Mr. Gerry Cross:

We approach this very much from the regulatory and supervisory perspectives. We ask whether it will work and where it will leave our regulatory objectives. I do not believe there are major divergences between where the Central Bank ends up and the Department's position but any divergences are probably on matters of gradation. There are some issues on which the Department probably has firm views and the Central Bank's position would be more agnostic, and vice versa. There is significant convergence on some of the main issues we have discussed today.

On the issue of the consumer protection mandate, the Central Bank raised this matter in its submission to the consultation on the ESAs in May. We considered that there was a gap in the sense that there was not a clear and consistent mandate for the ESAs in respect of consumer protection. It was not always the case that they could operate very well together across sectors. There were divergences and differences in definitions across different sectors and we called this out in our submission. To reply directly to the Deputy's question, we called for the establishment of a cross-sectoral committee with consumer protection responsibilities.

The Commission's proposals probably reflect a slightly different view of the issue. We believe they move in the right direction, call out more clearly the consumer protection mandate in the case of ESAs, and add to their mandates in terms of carrying out in-depth thematic reviews and developing risk indicators. The package goes in the right direction, although more could probably be done and it approaches the issue slightly differently from the way we suggested in our submission. It goes in a positive direction, however.