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Dáil Éireann debate -
Wednesday, 11 Oct 1978

Vol. 308 No. 1

An Bille um Údarás na Gaeltachta, 1978: Ordú don Dara Céim. - Industrial and Provident Societies (Amendment) Bill, 1978: Second Stage.

I move "That the Bill be now read a Second Time."

The purpose of the Bill is threefold:

First, it will preclude industrial and provident societies, in the main, from accepting deposits and will introduce supplemental controls to be operated by the Registrar of Friendly Societies; second, it will create and formalise a system for the inspection and supervision of credit unions; and third, it will make some fundamental and badly needed amendments to industrial and provident society law generally and will extend the power already vested in me to exempt bodies corporate from the scope of the Moneylenders Acts, 1900 and 1933.

Industrial and provident societies are bodies corporate which may be formed for carrying on any industry, trade or business, including "the business of banking". The governing Act is the Industrial and Provident Socities Act, 1893 and its section 19 lays down the conditions which must be met by societies which carry on "the business of banking".

A quick glance at section 19, however reveals how inadequate these conditions are, in terms of acceptable banking controls in modern circumstances. There are, for example, no regulatory controls involved. Instead, the conditions laid down could be said to amount only to minor administrative inconvenience.

When the Central Bank Act was enacted in 1971, industrial and provident societies as a general class were exempted from its scope. Behind the exemption was the very meritorious consideration that the tradition of limited deposit-taking undertaken, from time to time, by some co-operatives, mostly in the agricultural and fisheries sectors, should not be interfered with. This way of raising funds often served to ease the acute problem of capital shortage experienced by those co-operatives.

Since then, however, the exemption has been shown to have been too generous in its scope. Its generality opened a door through which has emerged a new type of financial institution, namely, the "banking" industrial and provident society. The type of society I refer to is easily identified by its almost exclusive concentration on the business of accepting deposits from the public. Of such societies registered since 1971, 14 are still on the register. At the moment, there are before the Office of the Registrar of Friendly Societies applications for the registration of 19 new societies, the proposed rules of which would also permit a banking activity exclusively.

These statistics put the problem being dealt with in Part II of this Bill in very meaningful perspective. Through use of the exemption for societies which was written into the 1971 Act for an entirely different purpose, a fringe banking sector has evolved, the basis for which was never intended to be facilitated and the existence of which runs counter to the very philosophy which underlined the 1971 Act itself. And though they operate in direct daily competition with the conventional banking sector, the deposit-taking societies concerned enjoy complete freedom from the extensive framework of controls which are applied under the Act by the Central Bank. This means that investors in them are bereft of the safeguards which characterise a licensed banking institution.

It is against this background that I have on a number of occasions issued warnings to members of the investing public about the need for caution in placing their money in the care of deposit-taking societies of this kind. There was, and there still is, no suggestion that, in the main, those persons who manage the affairs of "banking" societies are not both conscientious and prudent. But because a "control vacuum" exists, I saw it as my clear responsibility to advise the public that attractively high interest rates alone should not determine investment decisions. More importantly, I promised urgent legislation to fill the "control vacuum". Part II of this Bill represents my proposals in this regard.

Before discussing these proposals I should like to deal with a general point which I anticipate Deputies may make. That is whether it would not have been simpler in dealing with this problem to amend appropriately the Central Bank Act, 1971—that is to say, to bring deposit-taking societies within its ambit—instead of formulating the elaborate provisions now contained in Part II. I wish that such a simple solution would do but it will not. As the societies concerned have developed outside the Central Bank's control, they could not, if brought immediately within the bank's domain, live up to its technical licensing requirements. One consequence, in that event, would be that the societies concerned would have to be stopped from taking in new deposits immediately. Such a final development could clearly lead to early difficulties, of a very serious nature, in some cases.

It is, therefore, with a view to avoiding the danger of exacerbating, straight away, an already difficult problem, that Part II of the Bill has been prepared in its present form. It will give some breathing space to the larger societies concerned, within which they can formulate a definite plan as to their future, in the light of the firm prohibitions now being placed on the future acceptance and holding by them of deposits.

Section 5 contains my specific proposals in this regard. It prevents the acceptance of deposits by any future societies and by existing ones which have not yet accepted deposits or have accepted some on a limited basis. At the same time it stamps a definite time limit of five years on both the acceptance and holding of deposits by the larger existing ones. Excluded from this embargo, of course, are those classes of society listed in section 4.

