebol should, after all, be “our own task.”

At this point, it is necessary to consider why so many business groups—that is, industrial capital—came to have financial affiliates. There is always a reason behind such phenomena. One must ask whether they would have acquired financial affiliates if they had been able to obtain the necessary funds in the financial market in a timely manner and in the required amounts. Business groups came to have financial affiliates because the business environment forced them to maintain an “internal financial market.” Therefore, becoming absorbed in the rationale of separating industrial capital and financial capital, and sharply reducing the voting rights of financial affiliates without sufficient transitional measures and grace periods, would be a case of “killing the cow while trying to straighten its horns.” It should also be borne in mind that current financial laws have already established a basic firewall between industrial and financial capital by limiting the amount of shares financial institutions may acquire in their own affiliates.

6. Is the Extension of the Account Tracking Authority Persuasive?

The KFTC was first granted the account tracking authority (the authority to request financial transaction information) in 1999, in the midst of the IMF foreign exchange crisis. The reason for granting this authority was the judgment that restructuring would be difficult if distressed affiliates were supported and kept alive through internal transactions among affiliates. However, because it conflicted with the Real Name Financial Transactions Act and the principle requiring warrants, and because of concerns about abuse, it was permitted only temporarily for two years. It was later extended once for three years, and an attempt to extend it again in 2003 failed. Through this amendment to the Monopoly Regulation and Fair Trade Act, the KFTC is once again seeking a five-year extension of the account tracking authority.

The KFTC’s position on extending the account tracking authority is that “most unfair internal transactions take place through financial institutions, and in cases such as indirect cross-support, investigation is difficult without financial transaction information.” However, because in a monetary economy all transactions take place through financial institutions, the fact that unfair internal transactions occur through financial institutions cannot itself be the issue. Therefore, the real issue is whether unfair internal transactions can only be traced and identified by invoking the account tracking authority. In the past, when internal control mechanisms were inadequate, omissions and falsifications were possible, making account tracking necessary. But since the IMF crisis, improvements in governance and accounting systems have increased the accuracy of recorded transaction details and disclosed accounting information, reducing the practical effectiveness of the account tracking authority accordingly. Specifically, in 2003 the KFTC invoked the account tracking authority in its investigation into unfair internal transactions by the six largest business groups, but uncovered no additional findings beyond what had already been revealed in on-site investigations of the companies.

A key consideration related to the account tracking authority is the standard for determining unfair internal transactions. While the National Tax Service has a clear standard of plus or minus 30% around the normal price for determining “supportive transactions,” the standard for unfair internal transactions is merely “substantial suspicion,” which is not clear. This means that the determination of unfair internal transactions is left to the KFTC’s discretion. Because transactions among affiliates within a business group are a kind of “quasi-internal transaction,” whether they are unfair should be judged carefully according to a rule of reason that takes into account the efficiency-enhancing effects of internal transactions, and on the basis of whether they actually restricted competition. Tax evasion through transactions among affiliates that are not “competition-restricting,” as well as asset transfers through high-priced purchases and low-priced sales among affiliates including major shareholders, have long already been prohibited through “denial of wrongful act or calculation” and “deemed gift” rules, respectively.

The discussion of extending the account tracking authority lacks sufficient persuasiveness because the KFTC already possesses “sufficient” investigative authority. For investigations into internal transactions and the like, the KFTC has on-site inspection authority and the authority to seize materials, and it may impose administrative fines if firms refuse an investigation. It may also, when deemed necessary, request joint inspections with related agencies such as the Financial Supervisory Commission and the National Tax Service; and if it finds that the competitive order has been significantly undermined, it may file a complaint with the Prosecutor General. Strengthening a regulator’s powers alone does not enhance its authority.

From the standpoint of promoting competition and establishing a competitive order, the KFTC should devote more effort to uncovering “unfair collaborative acts (cartels or collusion)” rather than unfair internal transactions. This is also the international trend. Even the U.S. Antitrust Division has compulsory investigative powers only with respect to unfair collaborative acts that restrict competition.

7. Conclusion

The KFTC’s Three-Year Market Reform Roadmap aims to establish a transparent and fair competitive order. In that respect, there can be no objection to the policy objective itself. However, with regard to the tasks of market reform, there can be diverse views depending on how one sees the respective roles of the market and government.

The thrust of the large business group policy, condensed into the maintenance of the total investment ceiling regulation, is to prevent “reckless expansion of control by business groups.” But in this age of global competition, do firms that cannot restrain their desire to expand and seek to grow recklessly still truly exist? If firms have learned anything from the harsh restructuring process since the IMF foreign exchange crisis, there should no longer be any “reckless expansion.” Nor will market discipline tolerate such firms. This raises the question of whether regulating firms based on outdated perspectives is really being regarded as reform.

The total investment ceiling is a regulation that can directly affect “corporate ownership structures and corporate organization.” Even if there are many problems within business groups, government intervention in the private sphere denies the foundations of a market economy. From a global perspective, our problem is neither concentration of economic power nor the divergence between ownership and control. The total market capitalization of all Korean firms is no greater than that of a single U.S. company, GE. In some respects, fostering more global firms may be the quickest way to ease concentration of economic power. GE’s share of U.S. market capitalization is less than 3%. Also, as firms grow larger, divergence between ownership and control may be natural. And if chaebol chairmen remain obsessed with family management and show no interest in bringing in professional managers even as their firms grow, they are simply drawing the limits of their own growth. If controlling shareholders, shielded by their control rights, become absorbed in self-interested tunneling, they themselves will lose the market’s trust. The market is imperfect, but it is still capable of sufficiently screening out inefficient firms and firms that have lost the trust of the market. Accepting that market discipline can function only when the fate of firms is determined by “the hands of consumers” rather than political power is the first step in market-friendly reform. It is worth noting that the economic reforms of countries such as the United Kingdom and Ireland, which overcame economic crises, were “market-centered reforms.” These are eloquent examples showing that government cannot defeat the market.

