Ms MaryRose McGovern:

The Deputy mentioned the digital banking platforms used by younger members of society. It is important to understand that the organisations making those services available do not require a banking licence and tend to operate under e-money licences. It needs to be understood by the users of those services that right now, they cannot go to the Financial Services and Pensions Ombudsman with a complaint because of the manner in which those firms are structured. They do not have a physical presence here and they are not regulated by the Central Bank. They are not subject to conduct of business rules for technical reasons but that is because the payment services regulations provide a protection that is over and above what the conduct of business rules would offer. Anybody wishing to make a complaint, however, would need to go to the competent authority of the member state that issued the licence for those entities.

It is fair to say that it is in the public arena that at least one of those digital banking platforms has applied for authorisation in this jurisdiction. If that authorisation becomes real, customers of those digital platforms will be entitled to make a complaint to the Financial Services and Pensions Ombudsman.

From the point of view of the Central Bank, it is probably or may be a concern that anybody holding an account with one of these entities can, in a matter of seconds, go from cash to crypto. The Deputy referred to crypto. It is important to understand that there is no specific regulatory regime in Ireland in terms of cryptocurrencies. There is an argument that some elements of the e-money regulations or the payment services directive may play a part in cryptocurrencies but right now, they are not specifically regulated, so one is moving out of that consumer space into a non-consumer space. It is a cause of concern. Certainly in the past week or so, the Financial Conduct Authority in the UK has written to 300 firms warning them that they are failing to give appropriate warning to their customers about the risks of signing up to those services. It is probably important to understand that cryptocurrencies are not necessarily for the average consumer. They are very volatile. Even in the past week or so, the Deputy may have heard of the Musk effect where Tesla has indicated an unwillingness to accept cryptocurrencies in exchange for - I will not say "buy" because I am not sure if that is the correct verb - for the acquisition of a vehicle. This had the immediate effect of reducing the value of Bitcoin by 30%. These are volatile assets. It is a very dynamic and emerging landscape but right now, although the European Commission is looking at developing a regulation for markets in crypto-assets, it is not there yet. It is only in its very early stages and what consumer protections it will offer remains to be seen.