Underlying this approach is my belief that all banking activity—which means, in effect, the acceptance of deposits—should be subject to the Central Bank Act, 1971 unless there exists a special social emphasis to, or economic purpose behind, the acceptance of deposits in particular circumstances. Building societies already enjoy a special recognition in this regard. It is my opinion that only those classes of industrial and provident societies which are now proposed for exemption from Part II under section 4—namely, agricultural and fishery co-operatives, credit unions and a very limited number of societies which are analogous to the latter—have special characteristics as societies which justify the continued right to accept deposits as part of their normal activities.

Sections 4 and 5 of the Bill reflect this opening proposition. The supervisory controls vested subsequently in the Registrar of Friendly Societies, hinge around it. They are there to enable the registrar to monitor the structural changes in the businesses of existing deposit-taking societies which must follow upon the proposed cessation of the deposit-taking activity.

Broadly speaking, each society so affected will face the following three options on enactment of the Bill:

(a) First, it can gear itself towards applying for a banking licence from the Central Bank;

(b) Secondly, it can arrange alternative sources of finance, for example bank loans, to enable it to continue with its lending business, or

(c) Thirdly, it can arrange for an orderly running down of its business.

Whatever the course chosen by a society, however, the registrar is being given sufficient powers to enable him to maintain a watchful eye to see that the interests of investors are, as far as possible, taken full cognisance of by a society.

As regards the specific details of the controls, they are equivalent, in several instances, to the controls which the registrar already enjoys in relation to his supervision of the building society sector. There are a few exceptions, however.

Section 6 enables the registrar to regulate, in the main, the raising of funds by societies to which Part II applies. In framing this provision, I have been continuously conscious—in the light of the unforeseen consequence of the exemption of societies generally from the Central Bank Act, 1971—of the need to ensure now that whatever correction is made at this stage, is watertight. Section 6 must be seen in this light. It will assign to the registrar the function of determining whether or not a proposed method of raising funds by a society is contrary to either the interests of members or of the public. Notwithstanding the prohibition now being imposed on deposit taking, it would not be difficult for a society to switch to some other form of fund raising. It could, for example, invite lump investments on promises of attractive interest or dividends. Indeed, it is the very variety of ways in which funds could be raised that makes it so difficult to design legal controls to regulate each possible form. Section 6, therefore, both closes off any possible abuses in this area and, at the same time, constitutes a flexible mechanism of control which, we can be sure, will be operated by the registrar, particularly in so far as bona fide operations are concerned, according to the dictates of common sense and the common good.

Excluded from the scope of section 6 is the acceptance of deposits by existing societies, within the five years period that is, permitted by section 5 (2). This activity has been isolated for separate attention under section 10 which vests especially extensive regulatory powers in this area in the registrar. These powers are intended to ensure that within the time limit of five years, societies will proceed to operate in a fashion most consistent with the best interests of depositors.

I would draw particular attention also to section 15 which enables the registrar to appoint a person to the management committee of a society. There is no parallel with this in either banking or building society law. Behind it, too, is my paramount concern for investors. It could transpire, notwithstanding how detailed are the provisions contained in Part II of the Bill, that a society might decide on a future course of action which may not seem to serve the best interests of investors. Rather than invoking the formal and prolonged procedures of investigation or suspension, the registrar might see more merit in decisively intervening on behalf of the collective body of investors by appointing a person to a society's committee of management. Such a person would, on one hand, be privy to the society's plans in full and, on the other hand, be in a position to steer the society back on a course most consistent with the cause of investors. Should the society prove recalcitrant in this respect, however, the registrar could then employ the more direct powers available to him.

Part III of the Bill contains a scheme for the inspection and supervision of credit unions. I had considered the introduction of such a scheme by way of regulations under section 35 of the Credit Union Act, 1966, but, on balance, I have thought it best to give it direct statutory implementation in this Bill. While the provisions of the scheme are similar to many of the controls contained in Part II, they have the entirely progressive objective of ensuring, as best as possible, that future growth in the movement is matched with stability.

