Saincheisteanna Tráthúla - Topical Issue Debate

Insurance Industry Regulation

I thank the Ceann Comhairle for choosing this question for the Topical Issue debate. I have a real sense of déjà vu. Here we are with another insurance firm, which is principally regulated in another EU member state, failing with very significant consequences for policyholders, claimants and, ultimately, Irish insurance consumers. Qudos Insurance was regulated prudentially in Denmark and sold business in Ireland under the freedom of services provisions of EU law. It had approximately 50,000 policyholders, primarily motor insurance, much of it commercial vehicles and vans, and also some home insurance. Information I have received in response to a parliamentary question is that early indications suggest around 1,400 claims remain outstanding. This is similar in scale to Setanta Insurance, and is now the fourth foreign-regulated insurance company to collapse in recent years. Setanta Insurance was regulated in Malta, Alpha Insurance was regulated in Denmark, Enterprise Insurance in Gibraltar, and now Qudos, also regulated in Denmark.

Several issues require resolution. First, given that we are approaching the fifth anniversary of the collapse of Setanta Insurance and hundreds of claims are yet to be paid, I sincerely hope we are not looking at a similar time frame for those affected by the collapse of Qudos Insurance. Some policyholders have spoken in the media and their stories are quite striking. In some cases, people are in a bad way with repairs to their homes and with significant and serious crashes involving people insured by Qudos.

What reassurance can the Minister of State offer claimants that they will have their claims dealt with quickly? That is the first priority. Then there is the question of who ultimately pays this bill. Will it be Denmark or Ireland? As a result of a change of the law in Denmark in May 2018, it appears that if the company moves from solvent liquidation to bankruptcy after 1 January 2019, the Danish insurance guarantee scheme will not be picking up the bill. In that case it will rest with the Irish insurance compensation fund. That has a number of implications. First, claimants who do not have a third-party motor insurance claim will not get all of their money because there is a cap of 65% for payouts from the insurance compensation fund here. This would also mean another draw on a fund that is already significantly overdrawn and will remain so well beyond the next decade because of the bills for Quinn Insurance and Setanta Insurance as well as many other issues.

I am very curious as to how this change in the law in Denmark came about and the fact that the company is now in solvent liquidation. Who is in control of the decision on when or whether that company moves into bankruptcy? It has very major implications for Irish policyholders and indeed for all Irish insurance consumers. Will the Minister of State reassure the House that from the point of view of the Department of Finance and the Central Bank, the manner in which this issue is being handled by the Danish authorities is above board? I am not accusing them of pulling a fast one, but I want the Minister of State to reassure us that the process under way there is transparent, independent and is being conducted above board. I look forward to the Minister of State's response.

I thank the Deputy for raising this very important issue. My colleague, the Minister for Finance, asked me to take this Topical Issue debate for him because he has another previously organised engagement.

As the Deputy has rightly pointed out, on 28 November the Central Bank announced it had been informed that Qudos Insurance A/S had entered into solvent liquidation. Qudos is authorised and regulated by the Danish Financial Supervisory Authority, FSA, and therefore the Central Bank has no role in this decision. Qudos operated in Ireland on a freedom of services basis, and its products were sold through Patrona Underwriting Limited.

On 4 December, Qudos published further information stating it was no longer paying insurance claims. In light of the uncertainly around the payment of claims, the Central Bank then issued a statement strongly recommending that affected customers contact their insurance brokers to arrange alternative insurance cover. It is understood that at the end of November 2018, there were 51,012 policyholders with Qudos in Ireland. That is comprised of 37,948 van insurance policies, 10,940 household insurance policies and 1,366 private car insurance policies. I will provide the Deputy with the figures. There are also smaller numbers of fleet, haulage and non-standard insurance policies totalling 758. Patrona has issued a statement saying that policies remain valid and in force until their natural expiry dates. However, given the current Qudos position and in line with Central Bank recommendations, Patrona has provided brokers with options to replace all insurance cover with other providers at no extra cost to consumers. We understand that the vast majority of policyholders have now been transferred to new providers.

The Central Bank has informed the Department of Finance that, as of 14 December 2018, there were 1,544 open Qudos claims. This cohort is made up of 155 household claims and 1,389 private car claims. The Central Bank understands the Danish liquidators are continuing their review of the company, with a view to determining its underlying financial position. Once this exercise is concluded, they will be in a better position to determine whether the company is solvent or insolvent. It is only then that it can be determined that the company has failed, that is, it is unable to meet its claims obligations. The matter is fluid as information is being frequently updated. We were trying to get an update for the Deputy this evening. Consequently, it is expected that more information regarding this matter should he available later this week. When we get this information, we will convey it to the Deputy.

