Mr. Kieron Brennan:

Specifically, the fact that one cannot serve on the board of credit union or be an employee and give voluntary service to another. We find the last criteria, listed as (i), particularly objectionable. It reads:

parent [sibling] or child of a director, board oversight committee member, employee or voluntary assistant of that credit union. a person who is a spouse, civil partner within the meaning of the Civil Partnership and Certain Rights and Obligations of Cohabitants Act.

The families, siblings, parents and children of every actor in the credit union, be they on the board, an employee or a volunteer who cleans the building on a Friday night, are now prohibited from working in other credit unions. Many small credit unions operate with only voluntary members and no staff. They will now have to move to a point where the board of directors will have to undertake everything from governance to manning the counters. Now, they will have to find a new set of volunteers to do these tasks because they are prohibited.

In conjunction with that, there are several other elements that will disproportionately affect small credit unions. There is a requirement to have new committees which cannot overlap with board membership, an internal audit function and a risk management function. If one takes all of these into account, one could be on the board of a small credit union today and wonder where one is going to get the extra 20 or 30 volunteers over and above. How is one to attract these volunteers now they have a higher level of commitment and compliance expected of them? We see this as an undermining of volunteerism. At a time when financial services are letting our population down, we are undermining the one community-owned, volunteer-led organisation that is trying to help people.