Too few people nowadays seem to realise how important is the contribution which credit unions makes as a source of national savings. In 1969 the total amount due to shareholders and depositors by credit unions was just over £6½million. By the end of 1976, which is the last year for which complete figures are available, the amounts so due had reached almost £40 million. Indications are that this pattern of growth will have been maintained in the last two years. This record of performance bears ample testimony to the application and commitment of the many people who have given generously of both their time and idealism to the practical application of the credit union system. It is a fact, however, that growth brings its own problems. The bigger the volume of money being handled by part-time people, the greater is the element of risk.

It is my desire now to try to minimise these risks. I hope Part III will be seen in this context. It vests the registrar with sufficient powers not only to monitor trends in the businesses of credit unions but to foresee any problem situations developing and to take any early corrective action that may be necessary. I am confident that the movement itself will, by and large, welcome this development.

Part IV is designed to introduce some few, but basic, general amendments to existing industrial and provident society law. For example, present accounting requirements for co-operatives generally are very inadequate. Sections 29 and 30 will update these to coincide with basic company requirements. The greatest beneficiaries from this change will be the members of the co-operatives who can now expect an acceptable level of disclosure and accountability. As the House knows, the agricultural co-operatives in particular are now major powers in the economy and the turnover of the larger societies now is in many instances greater than that of most of our larger manufacturing companies. It is, to say the least, anomalous that the requirements on these societies under the law in the matter of disclosure and accountability are much less demanding than what is required of even the most insignificant of limited companies.

I recognise, of course, that there is a need to up-date the general body of law dealing with industrial and provident societies and it is my intention to introduce such legislation as soon as circumstances permit. Meantime sections 29 and 30 will improve the situation where the need for such improvement is most urgently required, and this amendment, I am confident, will be welcomed by all concerned with the co-operative movement. Another change of substance in this Part is in section 33 which will permit me to prescribe different financial limits for different classes of societies. Because of the inherent differences in the nature of their business the capital requirements of agricultural co-operatives can be much more demanding than for, say, a credit union. Up to now, however, I could never reflect this in legal form because the present law only enables me to prescribe the same financial limits for all classes of societies. On presenting draft regulations some time ago to increase the previous limits, I indicated my intention, therefore, to amend the existing law to enable me to prescribe different limits for different classes of societies. This power is now being achieved by section 33.

Finally, section 36 of this Part will extend the power already vested in my office under the Moneylenders Act, 1900, to exempt bodies corporate from the scope of the Moneylenders Act 1900 and 1933. I have been advised that societies which, as part of their business activity, lend money, could be in breach of those Acts. While a society can apply individually in the form prescribed in the Moneylenders (Exemption of Bodies Corporate) Regulations, 1934, some have not done so, notwithstanding that the legal dangers inherent in their present position were brought to their attention. It is clearly necessary to remedy this undesirable situation. Section 36 will, accordingly, enable me to declare, by order, that a specified class or classes of industrial and provident societies are exempt from the Acts concerned. It will be my intention to give retrospective effect to any such orders in so far as is necessary to cover, in full, the period during which societies affected operated a lending business.

I recommend the Bill to the House. If its prime motive can be summarised, it is to protect, so far as possible, the savings of ordinary people. It does not, perhaps, amend enough of the many outdated provisions of existing industrial and provident society law. Such an extension, however, would be a substantial one which would take some considerable time to complete. I assure the House that it will be done as soon as priorities permit. But, for the present, the pressing need is to legislate to safeguard people's savings which is why I am proceeding with the separate and urgent consideration of this Bill.

I entirely accept on my own reading of the Bill that it tends to the object which the Minister has summarised at the end of his speech as being the protection of the savings of ordinary people. Naturally we will support anything of that sort. In the short time I have had, I have not been able to discover any objection by the co-operative movement generally to Part II of this Bill, the part which bears largely on them. As far as I can gather, it is generally supported.

The same is true of the part of the Bill which deals with the credit unions. I understand that in its main outline that part of the Bill was suggested by the credit unions themselves and that the Bill in both or all its parts has been cooking in the Department for some years before the Minister's arrival and at the time of his predecessor. Despite having had a short time to think about the Bill and to talk about it, I welcome it and in general support it. I understand that the credit unions wished the part of the Bill dealing with them to go a little further than it does and that they wished the power to accept deposits which credit unions now have to be entirely removed. When I have had a chance to explore that matter a bit further, I will probably ask the Minister to explain how it was that his Department decided against taking this additional step which the credit unions recommended.