Last week Department of Finance officials were in contact with Denmark's Ministry of Finance. The ministry advised them on the basis of information received from the Danish FSA that, as the company is in solvent liquidation, it believes that claims will be met. As the Deputy also rightly pointed out, the Ministry also indicated that if Qudos is ultimately placed into bankruptcy before 1 January 2019, the Danish insurance guarantee scheme will be liable to meet these claims. However, due to a legislative change in May 2018, if bankruptcy is declared on or after 1 January 2019, the Danish insurance guarantee scheme will not be in a position to pay claimants located outside Denmark. This is the eventuality the Deputy is worried about. However, in such a situation, Irish claimants may instead be eligible for cover from the Irish insurance compensation fund subject to its terms and conditions and the particular circumstances of the case.

I understand Department of Finance officials were also in contact with the UK Treasury and the European Commission to set out the impact and importance of this issue for Ireland and to understand what, if any, actions they were planning to take. UK customers have also been impacted by the failure of Qudos. The Minister of State, Deputy D'Arcy, has met Insurance Ireland whose representatives outlined their serious concerns about the additional cost that Qudos could place on the Irish insurance sector if it is liquidated on or after 1 January 2019. Officials continue to liaise with the Central Bank which advises that it is in very frequent contact with its Danish counterparts and the supervisory authorities of other affected member states though the collaboration platform for Qudos established by the European Insurance and Occupational Pensions Authority, EIOPA. The Deputy can rest assured that, throughout the week, intensive efforts will continue through the appropriate channels to seek an early decision from the Danish authorities to provide certainty for all affected parties.

I thank the Minister of State for his reply. To be frank, it is very worrying. I would like to know whether the change in Danish law is compliant with EU law. That is something the Department of Finance should follow up on. That needs to be dealt with because the Danish authorities are simply passing on the bill in respect of a company that was principally regulated there. My main concern is that this process is being managed so that Qudos will be put into bankruptcy after 1 January. That has very serious implications. It will cost Irish consumers tens of millions of euro. It will mean that some claimants will not get all of their money because they will be subject to the conditions of the insurance compensation fund, which has a cap of 65% or €825,000, whichever is the lesser.

For Irish consumers to have to pick up the tab yet again is just not on. They are already paying up to 7% in taxes and levies on their insurance policies. We are now looking at the potential of another major draw on the insurance compensation fund. Looking at the figures, I note that the number of open claims, now at 1,544, will rise. That is the nature of how insurance works. It can take time for claims to be put into the system. We are looking at another debacle on the scale of Setanta Insurance, which is still rumbling on almost five years after the collapse of that company.

There are major questions about the quality of regulation of insurance across the European Union. It is only as strong as its weakest link. I support the passporting provisions. Ireland is a significant exporter of insurance services. However, this system only works if there is a common standard of regulation across the European Union. I have raised this issue directly with the European insurance regulator. We will see what that body's response will be. The Minister for Finance, Deputy Donohoe, needs to raise this issue at a political level within the European Union. That has not happened to date and it is not good enough. This needs to become a significant political issue on the agenda of the Eurogroup, the Economic and Financial Affairs Council, ECOFIN, and the other relevant authorities.

This matter is being treated with urgency by the Department of Finance and the Minister. As the Deputy said, the Minister of State, Deputy D'Arcy, has been in contact with the UK Treasury and the European Commission. We hope to get an update as soon as possible on their plans in that regard. We are concerned about it. I have taken careful note of all the points the Deputy has raised during the debate. It is hoped that the Danish authorities will come to a decision quickly to provide certainty to policyholders and claimants. The Deputy should note that the Minister is very conscious of the problems caused in recent years by the number of non-life companies passporting into the Irish market, particularly in the light of the significant motor insurance claims. On the other hand, Ireland is a major beneficiary of the cross-border passporting regime, particularly in the life insurance sector.

It should be noted that the Solvency II regulatory framework is not a no-failure regime. It is not possible, as we all realise, to build a viable system that will provide a cast iron guarantee that no insurer will ever fail. It is important, therefore, that EU supervisors properly and consistently supervise the insurers they authorise and that there be greater communication, as the Deputy said, between supervisors across the European Union on their respective companies in conducting cross-border business. In that regard, there is a proposal, as part of the ongoing review of the European supervisory architecture, to further improve cross-border co-operation and communication through the strengthening of cross-border collaboration platforms which operate on an ad hoc basis. However, the proposal would ensure a more formal structure was put in place where an insurer did a lot of cross-border business. It would give supervisors in the countries where insurance was written greater insight into how the business was being conducted. The Minister, Deputy Donohoe, and his colleague, the Minister of State, Deputy D'Arcy, are very concerned about this issue for Irish policyholders and every effort is being made in that regard. There is constant contact by the Department of Finance and other agencies with the Danish authorities to ensure a quick decision can be made in order that it will not extend beyond Christmas, something about which the Deputy is concerned. I will convey his views to the Minister.

Home Repossessions

I thank the Ceann Comhairle for selecting this issue. I am glad to have the opportunity to raise it because it is extremely important.

The behaviour witnessed at the weekend was like a scene from 19th century Ireland. There are no appropriate words we can use in this Chamber to describe it, only "completely disgusting behaviour". The Government should remind the banks who exactly bailed them out. They were bailed out by the people, taxpayers, which they seem to forget. The crux of the matter is that we need to see the banks being reined in. They are standing over evictions and putting considerable pressure on families. I have countless stories of families with whom the banks will not negotiate on their mortgages. They have put so much pressure on borrowers that many have taken their own lives in the past few years because of their financial difficulties, yet we bailed out the banks. We are, however, starting to see people stand up for themselves, which I welcome. There will not be as much tolerance of this behaviour in the future.

