Ms Michelle Byrne:

As the Deputy has acknowledged, we are positive about this, we are happy to engage and we support the policy objective. However, as I have outlined in the two submissions we have made - the written submission and the opening statement - there needs to be broader indemnification and simplification of the Bill. We are available to engage and assist as appropriate.

On safekeeping and safety deposit boxes, we have called that out to ensure there is an understanding that there is a distinction between them. On safety deposit boxes, I ask the Deputy to imagine a wall of locked boxes, some of which are accessed daily and others which have not been accessed in a long time. Some of those are still subject to a fee. That is one aspect of it and that has been subject to a recent regulation, ISBAR, which came in under the fifth anti-money laundering, AML, directive, whereby the owner of all deposit boxes is now included on a register for AML purposes. Some work is being done in that regard, not in this context but some work has been done on safety deposit boxes. On safekeeping, I ask the Deputy to imagine a secure room that is lined with shelves with all manner of items in there. There are envelopes and the majority of items would be paper. There are suitcases, trunks and boxes, and the owners of all of these would be known but the majority of the items are paper.

On our sense of simplifying the Bill as it is currently drafted, indemnification is one piece and the removal of the need for a detailed register is another. The first step in the process should be the opening of the items and communication with customers to try to identify the owner. If an item is deemed to be of historical or cultural significance, that is when we believe a register would come into play in noting those items. If those have been passed on to the director and an assessment is carried out, depending on the director's assessment, either they would be held by the State or returned to the bank. That sales process that is currently in the Bill should be removed. That would simplify the Bill as it is drafted.

There are also concerns around the 80-year timeline. It poses challenges in understanding the most recent access to the items, and that is not always clear. It also presents a challenge in introducing an annual assessment. Items that come into that 80-year scope every year would have to be assessed. What we would consider might be worth the committee's consideration is whether the timeline should be removed to allow for a one-off project whereby all items would be opened and dealt with. Those are some comments on what Deputy Ó Cuív said.