Oireachtas Joint and Select Committees
Thursday, 20 December 2012
Joint Oireachtas Committee on Finance, Public Expenditure and Reform
Scrutiny of EU Legislative Proposals
I call the meeting to order to discuss scrutiny of EU legislative proposals, COM (2012) 510 final, COM (2012) 511 final and COM (2012) 512 final on European banking union. I welcome Mr. Aidan Carrigan, Mr. Pat Casey, Mr. Kevin Nolan and Mr. Liam Morris from the Department of Finance and Ms Mary Burke, head of prudential policy supervision in the Central Bank of Ireland. The format of the meeting will be as follows. Mr. Carrigan will make some opening remarks which will be followed by a question and answer session.
I wish to advise the witnesses that by virtue of section 17(2)(l) of the Defamation Act 2009, witnesses are protected by absolute privilege in respect of the evidence they are to give to this committee. If they are directed by it to cease giving evidence on a particular matter and continue to so do, they are entitled thereafter only to qualified privilege in respect of their evidence. They are directed that only evidence connected with the subject matter of these proceedings is to be given and asked to respect the parliamentary practice to the effect that, where possible, they should not criticise or make charges against a person or persons or an entity by name or in such a way as to make him, her or it identifiable. Members are reminded of the long-standing ruling of the Chair to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official by name or in such a way as to make him or her identifiable. I invite Mr. Carrigan to make his opening comments.
Mr. Aidan Carrigan:
I thank the Chairman and the committee for the invitation to brief it today on the European Commission's legislative proposals to bring about a single supervisory mechanism, which constitutes a key element of the proposed banking union for Europe. I am accompanied today by colleagues from the Department of Finance and the Central Bank.
As the committee is aware, the single supervisory mechanism constitutes two regulations which were published by the European Commission on 12 September 2012. Taken together, the regulations will introduce the first stage of the banking union, the single supervisory mechanism, SSM. The remaining elements are the completion of CRD IV – the Basel III capital requirements for banks, the common deposit insurance and a common resolution framework, to which I will return later.
The two proposals before the committee which we are discussing today are a proposal for a Council regulation conferring specific tasks on the European Central Bank concerning policies relating to the prudential supervision of credit institutions - the ECB proposal; and a proposal for a regulation of the European Parliament and the Council amending Regulation (EC) No.1093/2010 establishing a European supervisory authority - the European Banking Authority - the EBA proposal. The Commission also issued a communication to the European Parliament and the Council, A Roadmap towards a Banking Union (COM 510) on 12 September. The communication sets the single supervisory mechanism in context and indicates further work towards a banking union beyond these first proposals.
The ECB proposal aims to introduce a new single supervisory mechanism, SSM, within which the ECB and national competent authorities, NCAs, will co-operate. Under the proposal, the ECB will have responsibility for the supervision of credit institutions in the euro-area member states and, with a view to maintaining and deepening the Internal Market, member states whose currencies are not the euro will have the right to opt into the SSM. The EBA proposal aims to introduce the necessary changes to the 2010 EBA regulation in order to ensure decision-making structures continue to be balanced and effective and preserve the interests of all its members. That will assist in avoiding fragmentation of the Internal Market following the establishment of the SSM. The banking union will be complete when the single supervisory mechanism is joined with European bank resolution and deposit guarantee mechanisms. The completion of CRD IV will be also an important element in that regard.
I propose to take a few minutes to set out the main elements of the ECB regulation under the proposal as published by the Commission in September, which is the subject matter of today's discussion. The main elements were the conferral on the ECB of specific tasks and policies relating to the prudential supervision of all euro area credit institutions.
The main elements were, as follows. The conferral on the ECB of specific tasks and policies relating to the prudential supervision of all euro area credit institutions. The ECB would have exclusive competence for a list of prudential supervisory tasks, including authorisation and licensing. The ECB, with the support of the national supervisors, would form the single supervisory mechanism. National supervisors would assist the ECB and comply with its instructions. National supervisors would remain responsible for supervisory tasks not transferred to the ECB, such as supervision of third country branches, supervision of payment services, on-site verifications, implementing guidance or regulations issued by the ECB, and anti-money laundering prevention. It would have explicit and significant responsibility to safeguard financial stability in the EU. The ECB would be responsible for co-ordinating the position of the competent authorities of participating member states in EBA decision-making contexts. There would be a full separation between the ECB's role in monetary policy and the exercise of supervisory functions. A supervisory board encompassing the specific expertise of national supervisors would be set up to achieve this. The ECB governing council would remain ultimately responsible for supervisory decision-making, with the supervisory board carrying out clearly defined tasks and related decisions. Any non-euro area member state and the ECB could enter into close co-operation. The ECB would then carry out its supervisory tasks in relation to credit institutions established in that non-euro member state. The ECB would be required to act independently in carrying out supervisory functions. It would be accountable to the EU Parliament and to the Council. While the ECB would start supervisory tasks as soon as possible, implementation would be on a phased-in basis.
