Mr. Brian Hayes:

I thank the Chairman and members of the committee. It is a privilege to be here and we appreciate the opportunity to come before the committee as exiting and remaining banks. As an industry group, Banking and Payments Federation Ireland especially appreciates that. I am joined by our head of consumer banking, Ms Michelle Byrne, who has taken on a lot of responsibility in our team for many of the issues we are dealing with across this migration of accounts.

It is safe to say that the loss of KBC and Ulster Bank to the retail bank landscape in Ireland is a significant issue and challenge for the whole sector. It is a significant challenge for customers. They did not ask for or want this. We have an absolute responsibility, from the perspective of exiting and remaining banks, to make sure we deliver results for our customers over the next year as they find a new home for their bank accounts. We are very conscious of that. It is incumbent on the entire sector, including exiting banks, remaining banks, and other providers such as credit unions, An Post, and digital providers, to find solutions as we go forward.

It is a logistical challenge, but I am conscious of one other thing. It is more than just a logistical challenge; it is a reputational challenge. The industry must step up to the plate and stand up to its responsibilities across the piece over the next year or so, to make sure we get this right given everything that has happened in the past. Given our experience of the payment break situation over the past two years, where short-term liquidity was provided by our members to about 180,000 business, corporate and personal mortgage customers, there is a lot of learning we can take from that going forward in terms of what has taken place.

This is the number one priority for our organisation. We are dealing with this every day, week and month for the past year or so. The other day, representatives from the charity sector were in with us about standing orders, such as payments people make to Trócaire and other NGOs. It is a big issue for them to make sure we get it right.

We will have to deal with many issues that throw themselves up as we go through this. We very much appreciate the observations of the members, given the fact that they are all front-line politicians. They hear and see people in their communities. Let us work through that as best we can. From our perspective, people and customers have to have confidence in the system that we deploy among the exiting and remaining banks. We will see a particular challenge going into quarters 3 and 4 of this year. I hope we can demonstrate our readiness to deal with those challenges.

I will not go through some of the issues we had in our submission in much detail but there are questions being raised in terms of the switching code or the alternative of choose, move, close. A customer chooses a new provider, transfers his or her direct debits and closes his or her account. We are agnostic on that. All we are saying is that different customers will choose different journeys. We have to be conscious that it is not a solution for everyone. We are very conscious that whether a customer chooses the switching model or the moving model, there are fundamental consumer protection rights along that journey which have to be vindicated by those exiting and remaining banks.

The issue of direct debit originators, DDOs, has cropped up and it is in our submission. I am conscious of the Chair's opening remarks on the readiness of the industry. We have met the top 20 DDOs over the course of the past number of months on at least three occasions. We have a good engagement with them. Their problem is our problem. It is a problem of resourcing up and making sure, from a remaining-bank perspective, that we are ready to deal with the new customers coming the way of the banks. We still have a job of work to do.

Our organisation has written to the Commission for Communications Regulation, ComReg, and the Commission for Regulation of Utilities, CRU, and we have looked for engagement there. We have raised it with our own regulator, the Central Bank of Ireland. We are very happy that our regulator has written to financial service providers within its own authority. However, there is a job of work to be done there, especially on direct debits, standing orders, recurring payments and credit transfers.

Frankly, the problem will not be opening or close an account. The problem will be in the meat in the sandwich. Effectively, that will be the transfer of all these payments from service providers and making sure that the experience is good. We reckon that approximately 7 million of these transactions emerge. If one takes an average of ten transactions per personal account and somewhere between 30 and 40 transactions per business account, one sees the scale of the challenge. Working together, we will get there, but there is a role for others to do and the example of our own regulator to follow. We would appreciate that.

Vulnerable customers are absolutely essential to get this right. Vulnerable customers do not come with a tag on their back. They are people who may well be challenged digitally. They are potentially older people, although we should not make the mistake that older people cannot deal with some of these issues. They can. However, banks have a considerable role to play there. Our banks have very dedicated teams when it comes to vulnerable customers. They know how to escalate issues. Many of those people will want to meet people face to face. In that regard, face-to-face meetings, home calls, late-night- and weekend-opening branches are crucial.

The implementation of the assisted decision-making legislation will help as we go forward in terms of some issues of capacity. Our members have opened, since the last day of February this year, in excess of 4,000 accounts for Ukrainian refugees who have come to this country. Some 15% of the total cohort or 26% of all adults have had an account opened by our members since the end of February. That is by the co-ordinated action of the remaining banks that have worked with the industry and other agencies to make sure we got into those centres to open those accounts. With regard to communications, we launched a campaign this week on FraudSMART. It is a well-known, industry-wide campaign. There will be many attempted scams of people as we go forward. We as an industry have a big job to do in making sure we get the message out to keep our customers safe.

My last remark will be an appeal to the Chair and other members of the committee. This issue has arisen about anti-money laundering and how one open accounts. To open an account, one needs proof of address and proof of identity. This has been raised in terms of consumer protection and Deputy Doherty has raised it publicly. Some people do not have a passport or driver's licence. One might say that is a minority example and it may well be so, but we would like to be able to open those accounts with public services cards.

We have been articulating for the past five years that we cannot do that under the current legislation. We are precluded from doing that under the current legislation. I am referring specifically to Schedule 5 to the Social Welfare Consolidation Act 2005. If the Oireachtas allowed us to open accounts with public services cards, we could deal with the cohort of customers who find themselves in this position. It would help older people who do not have the documentation to get through this. We cannot do what is illegal. It is currently illegal for us to accept a public services card. If we change the legislation, it would help. I ask the committee to take this up with their colleagues. It is not provided for in Schedule 5 to the original Bill. It is specifically precluded.