Mr. Dermott Jewell:

It is a pleasure to be here. It is wonderful to be able to contribute because this is such an extraordinarily important area. We are really glad that the committee is focusing on this.

Over the past 18 months so much has been written outlining the difficulties, the causes and the background issues, yet very little of it is substantiated by pure data. This was a case some years ago. The fact that there is no independently verified data or detail makes this a great difficulty. I am very conscious that every member here will have heard and read much about the difficulties experienced by motorists. I will introduce our position on this. We have been trying to create a level of interest in it since early 2013. We wrote to the Minister for Jobs, Enterprise and Innovation in 2015. The reason we wrote to that Minister was that that was the Department that initiated and established the Motor Insurance Advisory Board. Members can see where we were going with this; we were trying to point out the very significant - at that time, double-digit - increases that motorists were experiencing. Even then it was proving to be something of an affordability issue as well as a question of value for money.

In 2015 providers across the industry were making the point that increases were a necessity because, as is generally suggested, it was to do with the cost of claims, the cost of legal practitioners' fees, the level of court awards, and the age and condition of the vehicles. It was everything except anything to do with the industry. That is not to say that it is, but it still raises the question: "If you are going to say that, can you not please provide the clear, clinical data to allow us all to understand this?" That has been the main thrust of where we were.

The Injuries Board, in its 2015 annual review, outlined its concerns about the cost of claims. It made the point that it was very far from its comprehension of the market and the statements from the industry did not in any way indicate a necessity for increases resembling those that were coming forward. An Garda Síochána was reported to have indicated that there was a higher risk to road safety from older cars. The Injuries Board made the point that that did not match its evaluation of the situation. Motorists or consumers then started to question the validity of the national car test because they were spending significant amounts of money to maintain their vehicles, putting their cars through the national car test and passing the test, yet they were told they were not viable vehicles to insure any longer. There is a great loss to the consumer there.

In our letter, we referenced the Motor Insurance Advisory Board. In 1984, the then Department of Industry, Trade, Commerce and Tourism established the Motor Insurance Advisory Board (Establishment) Order, which formed the basis for the 1998 formation of the Motor Insurance Advisory Board. We then quoted extracts from the Act to indicate that they are totally fit for purpose today. They work; they give the power, they give the strength, and they ask for the independence to do what is necessary to understand this market. As a result of that, many good things came in the 2002 report of the Motor Insurance Advisory Board. There were 67 recommendations, most of which have been implemented. It was due to the work of that board that consumers for the first time got a renewal notice well in advance to allow them to look around the market - to shop around. That is what made that possible. They could not do it previously. They struggled even to get a renewal certificate and certainly a no-claims discount certificate. Much has changed since then, and a new approach is needed. To bring it right up to date in 2016, we have made the point that there is a need for re-establishment of some form of board resembling the Motor Insurance Advisory Board, because it was an independent structure. It had representatives, literally, from every agent and actor engaged in the provision or purchase of motor insurance, and it was excellent. Good people came around and figured out what the problems were. I am not saying it is not in train at the minute, but it needs to be taken into a greater context.

Not much happened because the Department of Jobs, Enterprise and Innovation now is not responsible for transport, and our letter was sent to the Department of Transport, Tourism and Sport, but there was a change in government and everything got pushed aside and delayed; we acknowledge that. The point was made to us in a response from the Department that the Competition and Consumer Protection Commission issued a report indicating that there is plenty of competition in the market. We acknowledge that there is plenty of competition in the market, but at outrageous and ever-increasing rates that many people just cannot afford. The key element of this is that this insurance is legally required; one must have it. It is not logical to say to anybody that one must have something regardless of how expensive it might be. It is certainly not what would be, even in good governance circles, an honest message to pass on to a citizen.

So, where are we? We have got the worries about that. Many consumers have gone for cheaper alternatives. The problem is, as much of the media has reported in the past two weeks, that many consumers who are seeking to get the best deal they can have approached providers that are not resident in this jurisdiction. For example, Gibraltar is home to 11 of 24 foreign insurers operating in the Irish motor market. We have already had difficulties coming through a number of those companies, and that is just at the early stage. Most recently, one of them announced it would not take any new business. There is a problem here. The problem is in the cost of claims. If we are to take that on board, it is fair enough. These organisations are allowed to trade in Ireland if they have a compensation scheme, but they do not operate one. There is a reliance on us to provide, and the motorists who are already experiencing additional costs from the cost of claims and everything else will now potentially be asked to foot many more bills for claims from companies that just walked away, went back home and left the Irish motorist in a very poor condition.

In the past ten or 14 days, another issue of significant concern in this market was reported to us. It was pointed out to us that certain members of Civil Service employee unions were in receipt of significant discounts. To have that level of discount challenges the market that was already challenged when it came, for example, to giving lower rates for female drivers. The European Commission stepped in to stop that.

Where insurance is a legal requirement, subsidisation like that must be reviewed without delay because it is discriminatory. It is entirely separate to a no-claims bonus, to which everybody is entitled. If we cannot all access the same discounts, then there is a very real problem that is open to both appeal and sanction.