Marian Harkin (Sligo-Leitrim, Independent)
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160. To ask the Minister for Finance the number of full-time equivalents working in the Registry of Credit Unions of the Central Bank of Ireland in each of the years 2011 to 2024, in tabular form. [30569/24]

Jack Chambers (Dublin West, Fianna Fail)
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The figures for Full Time Equivalents (FTE) staff in the Registry of Credit Unions (the Registry) in each of the years 2011 to 2024 are set out below.

In complement to the FTE staff listed above, the Registry has access, when needed, to resources in specialist areas across the Central Bank such as analytics and IT, as well as support from other Divisions including the Legal Division and Enforcement Division.

Marian Harkin (Sligo-Leitrim, Independent)
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161. To ask the Minister for Finance his views on the disincentive for credit unions to hold Government debt, as the reserve requirements in regulation 4(1) of Central Bank Statutory Instrument No. 1 of 2016 applies to Irish Government debt, but retail banks holding government debt is risk weighted at zero, as per article 114(4) of regulation No. 575 of 2013 (Capital Requirements Regulation). [30570/24]

Jack Chambers (Dublin West, Fianna Fail)
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Credit unions are subject to minimum regulatory reserve requirements under Section 45 of the Credit Union Act, 1997 (the 1997 Act) and the Credit Union Act 1997 (Regulatory Requirements) 2016 (the 2016 Regulations). Regulation 4(1) of the 2016 Regulations provides that:

Subject to paragraph (2), a credit union shall establish and maintain a minimum regulatory reserve requirement of at least 10 per cent of the assets of the credit union.

The reserve requirement for credit unions is calculated on a non-risk weighted, leverage ratio basis. This is a reflection of a number of factors including: available sources of reserves (retained earnings only); the need for individual credit unions to have the capacity to absorb potential losses in absolute terms and the non-complex business model currently operated by Irish credit unions.

Credit unions are not subject to additional capital buffer requirements, such as the Countercyclical Capital Buffer, that would typically apply as part of a risk weighted capital approach.

In the recently published ICURN Peer Review Report the Central Bank note that it remains "of the view that there is no rationale to change to a risk weighted approach (to potentially include various capital buffers, such as a countercyclical capital buffer) given the current asset mix of Irish credit unions, the nature of the business model and indeed the costs associated with implementation for credit unions".

Credit unions are expected to operate with a level of reserves above the 10% regulatory reserve requirement. It is for the board of directors of each credit union to decide on the amount of reserves to hold in excess of the minimum requirement having taken prudent account of the scale and complexity of the credit union’s business, risk profile and prevailing market conditions.

Overall the average total realised reserves (including regulatory reserves) held by credit unions at 31 March 2024 amounted to 16.3% of total assets.

The investment decisions made by a credit union are determined by a range of factors including but not limited to; return, risk, term. The reserve regulation 4(1) of Central Bank Statutory Instrument No. 1 of 2016 acts as neither an incentive, or disincentive to this independent decision making process.