The KFTC’s market reform program gives the impression of being highly sophisticated. If the economy’s course could be corrected as desired through the sophistication of such design, it might amount to efficient policymaking. But if not, it may even block the gradual “evolution of the market” through competitive pressure. As Hayek taught, policy should pursue not “expediency” but “principle.” I believe that faithfully pursuing competition-promoting policies consistent with the KFTC’s reason for existence is the policy direction most faithful to principle. I hope the KFTC will adopt a more flexible and market-friendly perspective.

If so, it should be possible to explain why business groups that in the past had similar characteristics in terms of pyramid ownership and control structures ended up taking divergent paths of survival and bankruptcy, and why some large firms in which the owner exercised full managerial authority nonetheless have high foreign ownership ratios.

Recently, the holding company system has emerged as an alternative to the ownership-control structure of business groups, and the KFTC is also encouraging conversion to holding companies. However, it remains the same in that a controlling shareholder “controls many assets with little capital.” For example, suppose Party A invests 10 to establish a holding company. If A receives an investment of 10 from minority shareholders, he can exercise management control (with a 50% equity stake and 50% voting rights). At that point, equity capital becomes 20. If A then uses outside capital equal to 100% of equity capital (the statutory debt ratio for a holding company is 100%), total available funds become 40. A can invest 40 and control a subsidiary with capital of 130 through a 30% stake (the statutory minimum equity ratio for a holding company’s subsidiary). In the end, A invests “10” and controls “130.” If a sub-subsidiary is established, A can control even more assets. Thus, whether through an affiliate organization (business group) or a subsidiary organization (holding company), there is no essential difference in that the controlling shareholder uses a small amount of seed money to control many assets.

Of course, there remains the possibility that a distressed affiliate with a high debt ratio may artificially lower its debt ratio by receiving an investment from another affiliate. But then, would such a distressed affiliate be able to secure borrowing from the banking sector? Before the IMF foreign exchange crisis, when debt ratios were calculated on an individual-company basis, cross-investment among affiliates could make financial indicators appear sounder than they actually were. However, after the IMF crisis, the requirement of combined financial statements made it impossible to artificially reduce debt ratios through the formation of fictitious capital. And artificially reducing debt ratios through fictitious capital no longer provides an advantage in obtaining bank loans. This means that banks’ loan screening function has been substantially strengthened in practice.

This is not unrelated to placing the burden of proof on the business community to show that investment regulation hinders investment. As long as investment regulation remains firmly in place, it cannot be denied that it is difficult even to formulate investment and investment plans that would exceed the total investment ceiling. And even if a new investment was abandoned because of investment regulation, such a plan is a kind of major confidential matter, so it is not easy to disclose the cancellation of the investment plan.

Specifically, in the recently converging telecommunications and satellite broadcasting industries, current industrial classifications treat them as different industries, so they do not qualify for “exclusion from application” under the investment regulation. Moreover, enumerating each case of exclusion one by one is not desirable in light of the principle of “simplicity of regulation.”

Although nothing has been finalized, the Ministry of Finance and Economy plans to allow large corporations to participate in bank management if they form private equity funds through a consortium. This private equity fund proposal is a painful expedient intended to draw in idle funds and sell government-owned financial institutions such as Woori Finance to domestic capital, but it conflicts with the KFTC’s position of preventing the participation of industrial capital in finance. Although nothing has been finalized, the Ministry of Finance and Economy plans to allow large corporations to participate in bank management if they form private equity funds through a consortium. This private equity fund proposal is a painful expedient intended to draw in idle funds and sell government-owned financial institutions such as Woori Finance to domestic capital, but it conflicts with the KFTC’s position of preventing the participation of industrial capital in finance.

If the voting rights of financial affiliates are reduced, the total internal shareholding in Company A that can exercise voting rights will fall from 15.5% to 15%.

This refers to Chairman C of the SK Group exchanging, at a certain ratio, the shares he owned in the Walkerhill Hotel for SK Corp. shares held by SK C&C in order to secure control over SK Corp. Chairman C was indicted by prosecutors on charges of overvaluing his Walkerhill shares. The case is currently pending before the Supreme Court, and it sparked intense controversy over the valuation of unlisted shares.

The KFTC analyzes that Sovereign was able to attack SK Corp. with little capital because the investment link between SK Corp. and SK Global (Networks) caused SK Global’s insolvency to depress SK Corp.’s stock price. But the more fundamental reason was that the total investment ceiling regulation had weakened Chairman Chey’s control over SK Corp.

Donggeun Cho (Professor, Department of Economics, Myongji University)

Wiki:

https://www.cfe.org/w/bbsDetail.php?idx=73

Original title: 독점규제및공정거래에관한법률 중 개정법률안에 대한 의견

Author: Dong-geun Jo

Date: 2004-05-25

Source: https://www.cfe.org/bbs/bbsDetail.php?cid=bill&pn=4&idx=25830

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