I have only two brief comments; they could be regarded as comments of detail but they are fairly important, at least if there is any meat in them. I wish to mention them in the Minister's hearing so that his Department may look at them before Committee Stage. One of them relates to a word which occurs twice in the definition subsection of section 4 which has the effect of explaining what is meant by an agricultural co-operative society or a fishing co-operative society, both of which are excluded from the operation of the Bill. The purpose of the Bill is not to catch bona fide agricultural or fishery co-operatives but co-operatives which are such only in name as the word is ordinarily understood and which concentrate exclusively on business which could be described as banking. The word which catches my eye is “insubstantial” in the definition of an agricultural co-operative society and fishing co-operative society. The conditions which this subsection contains in order to exempt such co-operatives from the application of the Bill are cumulative, in other words an agricultural co-op means a society most of which is concerned with farming and so on and in which the acceptance of deposits and the making of loans constitute an insubstantial part of the business. These are cumulative conditions and that cumulation is repeated in the definition of a fishing co-operative. They are not alternatives. Both of these conditions have to be met if an agricultural or fishing co-operative is to be exempted. I wonder if the word “insubstantial” is felicitous or the best way of dealing with this attempt, which is a correct effort, to exclude genuine agricultural and fishing co-operatives.

We are dealing with something which can be quantified. It is not an operation which exists in abstraction or which does not relate to money. It relates purely to money and I would have thought that it would have been possible for the Minister to decide what portion of a business would render it subject to the applications of this Bill or exempt from the application, not merely leaving this decision to a registrar or a court. What do the Minister and his Department regard as "insubstantial"? If they have no clear idea about it, how can they expect a registrar or court to have a clear idea about it? The Minister and his Department ought to give some thought to the idea of quantifying in terms of money or proportion of turnover or proportion of assets what exactly they mean by "insubstantial". The effect of it will be the means of deciding whether an agricultural or fishing co-operative is to be caught by the Bill or not.

I remember being in a case when I was at the Bar which turned entirely on the meaning of the word "substantial" in a quite different setting in regard to workmen's compensation. I think it was the first case decided on an amending Act in which the question of substantial ground was at issue. A great deal of legal ingenuity was expended, though I think to a wrong result in the end, on what exactly was meant by the word "substantial". It looks like a solid, easily understood word but it can cause a good deal of difficulty and I should like the Minister and his Department to see whether that way of measuring exemptability could be improved.

I make my other point with diffidence because I have not had enough time to examine this and to be sure I am right about it. Perhaps one never can be sure that one is right but I am less sure than I normally am. The procedure in section 14 in regard to the investigation of the affairs of a society includes a provision in subsection 2 to the following effect:

If any officer, member, agent or servant of the society refuses to answer any question put to him by the inspector with respect to the affairs of the society, the inspector may certify the refusal under his hand to the Court and the Court may thereupon inquire into the case and, after hearing any witnesses who may be produced against or on behalf of the alleged offender and after hearing any statement which may be offered in defence, punish the offender in like manner as if he had been guilty of contempt of court.

At the beginning of the Bill "the Court" is defined as the High Court. At first blush that subsection is very like a sub-section in the Dáil Éireann Committee of Public Accounts Act of 1970 which was subsequently held to be invalid by the Supreme Court on a couple of grounds, one of which was that this formulation implied that the High Court could try the issue of contempt or of contempt-like behaviour without a jury, but that since the offence of contempt was not a minor offence and since the only kind of court which could punish a minor offence was one of summary jurisdiction which the High Court was not, the section was constitutionally invalid. I am not positively asserting that this subsection will fall into the same trap: I will have to look at it a bit more closely.

However, I should like to signal that possibility to the Minister's advisers and ask them to look at the Haughey case, reported in 1971 Irish Reports, to see whether they can be quite sure about this subsection, which refers to whether this would be an indictable offence which can be tried only by a jury or whether it identifies the High Court as the only court which can deal with such an offence, in other words, the High Court sitting without a jury. I should like the Minister's advisers to look at that to determine whether it is all right by the standards which the Supreme Court have laid down.

That is all I want to say on the Bill at this Stage. I hope the Minister will not want the Committee Stage to be taken before this day week at the earliest.

I welcome the Bill. It is overdue. It has been quite evident in the past five years that there has been an urgent need to enact such legislation. Quite properly, the Bill attempts, and it seems quite effective in its attempt, to close a questionable loophole in our deposit-holding controls. I regret it has taken such a long time to do this, but better now than never.