Accompanying the ECB regulation was the EBA regulation, which is the second element of the single supervisory mechanism proposals. It is the proposed regulation amending the existing regulation establishing the European Banking Authority.
From January 2011, the regulation of financial services across Europe has been overseen by the European Supervisory Authorities, ESAs. There are three European supervisory authorities: the European Banking Authority, EBA; the European Securities and Markets Authority, ESMA; and the European Insurance and Occupational Pensions Authority, EIOPA. The EBA is the regulatory agency tasked with improving co-operation between national supervisors and continuing the development of a single rule-book for financial services in the EU.
The main amendments to the EBA regulation under the Commission's proposal, as published in September, were as follows. In imposing a binding decision to resolve disagreement between supervisors or to require action in an emergency situation, the EBA could request the ECB to follow its decision but could not require the ECB to do so. Where the ECB did not comply, it would have to provide adequate justification for non-compliance. There would be given to an independent panel dealing with the EBA, powers concerning breaches of EU law and the settlement of disagreements between national supervisors. It was proposed that a three-person panel would be required to include at least one member from a non-participating member state. The EBA management board would be required to include at least two representatives from member states not participating in the single supervisory mechanism. EBA voting on decisions relating to regulatory matters would continue to be based on qualified majority voting but with certain safeguards for non-euro member states.
That is a description of the proposal as presented in September.
Following the publication of the proposals, the European Council set up an ad hoc working party. In view of the importance of the proposals and their complexity, officials and experts from each member state came together to examine the proposals. The ad hoc working party met eight times between late September and early December. The negotiations allowed the Presidency to submit to ECOFIN ministers compromise draft texts on both regulations for final political agreement. The committee might note that, judging by the way the Council works, this was an exceptional measure. It involved a considerable commitment to these regulations and reflected the priority given at EU level to drawing a conclusion as soon as possible.
Arising from the work of that group, on 12 December, ECOFIN finance ministers reached a Council general agreement on the ECB and EBA regulations. As part of the council deliberations the text was amended to take on board the concerns of member states, so there has been considerable amendment to the original proposals as I have just outlined.
As EU President from 1 January, Ireland will now be tasked to represent the Council position in trialogue negotiations with the European Parliament. I will now briefly describe the current agreed proposal by the ECOFIN ministers.
Chapter I, articles 1 and 2, deals with subject matter, scope, and definitions. Chapter II deals with co-operation and tasks, and comprises articles 3 to 7. These are some of the important provisions of the regulation. Article 3 ensures the ECB and national supervisors co-operate closely in pursuit of high supervisory standards and that the ECB co-operates with the European Financial Stability Facility, EFSF, and the European Stability Mechanism, ESM. Article 4 provides for the tasks conferred on the ECB. Article 5 establishes the criteria by which the ECB will determine which credit institutions it will supervise directly and those where it will rely on national supervisors to implement the supervisory guidelines and instructions of the ECB.
The criteria for this assessment are based on an assets on balance-sheet threshold of €30 billion or an assets-to-GDP ratio of 20%. It is important to keep in mind that the ECB will exercise oversight over the functioning of the entire system and will retain the right to intervene to supervise directly any credit institution in any participating member state where it considers it to be necessary.
Article 6 provides for non euro-area member states to enter into a close co-operation with the ECB to join the SSM. It provides for circumstances where one of these objects to a decision of the governing council of the ECB. Chapter III deals with powers of the ECB, and comprises articles 8 to 15. The ECB can, within the SSM, direct national supervisors to take action.
Under article 9, the ECB has rights to information from legal and natural persons, and provides for the sharing of this information with the national supervisors. The ECB, supported by national supervisors, as the case may be, can conduct on-site investigations. Article 13 provides for specific powers relating to authorisations and article 15 allows for the ECB to issue administrative sanctions.
