Ms Annmarie O'Connor:

We are concerned that an appropriate balance will be achieved. At present, we are not clear that it will be achieved. Anybody who has perused the heads of the Bill would agree that the emphasis is on the regulatory and governance regimes. It is not evident to us that the social ethos of credit unions is adequately addressed within the heads. On that basis, we have raised the various issues to which our submission refers. In the context of our dealings with banks and credit unions, we are obviously dealing with a large number of distressed borrowers at present. We have a debt management protocol in place in respect of voluntary arrangements. We have been involved in working with members of the Irish Banking Federation, IBF, on this in recent years. We have now extended this protocol to the utilities. We are in discussions with the credit union movement at present with regard to putting in place a similar protocol in respect of its members. This would mean that we would have arrangements in place with 70% to 80% of all of the creditors with which we work. That is all concerned with non-judicial voluntary settlements.

The proposed insolvency legislation will have an impact on a cohort of our client group. However, there will be many others who will still wish to seek to have voluntary arrangements put in place. It is critical, therefore, that we have very effective relationships with all the major creditor groups because this is essential in the context of the work we do. We cannot do our work in the absence of such relationships. The protocol we have already put in place has been quite successful in improving our day-to-day working relationships with major creditor groups.