I am sure everyone in the House will agree that we do not want any questions raised about the possibility of a so-called fringe commercial banking operation emerging which would be unamenable to Central Bank control, and from that point of view this Bill will close a gap. That is very welcome. There are a number of points I should like to put briefly to the Minister in relation to his speech. Perhaps it is in the public interest that we should know the dimensions of the problem. The Minister had indicated there are some 14 of these so-called banking industrial and provident societies on the register. How many investors are involved in such societies, if the information is available to the Department and the registrar, of course, in so far as such bodies maintain records and disclose them?

Another question that should be put is in regard to the total general investment in the holdings of such societies. This may not be known to the Department or the Central Bank. Though the Minister indicated that there are 14 such bodies on the register and that there are applications in from 19 new societies, I do not entirely accept that such information gives us any meaningful perspective. Perhaps there may be more information available in regard to the dimensions of these transactions and I suggest we should be told about the financial magnitude of the control system we are trying to introduce.

There is one other aspect I should like to comment on. The Minister proposes that existing societies which held deposits of more than £25,000 on October 24 last cannot accept or hold deposits after five years from the passing of the Bill. However, the Minister had indicated that he wishes to retain power whereby he by ministerial regulation can extend that period. I suggest to him that it is perhaps a power which he should be loath to devolve on himself.

I should like to refer to an operation which occurred in relation to a defunct bank which caused a lot of political furore at the time. I recall the enormous pressures which were brought to bear on members of the Cabinet at the time when the Irish Trust Bank went into liquidation. There were enormous pressures on politicians within their constituencies, and on individual Ministers, to underwrite repayment of deposits. At that time the Minister for Finance, Deputy Ryan, stood firm and said he would not yield to what in effect at the time was political blackmail. I personally was approached by a number of people and one of the few definite things I have done in my time was to refuse to accept that we should bend and give such a promise.

At this stage I can foresee a situation emerging, because the Minister will have power to extend the period of five years, running up to the next general election when a few societies who should be winding themselves up, or down, legitimately, will come along to the Minister and say: "Give us another few years of operation, extend the period, we are a fairly large society and there is no way in which we can conclude our operations in five years". Approaching the general election three years hence, some of these societies might find themselves in trouble, and if I were in the Minister's shoes I would perhaps devolve the responsibility on the Central Bank because they could accept the responsibility with absolute objectivity and without appearing to be open to any pressures. I agree they are the kind of pressures which Deputy O'Malley would never yield to, but they are pressures which we should not allow for in legislation. It is not a major point but it is an aspect of the Bill which the Minister might reconsider.

The exclusion of agricultural and fishery co-operatives is reasonable and fair, but I am more pleased with the Minister's efforts to ensure that the societies on the agricultural side, provided for in Part IV of the Bill, will have to keep their houses in order. That is a valuable provision. It is fair to say that the manner in which some agricultural co-operatives have maintained their accounts over the years —and many of them are multi-million operations, massively large operations—would raise the hair on the top of the head of any self-respecting accountant. Some of these societies have got themselves into the height of trouble over the years. Therefore I am glad Part IV of the Bill will introduce some elementary general provisions which are essential. As the Minister has rightly pointed out, our agricultural co-operatives are now major powers in the land. They have enormous turnovers and it is desirable that there should be effective controls on them in the public interest, in the interest of their shareholders, and in the interests of the agricultural community.

With these comments I welcome the Bill. It is overdue. Some individuals availed of loopholes but, in fairness it should be said, not all in any deliberately evasive manner. When there is a vacuum there is always a good accountant who will see an opportunity to set up his own operations. There are always people with sufficient easy money to avail of loopholes and other legal methods of avoidance which are open to them and, quite properly under the law, they will avail of the loopholes the 1971, Act unwittingly left open to them.

I was in the House for the debate in 1971 and at that time I was ignorant of the possibilities for evasion which evolved in later years. I commend the Minister on his efforts in this regard. I know he and his staff in the Department feel strongly about his situation. I know the Central Bank have been very concerned about it. The quicker this legislation is enacted the better.

Apart from my unhappiness about the regulatory power in section 5 I did not consider putting down any amendment to the Bill. Perhaps the Minister will have a look at that so that he can be assured the Committee Stage will have a speedy passage through the House and the Bill can be sent to the Seanad as quickly as possible.