Chapter IV deals with organisational principles and comprises articles 16 to 25. Article 16 confirms the independence of the ECB and the supervisory board. Article 17 makes the ECB accountable to the European Parliament and to the Council. Significantly, it includes a separate provision allowing for national parliaments to ask questions of the ECB and to invite the chair of the supervisory board to participate in an exchange of views. National supervisors will continue to be accountable to national parliaments. Furthermore, article 17 requires the ECB to prepare reports on the execution of tasks under the regulation. Article 18 ensures the operation of ECB monetary policy is separate from supervisory policy.
The supervisory board of the SSM is created under article 19. It will be composed of members of the ECB and the national competent authority from each participating member state. In most cases, the supervisory board will take decisions on the basis of one member, one vote. A steering committee of the supervisory board will be appointed on a rotational basis to support the work of the supervisory board. Article 24 allows the ECB to levy fees on the supervised entities in relation to the costs incurred by it in the operation of tasks conferred upon the ECB by the regulation.
Chapter V deals with general and final provisions, and comprises articles 26 to 28. The ECB will assume its full tasks under the regulation on 1 March 2014, or 12 months from the date the regulation enters into force. In the transitional period from when the regulation enters into force and the ECB assumes its full tasks, the ECB is required to prepare a quarterly report on the implementation of the regulation for the European Parliament, the Council and the Commission. During this transitional period, the ECB will retain the right to assume the supervision of any credit institution in a participating member state where it considers it necessary, or if the ESM requests that it do so, as a precondition for direct recapitalisation by the ESM.
Article 26 provides for a review at the end of 2015, which will be repeated every three years thereafter.
As regards the EBA amending regulation, the main change from September is that additional safeguards are given to member states who are not participating in the SSM in relation to decision making in the EBA. Decisions on regulatory matters will continue to be made by qualified majority voting, QMV. However, it will have an additional safeguard in that decisions will be deemed adopted only if they are supported by a simple majority of member states participating in the SSM and a simple majority of non-participating member states.
When decisions are taking on a breach of law or binding mediation, an independent panel will be established to prepare the relevant decisions. Each such panel will consist of a chairperson, three representatives from participating member states and three representatives from non-participating member states. Decisions of a panel will be taken by simple majority. Where a panel proposes a decision to the board of supervisors, the board will adopt it by a simple majority of participating member states and a simple majority of non-participating member states.
The SSM is the first element of the package of banking union measures. It is necessary to conclude as a matter of priority discussions on the remaining elements. The December European Council conclusions call on co-legislators to agree proposals for a recovery and resolution directive and deposit guarantee scheme prior to June 2013. A more harmonised deposit guarantee mechanism would contribute to a more complete banking union. Its absence has increased the cost of bank failures to taxpayers and complicated their handling. The Commission's recent proposals on a bank recovery and resolution mechanism represent an important first step towards an efficient, financially sound, Europe-wide bank resolution regime. They aim to provide a harmonised toolbox at EU level. To overcome the challenges surrounding the orderly resolution of cross-border institutions an independent resolution authority will be required to exercise independently the bank resolution function across the eurozone. Heads of state and the Commission have indicated their commitment to bring forward proposals on such a resolution function mechanism.
Members will be aware that the capital requirements regulations and directive are currently under discussion in the trilogue negotiations in the Commission and European Parliament. The package known as CRD4 aims to strengthen the effectiveness of the regulation of credit institutions and investment firms and to enhance financial stability. The proposals aim to transpose the agreement reached by the Basel committee on banking supervision as endorsed by G20 leaders. Ireland has taken over from the Cypriot Presidency of the EU and it is our intention to complete negotiations under this file. We have commenced initial discussions with Council, Parliament and the Commission and early indications are that all parties will enhance their co-operation with a view to reaching an early agreement with the European Parliament. CRD4 is seen as important to a single supervisory mechanism which provides common standards to be applied across the single supervisory mechanism area. Under the EBA proposal the Presidency has commenced trilogue negotiations with the European Parliament. The ECB proposal will be decided according to the procedure set out in Article 127(6) of the Treaty which requires consultation with the European Parliament only, however both regulations will be considered as a package in the negotiations with that body.
Ireland's Presidency will give priority to the banking union package to ensure the remaining pillars, CRD4 and harmonised resolution and deposit are put in place as soon as possible to complement the single supervisory mechanism. As President of the Council, Ireland will be required to reflect the views of all member states in concluding negotiations and will act as an honest broker while having due regard to national considerations. I am happy to take questions or clarify anything.
It has been a busy day and, indeed, week and we will not detain the witnesses long. There are two proposals before the joint committee. There is a proposal for a Council regulation conferring specific tasks on the European Central Bank which is known as "the ECB proposal" and there is a proposed amendment to regulation 1093/2010 establishing European supervisory authority on banking. What is the relationship between the proposals and how will they function side by side?
