Priority Questions

National Asset Management Agency

Michael McGrath

Question:

1Deputy Michael McGrath asked the Minister for Finance if he is satisfied with the performance of the National Assets Management Agency to date; if he is confident that the agency will at least break even over its lifetime; when he expects the agency to wind up on completion of its work; and if he will make a statement on the matter. [19413/12]

NAMA was established by the Oireachtas to remove systemic risk to the Irish banking system through the acquisition of land and development and associated loans from participating institutions and to obtain the best achievable return to the State from these acquired loans.

Since 2009, when it was established, NAMA has achieved significant milestones, including the valuation, purchase and transfer of relevant loans from the participating institutions. The establishment and development of the agency itself to carry out the tasks mandated to it by the National Asset Management Agency Act 2009 has also been an important achievement. The agency is now fully engaged in its core role of managing and selling the assets under its control with a view to achieving the best financial return for the State. The agency advises me that it has completed its initial engagement with close to 800 debtors. At this stage, it has assessed 99% of debtor business plans which has enabled it to identify and implement strategies to maximise the returns from the loans and underlying property assets.

The recently completed independent Geoghegan review found that NAMA had achieved a lot in a very short time and had done so while building the organisation from the ground up, and all of this while dealing with a very complex issue. Given the considerable work and achievements of the agency over such a short period, it is clear that its performance to date has been satisfactory. However, clearly much remains to be done over the coming years to ensure a successful outcome.

The NAMA board is reviewing its strategy in the light of developments in the Irish economy and in the property market since it published its business plan in July 2010. I am advised by NAMA that the key factors which the board considers critical in terms of NAMA's ultimate profitability include the performance of various economies in which its debtors' assets are located, the timing and sustainability of any recovery in the property market in Ireland, the sustainability of the UK property market, the availability of finance and the extent to which it can maximise the level of income produced by its loans and the property assets securing them.

Additional information not given on the floor of the House.

Following a recent exercise conducted by NAMA, the agency confirmed its expectation to at least break even. NAMA advises me that it is firmly on course to recoup for the taxpayer, at a minimum, the consideration paid to the participating institutions for the acquired loans in addition to funds advanced to protect and enhance the property assets securing these loans. Based on the agency's record to date, I have no reason to doubt the agency's confidence that it will achieve its targets over its lifetime, and I have asked the NAMA board to keep me informed of developments.

I note that the agency's own projections indicate that it expects to have completed its work within the initially projected ten year timeframe. This is an issue that will be kept under review. As the Deputy is aware, the National Asset Management Agency Act provides for an initial assessment by me of the extent to which NAMA has made progress in achieving its overall objectives and whether continuing NAMA is necessary for the purposes of the National Asset Management Agency Act. This assessment is to be carried out in 2013. In the interim, NAMA will continue to meet its extensive requirements for accountability, which include provision for the chairperson and CEO of NAMA to appear, if requested to do so, before a committee of the Oireachtas; reporting on a quarterly basis on a wide range of matters, including details in relation to loans, and which quarterly reports are laid before each House of the Oireachtas; preparing an annual statement setting out the objectives and the projections for the performance of NAMA for the year ahead, which again is laid before each House of the Oireachtas; and submissions of annual accounts to be audited by the Comptroller and Auditor General which are laid before each House of the Oireachtas. The Committee of Public Accounts may examine NAMA on these audited annual accounts.

I thank the Minister for his reply. I am sure he will agree that the performance of NAMA, the most important State agency in our economic history, will be critical to the country in the next few years. We now have the benefit of almost two and a half years of NAMA being in operation. The agency has a difficult job of dealing with the fall-out from the collapse of the property market and the construction industry. It is in a position of absolute dominance in the Irish property market.

Last month, NAMA came before the Joint Committee on Finance, Public Expenditure and Reform. I asked the chairman, Mr. Frank Daly, if he was confident that NAMA would at least break even over the course of its lifetime. He stated his belief that it would and that he was confident it would.

Based on what the Minister knows at this point and accepting that these are still early days, is he confident that NAMA will receive the €31 billion it paid for the loans plus the running costs of the agency? When does the Minister expect the agency to complete its work and wind up?

NAMA advises me that it recently carried out an analysis which indicated that the agency would repay all its senior bonds by the end of 2020, with a small surplus given one scenario and a relatively small loss given another scenario. It is predicting a break even, under present circumstances, on the basis of that analysis.

