Oireachtas Joint and Select Committees

Tuesday, 28 November 2017

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach

Scrutiny of EU Legislative Proposals

7:15 pm

Mr. Pat Lardner:

There are different risks. That is fair, and that leads on to the point that Mr. Cross of the Central Bank of Ireland was making. Both the Financial Stability Board, established by the G20, and the International Organization of Securities Commissions, IOSCO, have looked at the question of whether there are systemic risks or vulnerabilities associated with the asset management industry, which is a part obviously of what we do. They have not seen it as systemically risky in the way that one might see other sectors, but they are focusing on particular issues. They focused on questions about the liquidity of funds. How liquid are they are if one needs to take one's money out? They examined the extent to which things like leverage might be used. Clearly, there are risks which are incorporated within global, European and local supervision, and that is where we participate very actively, to make sure we provide the information.

The Deputy's last point raised a question about the extent to which the proposals make our industry less competitive or otherwise. Our primary problem with some of these proposals is that the orderly function of the market is one of the responsibilities of the European Securities and Markets Authority, ESMA. We already have a functioning market. We do not see any evidence provided in the proposals that suggests there is a lack of function, or a problem requiring some of the changes required. That is our primary objective.

If some of these proposals come through there might be less choice for investors in Europe around product, which is a bad outcome. It would also not be as easy to provide access to European investors, which is one of the reasons companies decide to locate funds in Ireland and other places. That would have a detrimental impact. However, we are not, in our comments on this, separating the fact that it would disrupt what is already a functioning market, distort investor choice, reduce competition and increase costs in the absence of significant evidence otherwise. That is the basis for our approach to this particular issue. Anything which impacts on the European funds industry generally, given the growth rates outlined, clearly impacts on us as well.