Mr. T.J. Flanagan:

In general terms, we totally welcome the process. We want to commend the Department on the huge amount work that it has done. We have been calling for this for 40 years. It got stuck in over the past couple of years. Unfortunately, Covid probably interrupted the personnel in question. We appreciate that they have been extraordinarily helpful and open. We totally appreciate what they are trying to achieve, which is make the co-operative model more modern, inclusive and attractive and to simplify it in many respects.

Unfortunately, one side effect brought about by a couple of the measures that we are not happy with have the effect of impeding one of the key principles in the International Cooperative Alliance, which is independence and autonomy, and the autonomy of a co-operative to set its own rules around how it changes its rules in terms of rule amendment thresholds and such matters. There is a little bit of a heavy hand on the special rule amendments, the regulation around mergers, etc., and the piece around the legal reserve. We think they are just a little bit heavy-handed. However, in general terms, we welcome the work.