NAMA has also provided me with the unaudited accounts to the end of 2011. These indicate that NAMA expects to generate pre-impairment profit of €1.01 billion in 2011. Taking an impairment charge of €810 million into account, this should generate a profit for 2011 of €200 million. The calculation of the impairment charge is, of course, subject to final agreement between NAMA and its auditors and the Comptroller and Auditor General. I have no function in that process.

NAMA also assures me that it expects to make a pre-impairment profit in 2012.

I repeat my key question. Does the Minister for Finance, as Minister in charge of NAMA, share the confidence of the chairperson of NAMA that the agency will, at least, break even over the course of its lifetime? The Minister has restated the position of NAMA itself. We are well aware of that. It is on the public record. I want to know the Minister's own view. Does he agree with what the chairman has said? Can he confirm that?

I also asked about the timeframe for the operation of NAMA. Does the Minister envisage NAMA completing its work by 2020? Does he agree that it would be appropriate, given the changes in the Irish economy and the property industry since July 2010, that the business plan should be updated so that we can do a rigorous analysis of where NAMA is today?

It is unreasonable of the Deputy to expect me, in the first quarter of 2012, to take a different view from NAMA about what the situation may be in 2020. All I can do is to give him the assurances NAMA has given to me and, separately, to the Joint Committee on Finance, Public Expenditure and Reform. I accept those figures as the best possible estimate at this time.

As I said in my reply, there are many moving parts. We do not know what will happen in the property market in Ireland. It looks now as if there is the beginning of slight growth in the property market in Ireland. We are not sure what will happen in the property market in the United Kingdom or in the economies of countries where NAMA has significant portfolios. However, on the basis of the information available to NAMA at present, which the agency has shared with me, I share the view of NAMA that it will at least break even by 2020 and will complete its task in accordance with the Act.

Banks Recapitalisation

Peadar Tóibín

Question:

2Deputy Peadar Tóibín asked the Minister for Finance if he will provide on update on the work of the Troika technical group dealing with the Anglo Irish Bank promissory note; if he will provide an update on his discussions with the ECB and EU partners on this matter; and if he will outline on what he would consider a successful outcome on the matter of the promissory note. [19546/12]

As the Deputy is aware, the Government has been committed to reviewing the arrangements that were put in place to capitalise the Irish Bank Resolution Corporation, IBRC, formerly Anglo Irish Bank and Irish Nationwide. The purpose of this review is to determine if there is a way to reduce the overall cost to the State. Part of the capitalisation of IBRC was provided using promissory notes as consideration.

While the development in relation to the end of March promissory note payment is positive, we must continue to work towards the greater benefits that would derive from the re-engineering of the promissory note. There are potential improvements for the banking sector which could also stem from the ongoing technical discussions.

It is for these reasons that we must look at the recent developments as an initial step in a process. This is a medium-term project. The Government is focused on developing an alternative solution to the promissory note arrangement in IBRC.

It is too early at this stage of the process and indeed it would be inappropriate to predetermine what a successful outcome will look like or to indicate how the various stakeholders have reacted or may react to various proposals. We want to arrive at a successful conclusion that is in the interests of Ireland and the European Union.

First, I take this opportunity to share my sympathies and those of my party with Deputy Pearse Doherty, who lost his father suddenly in the last week. This is a sad time for Deputy Doherty. Ar dheis Dé go raibh anam an Uasal Uí Dhochartaigh.

Some of the Minister's backbenchers have been enthusiastically telling the world that the scheduled payment of €3.06 billion to IBRC, which was due to take place on 31 March, did not, in fact, happen. Of course, the Minister and I know different in that regard. It would be interesting and important for the Minister to put what exactly happened on the record. Is it not the case that the IBRC was paid this money from NAMA cash reserves, which are in essence, public money? Is it also not the case that subject to the approval of Bank of Ireland's board the money will then be reimbursed to NAMA by Bank of Ireland and, in turn, Bank of Ireland will hold it for 13 years and the Irish Government bonds to which the Minister referred in his statement will be repaid by the State in full? What happened on 31 March was that the State did pay the IBRC €3.06 billion but from a different source than was originally intended.

The Deputy must ask a question please.

