Mr. Paul Joyce:

That is an interesting topic. I have had a quick read through the recent discussion of 9 July. The administrative sanctions programme which was referred to fairly frequently throughout the submission that was made to the joint committee is the Central Bank's way of dealing with financial service providers who may breach standards and so on. Our experience would be similar. The process takes place behind closed doors, where the provider can opt for a settlement. The focus seems to be on settlements rather than on prosecutions of any kind. There is some material in the report, in which representatives of the Central Bank say that is the most cost effective way of doing this. Our overall impression would be that in the realm of financial services, different standards apply, that the financial service industry is unduly protected and, on the other hand, the consumer has fewer rights than they might have in other areas. We have had experience of writing to the Central Bank looking for details of how it arrived at sanctioning certain bank charges. It is very difficult to get information. Members may be aware of the famous section 33AK of the Central Bank Act 1942 is constantly referred to and it seems there is a kind of shield of confidentiality over everything.

As the petitioner at the recent meeting of the joint committee said, that is understandable for prudential issues and there are certain issue that have to remain confidential, but it seems to be a kind of confidentiality shield across the board, which is way over the top in our view.