Mr. Aidan Carrigan:
Proposing a single supervisory mechanism across 17 member states raised a concern at EU level that the banking authority balance which had existed across 27 member states with 27 different positions would be upset. Those not in the single mechanism were concerned that there would not be a voting block of 17 member states which could consistently outvote those outside. It was important therefore to amend the European banking authority voting modalities to achieve a more balanced voting arrangement between those inside and those outside the mechanism.
Mr. Aidan Carrigan:
The ECB is to take over responsibility for the prudential supervision of all banks within the eurozone. Much of the discussion in the negotiations centred on the fact that the Council decision said there should be differentiated supervision whereby the ECB would take a direct, hands-on interest in day-to-day supervision in some institutions while relying on national competent authorities to supervise the smaller institutions of which there are some 6,000 to 7,000 across Europe. That would all take place within a single supervisory mechanism.
Mr. Aidan Carrigan:
I would not put a figure on it but we are talking about several hundreds of larger institutions. As I highlighted in my opening statement, the text includes thresholds of €30 billion in assets or 20% of GDP of the relevant member state. Banks large enough to exceed those thresholds will be taken into direct day-to-day supervision by the ECB. Banks below the threshold will continue to be supervised day-to-day by local competent authorities under the oversight of the ECB and within its general guidelines and rules. Provision is also being made to ensure that at least three banks in each eurozone state will be supervised directly by the ECB.
Mr. Aidan Carrigan:
The thresholds are clear, but the regulation provides that the ECB must bring forward methodologies on their application and tease out the detail of how to identify specific banks to supervise. Based on the criteria, it is likely the two pillar banks in Ireland will fall under direct supervision. It is a matter to be determined based on a methodology yet to be established by the ECB. The ECB will take over supervision in March 2014. As of today, the banks may meet the criteria, but we will see what happens in future.
I realise Mr. Carrigan is not a member of the European Council, but can he tell me what will change when this system is implemented? What will happen when a major bank gets into severe difficulties of the type which have wrecked our economy, the upshot of which has been to place the burden on the working class and taxpayers by way of massive austerity. Old debt has been replaced by new debt which has in turn been placed on the shoulders of taxpayers. Will the same principles apply?
Mr. Aidan Carrigan:
As I pointed out in my statement, this is a first and most important step towards achieving an integrated banking union across Europe. These provisions deal with consolidating the supervision function to the ECB. That should contribute to improved financial stability across Europe, greater confidence in the markets, better functioning banks that will lend to each other and operate across borders in a way that they have not done because there was no cross-border trust. If there is a single supervisor applying clearly defined standards across the area it will generate confidence in the banking union which is an important first step. The December statement of the Heads of State has made very clear that this initial step on supervision must be complemented by further measures in respect of a co-ordinated resolution mechanism and deposit guarantee scheme. The improved dealing with bank failures will take place in the context of that resolution mechanism and deposit guarantee scheme.
Will this in any way change the predatory nature of these major European banks which historically speculated widely in Irish property and landed us in this crisis and insisted that our people pay? Will they continue to look around for new sources of speculation in whatever area to maximise profits for their private shareholders etc.? Are there any implications for their behaviour within the capitalist marketplace?
In practical terms, the ECB will be the supervisory authority for the entire banking system at two levels, the heavy and the lower artillery levels of banks within the Eurozone. Will there be harmonisation of how assets and liabilities are treated in the balance sheets of these banks because that will determine the risks?
Mr. Aidan Carrigan:
Single supervision must be complemented by a single rule book across Europe to make sure the same rules are applied in calculating risks, risk weightings and asset values. A key role of the European Banking Authority is to bring forward a single rule book for all 27 Members on how to calculate assets etc. The capital requirements directive is also setting new standards of governance to be met by banks across Europe. Between the single rule book of the EBA and the directive it is anticipated that the single supervisory mechanism will apply clearly defined consistent standards across Europe.
Is it correct to say the EBA is the one that has the rules for accounting, reporting, all the measurements or calibrations that banks operate and the ECB is the supervisory or structural authority which makes the assumption that the EBA rules are being complied with and can test them?
Ms Mary Burke:
I should add that some of the rules and regulations come directly from the European legislature by virtue of regulations. The capital requirements directive is complemented by a regulation. It is not simply the case that the EBA comes up with the rules but it will develop binding technical standards.