The first question is to put the issue on the record. The second question is that the most immediate consequence of the smoke and mirrors element to this is that there will be a cost to the State of €90 million this year. The money must come from somewhere. Where will it come from? Will it come from cuts or increased taxes and what part of the economy will suffer as a result?

I appreciate the difficulty in understanding every detail of the transaction because it was quite complex. There were probably simpler ways of doing it but we were not free agents in making the arrangements. If one looks at it in its totality, the European Central Bank, ECB, provides emergency liquidity assistance, ELA, funding to IBRC - formerly Anglo Irish Bank and the Irish Nationwide Building Society. That money had to be paid back because some of it was underpinned by a promissory note. The first repayment is the payment back of money to IBRC which is European Central Bank money. The bond is being repo'd by Bank of Ireland - if the shareholders agree to the deal, and there is no indication they will not. At the shareholders' meeting following that, the bond will be repo'd, in other words, effectively turned into cash, but that will be done with ECB money as well, because the money into Bank of Ireland is coming through the liquidity window, which is going into the Irish banking system anyway so that is ECB money as well. The money which we accessed for bridging finance from NAMA was money which is due to be repaid to the ECB for the loans it gave to NAMA to acquire the impaired assets in the bank. Again, it is ECB money that is providing the bridge. What will happen is that when the circle is completed and the shareholders give their consent, which is my expectation, the NAMA funds will be restored and NAMA will do what it intended to do last month, namely, it will repay another portion of what it owes to the ECB. It has already paid €1.9 billion back last year and it will continue to repay in accordance with its schedule. There are three different involvements of the ECB. It is a good deal for Ireland. There is no doubt about it but it is only one step. I do not wish to exaggerate it and I did not when I presented it originally.

It is interesting that the fanfare which accompanied the initial announcement by the Minister has disappeared because the agreement that was originally envisaged to be about to occur did not happen – unfortunately for the Minister.

The Deputy must ask a question.

Given that Bank of Ireland is part of the infrastructure to give loans to potential home owners and to businesses in future and given that a chunk of the money will come from Bank of Ireland in at least the short to medium term, there must be an opportunity cost to the money coming from Bank of Ireland into the real economy. ISME indicated that 49% of small businesses have difficulties in getting loans currently. Is it not the case that the Byzantine solution which the Government has concocted will have a negative effect on the real economy?

First, there was absolutely no fanfare. I announced twice in the House what was happening and I did it in the most modest way. I made no attempt to turn it into a PR occasion and I described it as a first step. I know Deputy Tóibín's party is disappointed because it thrives on things going wrong. He and his colleagues hope to build the party on the sufferings of the Irish people. That is the party's policy.

Could we focus on the questions?

The wish of its members every day is that nothing succeeds and everything collapses and then out of disaster the party will grow. What is the Sinn Féin Party policy? We know the party's position, but the Deputy should stick to the record and to the truth. I have described in detail what has happened.

What is the opportunity cost?

There is not an opportunity cost because Bank of Ireland is getting additional funding from the ECB to repo the bond through the liquidity window. If one looks at banks all across Europe they are getting far greater quantities of money than the Irish banking system is getting. It does not impair Bank of Ireland's day-to-day business whatsoever. I agree with those who have said this is not a full and final settlement. I said that myself. It is only a first step which improves the situation for this year

Stephen S. Donnelly

Question:

3Deputy Stephen S. Donnelly asked the Minister for Finance the way in which the €90 million cost of the recent arrangement on the March promissory note payment is arrived at; the final beneficiaries of this €90 million; if there was agreement from the European Central Bank, prior to his announcement of 29 March, to lend the required funds to Bank of Ireland; if so, at what rate, or if Bank of Ireland will use its own capital to fund this; and his views on the use of National Asset Management Agency assets to offset Government debt. [19452/12]

The €90 million is the estimated difference, for the remainder of 2012, between borrowing under the programme at an estimated 3.5% and the impact on the deficit of the new Government bond. The State is the ultimate beneficiary as the coupon on the new Government bond is paid to its wholly owned subsidiary, IBRC.

My Department is currently updating its macroeconomic and fiscal assessment for the forthcoming stability programme update, SPU. The SPU will give an update of, among other things, the general Government deficit estimate for 2012, taking account of all of the latest available economic and fiscal data, both positive and negative. The SPU will be published at the end of the month. On foot of the Exchequer returns for the first quarter of the year, I am confident we will meet our budgetary targets for the year.

