Mr. John Palmer:

While the Deputy obviously would allow us time to review them, do an analysis on them and so forth, an initial reaction is that we should probably be welcoming both of these. One of the reasons is that we are not doing it on a level playing field and it will be a European-wide solution. That is a very important thing. As regards going beyond that, there would be concerns, particularly if we were to go it alone. There is always a concern about this. Are we erecting barriers to entry? Would some of the smaller PSPs say the Irish market is not there? We have to remember that the UK market is a much bigger market so it can compensate with its size for a lot of barriers to entry because there is still a viable business proposition. We are quite a small market so we have to be careful about that.

There are all sorts of other issues about competition. This is one of the areas where we would be very interested to see what the committee recommends. If it does recommend that there should be a full reimbursement scheme, would it apply to all PSPs or just the large banks? What would be the impact of that in terms of competition? If people know that if they go with one entity, they are going to get a refund if they make a mistake and become the victim of a fraud, then why would they go with one that would not give a refund? That is a serious competition issue that would have to be considered.

In terms of where we are going with this, as the Deputy knows, the national payments strategy which was recommended by the retail banking review last year is to be completed by 2024. The Department is working on that. The terms of reference were only published yesterday but they include a requirement for it to examine or analyse fraud on a domestic basis and see what measures can or should be taken to help to address that. In that context, as regards all the measures on whether we should do the confirmation ahead of time, that would be a very good place to look at this, and then the whole area of APP reimbursement is another issue. Does it stack up? Would it provide a valuable way to encourage banks to invest more money to stop the fraud, or is there a danger that it would in fact become a pull factor for fraudsters?

As the Deputy has highlighted, the UK has stronger regulation and it already has the voluntary reimbursement code, yet push payment fraud there, as I said, was about £440 million last year. According to the BPFI, push payment fraud is about €10 million here, as opposed to the Garda figures, which are basically for full economic crime, not for push payment fraud per se. Given the UK population is about 13 or 14 times bigger, we would be up at around €140 million. Can we explain the difference between the two? Is it just that the UK is a larger market and it attracts a lot more fraudsters, or are there any other factors? We have to think through all of that analysis and do a lot of research to decide whether it would make sense.