Mr. Ed Farrell:

There is the full suite. The rules state every credit union must have a risk officer, risk committee, compliance officer, compliance committee and an internal audit function. The external audit function was always in place. A credit union must have a board of directors and board oversight committee. There are six or seven layers of checks and balances. With the absence of tiering, the smallest or simplest credit unions are subject to the same requirements as the largest. Some of the bigger credit unions might have a simple business model. We are not necessarily saying it a case of the smaller versus the bigger. The one-size-fits-all-regulatory burden has been imposed and there is a cost to implementing those systems. As Mr. McCrory stated, when the Government talked about the big hole in the credit unions, it created funds, and the credit unions are levied every year to put money into them although the money was already in the movement. Some €20 million or €25 million per year is going into three or four of these key funds. It represents approximately 20% of credit unions' income. The funds are not needed. The rainy day has passed, as it were.

Without giving too much detail, one of those funds was the credit institutions resolution fund. It was set up for four years and it was to have €100 million after that period. The banks were to pay in €17 million, the credit unions were to pay in €7 million and what I call the IFSC companies were to pay in €1 million. Therefore, €25 million per year was to go in for four years.

The four years have passed. We have been asking the Central Bank and the Department of Finance if that is the end of it. It was a four-year fund. Is that the end of our levy going into that fund? Before they answered us, they took a fifth year’s levy into a four-year fund and we still cannot get an answer. One is pushing it to the other and we are not able to tell our credit unions if the fifth of four is the last one or if there will be six or seven or four.

At the same time, they commenced another fund, the Deposit Guarantee Scheme Fund. We got reassurances in November. Last May we had been expecting it by year-end. We got reassurances in November it was not current, but in less than a month invoices for €12 million went out to credit unions after we had been reassured a month earlier it was not current. That €12 million and €7 million gives a total of €19 million in levies that went out in December. The €7 million is the fifth year of four and the €12 million we were told was not imminent. It is 20% of the credit unions' income and the income is under pressure because of the interest-rate cycle we have been talking about.