Ms Anne Marie McKiernan:

Can I address two points there? One relates to the regulatory burden, either the cost or the practice of it. On the second point, I will not attempt to refute all of the matters raised during a very long hearing on Tuesday but perhaps I will raise a few for clarification purposes.

On regulation and regulatory burden, we have one framework but we do not apply it with a one-size-fits-all approach. We do so in a proportionate way. We do that through several different approaches. One is that we have higher expectations and requirements for the largest credit unions and those that aspire to do more complex business. We have much simpler expectations and engagements with the smaller credit unions whose model remains simple.

In terms of our engagements with credit unions, we differentiate significantly on that basis too. We have larger, longer and more frequent supervisory engagements with the biggest and most risky credit unions, as would be expected. We have scaled-back and less frequent engagements with the smallest, lower risk, credit unions. We focus significantly on viability and credit risk there. We are operating within our existing framework in a tiered way to the greatest degree that we can. We are trying to adhere to the spirit of the Commission on Credit Unions' recommendation in respect of tiering, but within one framework. It would be erroneous for it to be presented as a one-size-fits-all framework. It is not.

We have also started to introduce an element of tiering in the way in which we apply certain rules. For example, with regard to payment service and MPCAS approval, which means taking on a more complex and expensive future business line and which involves particular costs, we are, at least initially, making that opportunity only available to credit unions over €75 million. It can cascade down to smaller credit unions in time. That is very much in the spirit of letting more complex business be taken forward by more progressive credit unions who are better able to handle any downside risks from it. That is in respect of the cost or burden of supervision and regulation.

One issue which I believe is important to get on the table arising from Tuesday is the sense that we are blocking the making available of sector-significant funds towards social housing. That is absolutely not the case. To be clear, one of the main reasons the large excess funds of the sector cannot be made available for social housing directly through lending is the common bond. Under the common bond, credit unions can only lend to members within their common-bond area. If a credit union wished to lend to approved housing bodies, unless the approved housing body was within the individual space, it could not do so. They would not be able to marshal the funds at the level of the sector in that way.

While recognising that the common bond is a core part of the Irish sector, which is very valued and which the sector would not want to change or meddle with in any simple way, we nonetheless highlighted that it was an important issue in our submission to the CUAC review in 2016. We pointed out situations where the common bond, in its current legislative framework, restricts certain progress, both on social housing and on restructuring. We put it on the table as an important issue that could be addressed. It is up to the credit union sector to decide how far it is willing to change that. Progressive credit unions in other jurisdictions have tended to move away from the type of common bond approach we have now.