Mr. Oliver Gilvarry:

If I could take the Deputy back a bit, what the banking review basically said was that as of the end of December, taking account of the planned exits, access to cash was reasonable. That was backed up by ECB surveys and stuff as well that showed approximately 90% of the population found it very or fairly easy to access cash. The purpose of the criterion of the 10 km is not to say that an individual has to be within 10 km; it is saying that for a region, on average, 99% of the population have to be within 10 km. When creating this legislation, the first step was to preserve and hold what we have as of December 2022. The Department of Finance has to come up with objective criteria that will drive that and we are confident that will do that. It is entirely reasonable to suspect that there are some existing local deficiencies and provision has been made for them to be addressed but we are also thinking for the future. The Deputy gave the example there and it is highly likely that further ATMs will be withdrawn, that bank branches potentially will close and that is when we will start to see local deficiencies come to the fore. It will be where certain levels of the population that used to be within ten or 20 minutes of an ATM suddenly find themselves facing a round trip of 30, 40 or 50 minutes. We see this as being independent of the 10 km criterion because it is clearly stating that within a region, if there are particular difficulties in accessing an ATM or indeed in the ability to lodge, you then will be able to make a complaint to the bank or a submission to the bank and the bank can then assess whether there is a potential local deficiency and then go on to the next level, which is where an investigator examines the situation and then it can determine whether to order a remedy. We do not see this as an exceptional measure. It would be an important part of the framework, as Mr. Palmer outlined.

The aim of this legislation is to manage the change in cash. We saw a massive drop during Covid followed by a slower drop and then a stabilisation. This is an important pillar of that framework that we have that macro framework. To be honest we have to have those criteria of 10 km and 100,000 people for the designated entities to know what the rules of the game are but also to have that further protection that ensures people have the ability to access cash for all of the reasons we outlined in the opening statement such as for financial inclusion, the importance that that has for people budgeting and others that they can actually get there. It is not that it would be exceptional. The case is there and as Mr. Palmer said, as things change we need to have that framework there. It is equally as important as the more macro part.