Mr. Pat Owens:

The Bill suggests an asset base and we think this should be an interim measure only. The regulation should be linked to risk and asset base is only one measure of risk. The more assets that a credit union has, if they go bad, the greater the damage, as we have seen in the country in general. That is not the only measure of risk but to bring that aspect into the legislation, the present tiers, as suggested by the commission, particularly that between €10 million and €100 million, are much too broad. A credit union with assets of €12 million is a different operation from a credit union like that of Mr. McConville, with €90 million in assets. St. Mary's parish credit union has €49 million in assets so we are in the middle. We feel that it is fine for credit unions up to €10 million, but there should then be tiers of €10 million to €30 million, €30 million to €60 million, €60 million to €100 million and then over €100 million. That would bring us to a situation where we are treating like with like in the services each credit union can offer. A credit union with an asset base of €49 million might not have the resources to offer some of the services the larger credit unions could offer but we are going to be subject to the same level of regulatory interaction as them.

Even from the regulator's point of view, it makes sense to have tighter bands. We would suggest the regulator has already embraced this concept with the prism model that has been introduced for regulation of all institutions in the country, which categorises financial institutions according to the level of risk they pose to the national economy and regulates them accordingly. They have already embraced the concept in their overall operations and we are saying it should be embraced for credit unions, which should be regulated according to tighter bands.

There are two or three other issues. What is Mr. Owens's view of the role of treasurer?