Mr. Rónán Hession:

We have had some contact with the Central Bank on the issue and it produced its own analysis. One of the reasons we have ended up over time in a position of controversy with the funds is they are esoteric from a tax and a regulatory point of view and have thrived in that blind spot. Certainly, when I mention section 110 companies - the SPVs of most interest - that section of the tax Act was intended to be used for a genuine securitisation of the financial services industry, but it became primarily a vehicle for property and the acquisition of loans as opposed to a vehicle for property development. One of the changes made in the Finance Bill when we were addressing the tax problems was aimed at improving the level of information Revenue would receive from these funds because up until then there was a delay in the reporting of information and the detail was somewhat wanting. There should be better information available.