Mr. Brian Corr:

On the recommendations, collectively as a group we felt the most important recommendation was in respect of lending. The full review of the lending limits is under way; the consultation has started. The Central Bank took significant account of the scoping paper on that which we issued to it as a group in late 2017. A fair bit of that got incorporated into the consultation, although not everything that the group recommended. In terms of that consultation, each representative body represented here today and other stakeholders - all the individual credit unions - will submit, and many of them have already submitted, submissions to the Central Bank on that consultation. They will raise different issues to those we would have raised collectively as an implementation group.

The group cannot bind individual credit unions or individual representative bodies to one form of progress.

On tiered regulation, which is probably the second most important aspect of the CUAC recommendations, the two-tier tiering that was proposed by the advisory committee was not agreed to collectively as a group. We put forward a tiered regulation paper to the Central Bank and, in a sense, we were saying it should not be the two-tier regulatory framework and should be something different, which is tiering in the regulations, and for it to be revisited if the Central Bank does not deliver that. However, the Central Bank is delivering a portion of that at the moment.

We called out the third recommendation, which the Central Bank did not progress. I said in my opening statement that the group and the advisory committee were disappointed that it did not bring in a form of service level agreement between the credit unions and the Central Bank, which was the original recommendation. That is definitely called out.

In regard to recommendation 3(b) on consultation and engagement, which is tied to regulatory impact analysis in consultation papers, the group felt there was satisfactory progress by the Central Bank. While there was definitely room for improvement, there was satisfactory improvement.

The next item concerns governance, where no action was specifically required of the implementation group, although we reviewed the issues. On restructuring, the Department of Finance has committed to doing a review of restructuring cases and mergers after a significant period of, say, several years for those to be embedded, which will mean a review in 2020 or 2021. That is the action being taken in that regard. With regard to the interest rate ceiling, as the committee knows this is a legislative chain so it has to go through the legislative process. I cannot pre-empt the views of Cabinet in regard to approval for heads of a Bill but that is progressing and, assuming it is all approved, it will come to the Oireachtas.