Mr. Gerry Cross:

I agree with much of what my colleague, Mr. Gilvarry, said. I will add a couple of thoughts. The Central Bank approaches this matter very much from a regulatory and supervisory perspective. We have stated we are very strong supporters of the objective of creating a capital markets union. The idea of enhanced sources of funding, investment opportunities and diversification funding are highly valuable. The first question we ask, which is the same as the question being asked by the Department, is whether it is necessary to do what is proposed to achieve these objectives. In many respects, as Mr. Gilvarry stated, some of the examples of convergence, even in the past few months, are quite striking, in particular, what the European Securities and Markets Authority, ESMA, has done around Brexit. ESMA established a supervisory co-ordination network which has significant oversight of how some of these decisions are being made.

Deputy Doherty asked whether we are concerned about the establishment of the board or the powers it would have. To take one example of these powers, the three-year strategic supervisory plan, we are very much concerned that we may somehow end up with an inconsistent allocation of powers and responsibilities. The Central Bank has responsibility for supervision in the context of Ireland, accountability to the Oireachtas and securing financial stability and consumer protection in Ireland as well as in the European context. This becomes complicated and potentially conflicted if the plan we have to follow is set at the European level and we have to stick closely to it and be assessed on it. One of the concerns that we have, which we also observe in the discussion on funds authorisation, is about different allocation of responsibilities between the national and European authorities in respect of approvals around third country delegations. Across the piece, what concerns us is the risk of fragmentation and inconsistency of approach which may ultimately result in a divergence between powers and responsibilities.