Ms Mary Burke:
The trialogue is used in a different context. Mr. Carrigan was talking in terms of the co-decision mechanism in Brussels. The Deputy is right, however, the ECB will supervise the banks to try to ensure the rules are being implemented and to take action if not. The rules are developed either by the European legislature or by the EBA.
Are we sure and confident that the framework for all of this is secure and that all the nuts and bolts are correct? I find it quite a job to read this type of stuff about article this and sub-section that and all the interlocking engineering of the thing.
Mr. Aidan Carrigan:
I appreciate that it was not an easy read and I was conscious of that when we were presenting the opening statement but the onus was to put on the table the facts as in the document and to introduce them to the committee. It has been a very complicated discussion and it is a complicated text and issue. The Deputy is right in saying the single supervisory mechanism is only one part of the key architecture which is made up of European regulations which are directly applied law, European directives which are transposed law, and European rules and technical standards which are developed by the European Banking Authority consistent with that law. Within that there is a comprehensive framework of rules to be applied consistently across Europe by a single supervisor.
Do we have the management power, the brain power and the character power to ensure this framework of prudential rules and regulations and road maps for banks within the Euro system? Do we have people who will be independent, and not going in and out of institutions, and who will have the character to be courageous if they see something going wrong, or if there is a weakness in the system, to investigate and prosecute? I do not mean prosecute in the legal sense but to say there is a weakness here and we must address it no matter how uncomfortable that is or how powerful the bank is. For instance, Mr. Carrigan is probably aware of the recent SEC revelations about Deutsche Bank's accounting fraud of possibly up to €12 billion.
Mr. Aidan Carrigan:
That is the assumption we are now making. Mr. Draghi has made it very clear that he feels the ECB is up to performing this task. This will not be simply a body emerging out of nowhere. It will draw on the existing central banks across Europe and national regulators bringing them to the centre to fill some roles and working very closely with the existing national authorities. The assumption is that the necessary skills will exist.
Mr. Aidan Carrigan:
We have had that debate in a national context as well as in connection with the ECB and the response is that there will be parliamentary oversight of this ECB supervisor. The text, which was agreed at Council level, provides clearly that the supervisor will report to the European Parliament as a European institution under European law and will also report to Council. In the negotiation the Council members provided a specific requirement for a report to national parliaments because the actions of the European Central Bank will have a national impact. The oversight will be at parliamentary and Council levels.
The worry would be that at the parliamentary level of oversight or sentinel supervision there would be a lack of competence and capability to ask the tough questions. That is a worry that should be addressed in the conversations at European level. Now is the time to ask the tough questions.
I appreciate that it is quite complicated and there seems to be a problem in co-ordinating the different elements of the European Union's architecture between the ECB, the Parliament, the Commission and so on, and perhaps that explains its complexity. In order to understand it, may I ask the following questions? Is it basically the case that the Parliament writes the rule book, the supervisory mechanism is provided by a smaller group of states, are they the eurozone states?
Mr. Aidan Carrigan:
I sympathise with the Deputy grappling with the detail of this as it is very complex. A number of European institutions have overlapping roles.
The decision making process at Europe is a co-decision between the Council and the Parliament. That is the trialogue process that brings together the Commission, the Council and the Parliament. It is the Commission, the Council and the Parliament, that trialogue, that will finally put in place the regulations and the law which will define how this new European Central Bank Supervisory Authority operates. The Supervisory Authority will take over day-to-day supervision on a consistent manner for all of the larger banks across Europe and a number of banks in each country. The Supervisory Authority will be accountable to the Parliament and to the Council for the way they do that. The Supervisory Authority within the ECB has not been created out of nothing. There is an actual supervisory board that will be running this, which is made up of the head of regulation of every supervisor in every member state that is involved. It is bringing together all the national expertise into this one entity.
Is it correct that the supervisor will be accountable to us? If we want to ask questions about what is going on, do we quiz our delegate or representative on the single supervisory mechanism, SSM; board?
Mr. Aidan Carrigan:
The legislation had to be delicately drafted around this because as a European institution, it can be accountable only to the European Parliament and the European Council. Within the provisions, it is quite clear that national parliaments can ask questions of this body and the ECB has made it very clear in its commitment to Council that questions put to the body will be dealt with. If national authorities ask questions they will get replies and explanations. There is provision for any of the national authorities to seek to meet a member of the supervisory board, which we would expect to be the national member of the supervisory board and to ask questions of that person as well.
