Submissions to Treasury on the Federal Government's proposed price-signalling ban are unanimous: it is an ill-advised law.Though the submissions predictably come largely from business groups affected by the law, and from their legal advisors, the range and size of defects they highlight is impressive.The revelation of the full range of submissions follows strong criticism from competition law experts Brent Fisse and associate professor Caron Beaton-Wells.They have now been joined by another group of law and public policy academics - the University of Melbourne's Rhonda Smith and Arlen Duke, and the University of SA's David Round, a former ACCC associate member and a member of the Australian Competition Tribunal which reviews ACCC decisions. The submission from the three says the proposed law has "many problems" and should not be rushed in.The proposed law has two key clauses: a ban on all private disclosures to competitors, and a ban on public price disclosure for the purpose of substantially lessening competition.The 22 submissions feature a number of common criticisms of the draft bill, including:there is no clear evidence of a "market failure" in banking. The Business Council cites the OECD's recent comments that in the Australian banking industry "competition is generally considered to be healthy". The government needs to show that price signalling is reducing competition in industries such as banking, the BCA says, and should refer the issue to the Productivity Commission.The overall effect of the bill goes well beyond attacking anti-competitive behaviour. The National Australia Bank says it "will have the potential to discourage legitimate price transparency and reduce the ability for our customers, suppliers and investors to make informed decisions."By banning unilateral disclosures of information, the proposed law would be applied too broadly, going well beyond US and European Union laws. The Law Council of Australia says government claims that the proposed law reflects those overseas are "fundamentally misleading".The ban on any disclosure for the purpose of substantially lessening competition "is likely to stifle the legitimate and pro-competitive flow of information", says the Law Council.There is no exception, or defence, for legitimate business practices, or for disclosures which are not commercially sensitive. Smith, Duke and Round note that "signalling conduct can have both positive and negative effects on competition". And Westpac's submission says the government has incorrectly assumed that private disclosure of pricing can only be for anti-competitive purposes. Such disclosures are important in syndicated lending, payments system processes, due diligence for fundraising, and in certain public policy discussions.The law would let the government decide which industry sectors it would apply to. Smith, Duke and Round call this dangerous, saying it could lead government to "knee-jerk reactions to perceived competition problems". Global law firm Allen & Overy's anti-trust group says this would risk leaving Parliament without the opportunity to fully consider and debate its application across industry sectors. Law firm Gilbert & Tobin says it indicates that the law is not well formulated.The announcement that the law would first be applied to banking is, as the Australian Bankers Association submission