Tommy Broughan (Dublin North East, Labour) | Oireachtas source

I support the comments made by Deputy Doherty. It would be a valuable asset to the credit union movement if such a clear memorandum of understanding were provided for in this legislation. Such memorandums of understanding would be agreed in consultation with the credit unions, representative bodies and the banks.

We are moving into a markedly different regulatory environment with new onerous obligations on credit unions. It is critical that this communication channel between the credit unions, representatives bodies and the bank would be clear, with no possibility of misunderstanding. The concern remains that misunderstandings may arise in the future if written instructions are sent to the credit unions from the Central Bank through their representative bodies and the unions, which abruptly introduce new regulatory conditions. The provision of a general channel of communication, namely, the memorandum of understanding, would be of assistance.

I agree with Deputy Doherty that the Minister is knowledgeable about memorandums of understanding given he is party to one, on behalf of the country, with the troika. We are now heading into our third horrendous year of that memorandum of understanding. The Minister will, therefore, at least understand the reason it is important it is clearly written down in a memorandum of understanding exactly what is required of both parties. This request from the credit union movement is a reasonable one. Also, I believe the Bill should make provision for the regulatory impact analysis to which I referred in my opening contribution on Report Stage. The changes that are coming in terms of new structures, officerships and costs for the credit union movement generally, must be explored by the Central Bank in close consultation with credit unions so that there can be no misunderstanding or belief that it is a one-way channel of diktats from the Central Bank to the smallest financial institutions in the State.

I ask that the Minister give serious consideration to adopting amendment No. 46 and tabling it for for debate in the Seanad, following which we can discuss it further when the Bill comes back to this House.

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