Ms Noreen Byrne:

My key point is that, in the legislation, restructuring is defined quite narrowly. It only revolves around amalgamations, transfers of engagements and resolutions. The commission report is much broader and the definition therein includes not only amalgamations, etc., but also the idea of shared service networks, such as CUSOs. The legislation is supposed to be in line with the commission report but it is clearly not.

The remit of the credit union restructuring board will be based on the narrow definition of restructuring. This cuts off opportunities for credit unions. It is proposed that credit unions be incentivised. I am not sure how this will work in practice. Perhaps it would involve identifying an area and incentivising one credit union to merge with others, for example. This introduces a different dynamic in an area. It makes it very difficult for credit unions to enter a collaborative structure if they have a foot in a collaborative arrangement and another foot outside it. To some extent, this interferes with an organic process.