The ECB had expressed a clear preference that the financing arrangement would be between IBRC and a bank that was not in majority State ownership. The transaction would then be financed by Bank of Ireland, through standard ECB money market operations, using the Irish Government bonds issued as collateral. As NAMA had the funds available, as a short term interim measure, pending the results of Bank of Ireland's shareholders' vote, I directed that the financing of the bond would be through a collateralised facility provided by NAMA to IBRC on equivalent commercial terms as the financing with Bank of Ireland.

The back and forth exchange with Deputy Tóibín and the answer the Minister just outlined reinforce what was a very disappointing statement. The Minister made a statement in the Chamber. He told us he was spending €90 million of our money and he refused to answer any questions but he did have time for an interview with RTE afterwards. We have only come back after a two-week gap. It was very disappointing to be given that little information and not to be given a chance to ask the Minister reasonable questions. Deputy Michael McGrath and I, and many other Deputies, spent three and a half hours with the Governor of the Central Bank, Mr. Honohan, earlier in the week and the story he gave us of what he believed would happen was substantially different to what we are hearing in terms of the detail now. There was no mention of NAMA or Bank of Ireland.

Could the Deputy ask a question please?

The nub of my question is who is the beneficiary. My understanding is that the ECB will lend the money when the bond is repo'd to Bank of Ireland at 1%. What I would like to know is at how much is Bank of Ireland going to lend the money to IBRC and whether Bank of Ireland will walk away with a profit. The Minister stated that the €90 million additional cost is entirely circular. I hope it is so that ultimately there is no long-term cash cost to us because it stays within the circularity of the financing, but that is not the case if Bank of Ireland lends the money to IBRC at anything above 1% because then State money will go to Bank of Ireland in which we only have a small minority stake. Could the Minister confirm the rate at which for at least the nine months in question Bank of Ireland will lend the €3.1 billion to IBRC? Could he also confirm that the Bank of Ireland will or perhaps already has borrowed the money from the ECB at 1%?

I will deal with the €90 million calculation first and then with the second part of the Deputy's question. The €90 million is estimated to have an incremental impact on the Exchequer which is calculated as follows. The status quo was estimated as the cost of borrowing under the programme for the promissory note instalment, namely, €3.06 billion at 3.5% for the remainder of 2012 giving an interest cost of €80 billion. On 29 March, before the Government bond was issued it was estimated that the bond power value would be €3.53 billion. The coupon was known to be 5.4%. In 2012 the interest cost was therefore €140 million. There is also a technical adjustment under the Government accounting rules which increases the deficit impact to €170 million. The €90 million was therefore the difference between the estimated status quo of €80 million and the estimated deficit impact from the new Irish Government bond of €170 million. The cost to the Exchequer arises from the interest payable on the Government bond not on the margin which Bank of Ireland is getting. Bank of Ireland is a commercial bank of which 15% is in State ownership. Of course it is doing this because it is going to make money on it. Their margin is 135 basis points above the cost of the money. As Deputy Donnelly correctly states, the money is coming at 1%. Of course, that is cheaper than the average cost of funds. The alternative was that we would go back to the European funds, the EFSF fund or whichever fund would provide the funding, where it would cost us on average 3.5%. Because we are getting it cheaper, there is a margin. There is a cost, but if one sets the €90 million off against the fact that we are not borrowing an additional €3.06 billion in 2012, one can see that there is a big advantage because that €3.1 billion remains as money on which we can call if we need it, for example, next year.

I appreciate the advantage of not using the troika facility, but we are still borrowing. The Government merely issued a bond for it. In real terms, we have merely borrowed it.

Yes, but for a longer term and cheaper.

That is the objective.

Am I correct in thinking that, broadly, Bank of Ireland will make approximately €30 million this year out of that deal? If we take 135 basis points on €3.06 billion over nine months, there is approximately €30 million for Bank of Ireland out of the deal.

I stated it might make a little more because I hope the bank will commit for 364 days, not for nine months. It will be nearly a full year.

Some €45 million.

Of course, there are handling costs and there are administrative costs as well. They are entitled to their profit. I hope that they will not have any difficulty with their shareholders but I must stand back from that because shareholders have an independent function and cannot be influenced by the Minister.

