Oireachtas Joint and Select Committees

Thursday, 14 May 2015

Committee of Inquiry into the Banking Crisis

Nexus Phase

Mr. Paul Dobey:

Well, I have to take you back to the comments I made in my opening statements. If a bank thinks it needs more capital, it can hold capital. It can decide not to pay dividends, we had that discussion earlier on. It can decide to raise capital in the markets. If the regulator thinks there's greater risk in the banks than they would like to see, they can specify that greater capital should be held against those risks. So IFRS accounting is only one small piece in the picture here, and the other thing I should say to you; when general provisions are set aside by banks, they're not necessarily a buffer against capital because the capital adequacy rules, under the CRD are such that those loan loss general provisions get added back to capital. So they're not available always as buffer. Now they get ... it's technical but they get added back to tier 2 capital. But they do get added back to capital and it's not necessarily a buffer against loss in that circumstance.

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