I understand the participating countries will be fewer than the entire EU membership, where does Great Britain stand on this? We had some meetings with their finance committee and some colourful characters on that committee would have a particular view, the Rt. hon. Paul Beresford has a particular view of where this is going. Has the UK signed up to this Supervisory Authority?
Mr. Aidan Carrigan:
As this is structured, all ten non-eurozone members have an option to opt in. In Ireland's approach, we were very keen to make it as attractive as possible for non-eurozone members to opt in and the text has been structured in that way to try to facilitate as wide an application of the single mechanism across Europe.
To answer the Chairman's specific question, from the outset the United Kingdom has made it very clear that it sees this as a very good development for Europe but that it will not be participating in it and it would prefer to continue with its sole supervisory arrangements.
Foreign banks such as Ulster Bank, Bank of Scotland, Danske Bank and other European banks operate in the Irish market. Could we have banks operating in the Irish market that are being supervised and others that are not part of the supervisory process?
This will have massive structural aspects for the Central Bank and for the Department of Finance when it is rolled out. In terms of the banks that are being wound up, is there a possibility that IBRC could be under the supervision of the SSM board?
Mr. Aidan Carrigan:
The legislation does not anticipate every particular eventuality. The situation of IBRC is unique. As I mentioned, the methodology on the application of the threshold is to be developed by the ECB and that must be done by June 2013. We would expect that when the methodology is clearer, the detail of its application to things such as wind down banks will be somewhat clearer.
I thank Mr. Carrigan for helping us get the structure clear in our heads. To what extent is the rule book written? Will it be possible for us to see the rule book which will then be applied by the supervisory mechanism? Will the rule book be in a fairly clearly understandable form?
We are talking in terms of architecture and engineering of the supervisory structure, but then of course policy comes into play. One could have concerns, especially given my perception of the attitude of the ECB. I have made this point a number of times. At the beginning of 2008 the ECB issued a guideline to States and to Central Banks in which it states that if states needed to rescue banks, if possible they should avoid nationalisation but even if they nationalise them they should avoid diverting the goals of the bank from profit maximisation to other social goals. That is its directive because it believes that to be in the best interests of banking, but as some of the discussions we have had earlier today and much of the discussion between the Parliament and banks at present, we might have a very different view of that. We might think it would be a good thing if the banks took social and macro-economic goals more into account when deciding their policies. To put some of this into context, it would be useful for us to know what the rules are, how far-reaching they are.
Some of them are about the level of capitalisation, possibly risk management and so on, but how far reaching are they and will more rules be developed and, if so, will we see them in a clearly understandable form in order that we know what rules are being applied to the banks and then we can decide whether they are a good idea?
Mr. Aidan Carrigan:
Not the national parliaments. However, the national parliaments will have the right to put questions to the ECB supervisory authority and they will be responded to and the national parliament will be able to invite a representative of the Supervisory Authority to appear before the national parliament.
Ms Mary Burke:
I will answer that question as best I can. There is a rule book. At least some of the rule book is written. When Mr. Aidan Carrigan speaks about the fact that we are looking at CRD, he is referring to the capital requirements directive No. 4. By definition there were three previous directives, at present we are on the third version. As it is being expanded there will be more rules. Yes, one can see the rules to the extent that they are EU legislation, to the extent that the EBA issues rules, guidelines, standards, all of which are published. They go through a consultation process and are finalised and published. I cannot give a guarantee that they will be particularly user friendly, by their nature they are legalistic and technical but they are available. Further rules are being developed. Therefore, the area about which the Deputy inquired, which might be captured under bank resolution, for example, currently the CRD would not go that far but they are working on a resolution directive which, in my recollection of the outcome of the recent summit, was that they wanted that finalised in the first half of 2013. That is working on a basis of national resolution regimes. Any aspiration to a pan-European resolution regime is somewhat further out but it is one of the goals of banking union and is recognised both by the Heads of State and, I think, by Mr. Draghi, in some recent statement that is essential.
There is an analogy with architecture in a semi-state of construction. Perhaps I could make a request that in quarters one and two the witnesses come back and let us know how this is working out in terms of construction, whether we are at first joists stage, roof or wherever.
With that said, I thank the officials from the Department of Finance for the briefing. I do not believe there is any other business. As this is the final committee meeting of 2012, I avail of the opportunity to extend the season's greetings to everyone and wish you all the best for 2013. We have had a very busy 2012 and I certainly had since my arrival. I express my gratitude and appreciation for the co-operation received from members in the past. I understand 69 meetings were held during the year. I invite members to enjoy the break and we will try to get the number of meetings over the 70 mark next year.