I should like to thank the two Deputies who spoke their views on the Bill and their support for it. If I can, I will deal with all the points raised. Deputy Kelly raised a point in regard to the use of the words "insubstantial" and "substantial" in the definition of agricultural and fishery co-operatives in section 4. He suggested we should seek to quantify by way of amount or percentage the section of the business which related to deposit taking.

One of the advantages of having the section the way it is, is that it gives discretion to the registrar who will be dealing with this primarily. I suppose it would only go to court in the event of somebody trying to get a more definitive ruling on it. By giving discretion to the registrar to exclude bona fide agricultural and fishery co-operatives and to include those he feels are not bona fide, he is in a position to serve the public interest better. There could be a situation in which perhaps only 5 per cent of the business at a given time was deposit taking, 5 per cent of a very small business, and suddenly the deposit taking side of the business is expanded in a very big way and the agricultural or fishery side is run down. The letter of the law might be observed but certainly the spirit would not in those circumstances.

The other point Deputy Kelly made about the question of the wording of section 14 (2) has greater validity. In fact, some days after the Bill was circulated the draftsman got in touch with my Department to draw their attention to the fact that the section as it stood was too close to the wording used in the Dáil Éireann Committee Act of 1970 and in his view it would be desirable to amend it somewhat to make it clear that it did not come under the ruling of the Supreme Court in the case where that Act was examined. The same applies to section 23 (2) where the wording used is the same as in section 14 (2). I will propose two amendments to make some modifications to the wording to get over these difficulties.

Deputy Kelly inquired also about the submission of the Irish League of Credit Unions on credit union law. That is being studied by the Credit Union Advisory Committee, a statutory committee who must advise me on matters of this kind before any action can be taken one way or the other. I am awaiting their recommendations on the submission. They have not arrived yet.

The question of the possibility or otherwise of banning deposit taking by credit unions could be considered after those recommendations have been received. Perhaps it would have been somewhat misleading to the public to have introduced such a ban here and now in this Bill because, in the public mind at least, it would have classified credit unions who are wholly commendable in their activities with certain quasi-banking institutions which are less commendable. It is better that the distinction should be kept clear.

Deputy Desmond inquired how many investors are involved in the societies and by that I presume he means depositors. Unfortunately I cannot give him the figure. We will seek to get it. As of the end of 1976 there were 1,071 members of these deposit taking societies. One could safely say the number of depositors would be substantially higher than the number of members and would therefore be several thousand at least. So far as the amounts of deposits involved are concerned, the latest figures available are in the registrar's report for the year ending 31 December 1976. The amount of deposits and interest outstanding as liabilities to depositors by the 14 societies taking deposits at that time was £11,443,619. I would assume that in the 21 months since then there has been a fairly significant increase in that amount, perhaps as much as 50 per cent, so that we may now be talking about a current figure in the region of £15 million, particularly in view of the fairly extensive advertising the societies insisted on carrying out over the past 12 months although they were advised not to do so. The amount involved is probably pretty considerable by any standards and, if there were default, it would obviously be a serious matter for a great many people.

Deputy Desmond raised a point also about the five-year period in section 9 and the question of extending it. I would imagine that power would be exercised only on the advice of both the Central Bank and the Registrar of Friendly Societies. Indeed, subsection (3) requires consultation with the Central Bank before a decision to extend the period is made. In a matter such as this I certainly would be inclined to act only in accordance with their advice or recommendation.

It is important that the Bill be enacted as soon as reasonably and conveniently possible. I would hope it would be possible to have the Committee Stage next week. I would like to thank Deputies for agreeing to the Second Stage. I think I have answered all the queries but should there be any further queries I shall be only too glad to answer them on the Committee Stage.

Does the Minister expect that the report in regard to the last matter in the credit unions' submission with regard to the prohibition on accepting deposits—the Minister referred to a report he expects to get or have assessed by some advisory board—will be here in time to be reflected in this legislation?

Does the Registrar intend to defer any decision on applications pending the enactment of this Bill?

I understand he has deferred them and since the operative date is now the date of publication, which was 4 October, I am correct, I think, in saying, assuming the Bill is passed, it is immaterial now whether or not he registers them because they would be able to accept deposits as being societies registered after the operative date of the Bill.

Question put and agreed to.
Committee Stage ordered for Tuesday, 17 October 1978.