That is a real additional cost.

Legislative Programme

Michael McGrath

Question:

4Deputy Michael McGrath asked the Minister for Finance in the context of recent comments by the IMF on the publication of its latest World economic outlook, if he is satisfied with the proposed personal insolvency arrangements in respect of secured debt, in particular residential mortgages, as set out in the published scheme of the Personal Insolvency Bill; and if he will make a statement on the matter. [19414/12]

The recent IMF World Economic Outlook report, and its chapter on household debt, is a useful contribution to the range of measures being considered to address the global economic situation. However, it should be noted that the examples examined in the report in the chapter dealing with household debt related to particular countries and times, and that some of the debt restructuring examples investigated were more successful than others. Therefore, the particular circumstances of each individual case was a relevant factor in the outcome of the action. While one should seek to learn from previous examples, it is also important to exercise caution in drawing general conclusions from the report and applying them to the current Irish economic position. Indeed, in their public comments on the report, the IMF staff indicated that they were not stating that such a blanket approach should be taken in the case of Ireland and, indeed, indicated that, in cases of constrained fiscal space, which unfortunately is the position Ireland currently faces, a targeted case-by-case debt restructuring approach may be the most appropriate approach. This case-by-case approach is consistent with the recommendations of the Keane report on which the Government approach to address this problem is broadly based. The current funding situation of the Irish fiscal and banking sectors are also relevant factors to be borne in mind.

On the issue of bankruptcy reform, as the Deputy will be aware, the Minister for Justice and Equality, and Defence, has developed a detailed general scheme of a personal insolvency Bill, which was published for public consultation earlier this year. A significant number of submissions were received in response and these, along with the detailed report by the Oireachtas Joint Committee on Justice, Defence and Equality on its hearings on the scheme, will be taken into account by the relevant Departments and the Office of the Attorney General in the finalisation of the Bill. Ireland is maintaining close contact with the IMF and the other troika authorities in the development of its personal insolvency reform proposals and also on the wider approach to tackle mortgage arrears problems and will take full account of their views in the further development and implementation of these proposals.

The main legislative response of Government to the crisis of personal indebtedness and mortgage arrears is the personal insolvency Bill, the heads of which were published in January, and it has since been considered by the Oireachtas Joint Committee on Justice, Defence and Equality. I want to focus on one of the three instruments in that Bill, the instrument dealing with secured debt such as mortgages, that is, the personal solvency arrangements. The Minister co-sponsored this Bill with the Minister for Justice and Equality, Deputy Shatter, and I want to ask him how it will work in practice and what he sees as the benefits of this arrangement for distressed mortgage holders. For those who are in mortgage arrears whose income is not sufficient to meet their obligations, can the provisions of this Bill result in a reduction of the mortgage debt as a result of a personal insolvency arrangement? Can the Minister outline what the benefits of such an arrangement could be for distressed mortgage holders?

The Bill is being drafted. It is never the practice in this House to discuss detailed measures in a Bill which has not yet been published. We will get to that at Committee Stage.

I am sure the Minister agrees with the comments of the Taoiseach and Tánaiste in recent weeks that there is a frustration, which they themselves share, about the lack of progress and the lack of urgency in dealing with the mortgage arrears crisis. The Government has held up this Bill as being the centrepiece of its response. The Government accepted, at Second Stage, a Fianna Fáil Bill in October last which would have set up a non-judicial debt settlement system. They are not proposing to set up their own one and one of the key elements of that is a personal insolvency arrangement which will deal with secured debt. There are thousands of mortgage holders out there who are asking the simple question of what potential benefits can such an arrangement in general terms bring for those who are experiencing genuine mortgage distress.

We want provision in law, as was explained by the Minister, Deputy Shatter, and myself when we launched the heads of the Bill, that is not a full bankruptcy hearing to drive mortgage holders into a bankruptcy position where bankruptcy legislation was never intended to deal with the problems of somebody with an impaired mortgage. We have also decided that it is insufficient from a policy point of view to leave case-by-case arrangements with the lending authorities to the discretion of lending authorities without the force of law underpinning it. The proposal to which Deputy Michael McGrath refers is to give judicial recourse, short of full bankruptcy proceedings but also well in advance of voluntary arrangements, and that is the space we are trying to fill. The legislation in that respect is being drafted in accordance with the head that is published.

EU-IMF Agreement

Peadar Tóibín

Question:

5Deputy Peadar Tóibín asked the Minister for Finance if he will provide an update on the Troika review of the Memorandum of Understanding taking place this week and if he will indicate the aspects of the Memorandum of Understanding that he is hoping to amend. [19547/12]

As the Deputy will be aware, the latest review mission by the external partners is currently taking place. It began yesterday, Tuesday, 17 April and will continue until Thursday, 26 April. The review mission comprises of a significant number of meetings designed to evaluate all the elements of the programme covering fiscal developments, the macroeconomic outlook, progress on commitments regarding restructuring the financial sector and structural reform.

After the mission to Ireland is concluded, staff reports will be sent to the ECOFIN Council and the IMF executive board for approval, thus facilitating the next round of disbursements of EU-IMF funding.

Verification of the relevant quarterly targets forms a key part of the mission. The Government has repeatedly stated its commitment to the programme targets. Meeting these conditions on time and on target is the best way to ensure we emerge successfully from this programme, which is our primary focus. That would mean we can return safely to the financial markets for funding in as timely a manner as possible. This is one of the principal objectives of the programme. The Government's commitment to the programme does not stop us from seeking and agreeing changes to aspects of the programme. We have already done this successfully. The Government will continue to do so at the appropriate time.

Following each review mission, and arising from detailed and lengthy discussions with the troika team during it, revised versions of the programme documents, including the Memorandum of Understanding on Specific Economic Policy Conditionality, are prepared by my officials before being submitted to the external partners. It would be premature at this stage to comment on the possible outcome of these discussions.

However, it is also important to note that the relevant programme documents are made publically available at the end of the process.

Many were disappointed to hear over the past couple of days that there was a break with the practice of the troika meeting with Opposition parties. It was a situation where Opposition parties had an opportunity to represent their constituents to the troika, and also to find out if the troika and the Government were on message or was there a deviation between the message that both separate organisations were giving out. I read in their statement yesterday that they indicated the proximity to the treaty referendum was the reason. However, many remain sceptical on that issue. Many believe it was the Government that requested the troika not to meet the Opposition parties.

I would like the Minister to go on record in that regard. The initial response was very vague and much of the information is general. Will the Minister put on record the detail of what issues are currently being negotiated with regard to the memorandum of understanding and in particular his intention with regard to the National Pensions Reserve Fund and its use for potential job creation?

The decision by the troika not to meet Opposition party members on this occasion was a decision made and announced by the troika. They make their own arrangements when they come here on how they will relate to different groups in society, different Departments and so on. That is what they have done on this occasion.

On the programme, the first thing we always do is to have a general weighting to set the scene, and we had that yesterday afternoon. They gave their view of how the programme was proceeding and the Minister, Deputy Howlin, and I gave the Government view of how the programme was proceeding. Following that, there are then a series of meetings with officials, principally from the Departments of Finance and Public Expenditure and Reform but also from other Departments.

The first task is to see whether, at the end of the quarter, the Irish Government has fulfilled all the conditions in the memorandum of understanding. When one fulfils the conditions, which we have done, that is a bit of a box-ticking exercise, and it only becomes an issue if one has not fulfilled the conditions. However, it is a very important box-ticking exercise because unless one ticks the boxes, funds can be withheld. Therefore, one needs to meet all the conditions of the memorandum of understanding for the quarter before one can draw down funds from the various funds in the future. We then look to the future as well and, obviously, we will have full discussions on that later in the week or early next week.

With regard to ceasing discussions with the Opposition, did the troika ask an opinion of the Government and did the Government in any way proffer its opinion to help them make that decision? Has the Government asked in any way so far for use of the National Pensions Reserve Fund for job creation?

They informed the Department of Finance, which informed me and my officials, and, of course, I informed the Government that they were not meeting the Opposition on this occasion. I suggested that a formula that might suit their concerns would be to meet the finance committee of the House, on which all parties would be represented, and to do it in public session because they had a fear of being misrepresented when they meet in private. They decided they would not take up that option. I would have no problem if they were to meet.

The other alternative, given the Deputy obviously wants his views to be known to the troika, is that they are always available to take written submissions. If he wants to write out his views and send them to the Commission representative, who is the chair of the troika group, I am sure they will consider those. It could be as effective as an oral submission.