Deputies who abstain on or vote against important legislation with anti-eviction measures have a great deal to answer for. They can no longer sit on their hands while this is happening.

What happened in County Roscommon is evidence of what is seen in many parts of the country. People are very angry that the banks which bankrupted the country are sending in security firms to evict people from their homes in the most abusive manner. While the security firm in this case is based across the Border, many of the security firms involved in other places are based in Dublin, Carlow and Longford, among other counties and they, too, are acting in the most abusive fashion. Something has to be done to rein them in. Clearly, there is a need to put legislation in place. It is welcome that the Minister for Justice and Equality, Deputy Flanagan, has acknowledged that this needs to happen. Legislation needs to be brought up to date to ensure the particular groups involved - they are thugs really - will be reined in and regulated properly.

Another issue is that the banks are not dealing with people. We should not be talking about this as a justice matter but as an issue that is being dealt with appropriately by the banks. Many borrowers approach them to try to make deals, but they cannot do so because the banks will not deal with them, which is simply wrong. The banks need to be brought to account.

I thank the Ceann Comhairle for allowing us to raise this important issue. I will repeat what I have stated on numerous occasions in recent days. I grew up three miles down the road from the family in question. I went to school with them and know the case well. The two Deputies who have spoken are correct. There is extreme anger in the area. I use this opportunity to appeal for calm.

We must ensure people who are heavy-handed will be taken out of the system in removing people in evictions. What I would like to see every Member of the Dáil address, if at all possible, is the introduction of legislation in order that we will not have such firms involved in this work. Evictions are unfortunate. When one talks about the eviction in Strokestown, County Roscommon - the Minister and everybody else in this Chamber is aware of the history of what happened there - one must remember that "eviction" is a very dirty word in that part of the country where it has left a sour taste, particularly since the Famine in which so many people were either lost or driven out by the British. While it is a place of great peace and people do not want to engage in violence, they are extremely angry, upset and annoyed at what has happened.

As the Deputies are aware, a High Court order was executed last week for repossession of a property at Falsk, County Roscommon. As the Deputies appreciate, the courts are, subject only to the Constitution and the law, independent in the exercise of their judicial functions and the management and conduct of cases which are brought before them and I have no role in the matter. Sheriffs are officers of the court and independent in the exercise of their functions and duties under statute passed by the House and the rules of court. The sheriff, or the county registrar acting as sheriff, is responsible to the court for the enforcement of court orders. The law and procedures governing the execution of court orders are contained in the Enforcement of Court Orders Acts, 1926 to 1940, and the rules of court made thereunder. As Minister, I have no operational function in this matter. However, it should be emphasised that there is a clear difference between persons or companies employed to execute court orders and vigilante groups carrying out acts of organised and serious violence, as occurred on Sunday. I condemn in the strongest terms the violence that occurred at Falsk, County Roscommon, early on Sunday morning. A Garda investigation is under way following the violent incident that occurred there, during which a number of people were injured, some of whom were hospitalised. It is important that the Garda investigation take its course and I note that arrests have been made. Gardaí are required to carry out their important duties in accordance with the law and should any person have a complaint about the actions of a garda, he or she should go to the independent complaints body - the Garda Síochána Ombudsman Commission.

I will not comment on any individual case, but I stress that violence is never justified. An Garda Síochána is the sole legitimate guardian of the peace in the State, charged with upholding the law in the interests of the whole community. It is never appropriate for vigilante or criminal groups or gangs to take the law into their own hands and commit acts of serious violence against people, animals or property, as happened in County Roscommon on Sunday. I strongly condemn the incidents. It is welcome that An Garda Síochána is investigating the matter and there is a criminal investigation under way. I am deeply disturbed by the thinly veiled references to vigilantism made in recent days on social media and elsewhere. This is a very dangerous road to go down and vigilantism and private armies will not be tolerated in the State.

While conscious that the full facts of the case are not in the public domain, it is clearly deeply distressing to see a family lose their home, particularly at this time of year. I hope the issue can be resolved peacefully through dialogue and mediation.

On the broader issue of mortgage arrears, the Government is committed to helping borrowers to achieve solutions that will allow them to stay in their homes. Abhaile, the national State-funded mortgage arrears resolution service, has provided free financial advice for over 10,000 households in mortgage arrears since it was established. That over 116,000 mortgage restructures have been completed to date and that 87% of them are on track is proof positive that engaging with a lender works. There is help available for those in mortgage distress who wish to avail of State support. Furthermore, my departmental officials are in the process of drafting a land and conveyancing law reform (amendment) Bill, the principal purpose of which is to broaden the range of matters a court must take into account when deciding whether to grant a repossession order to a lending institution on a borrower's principal private residence. I acknowledge the work of the Minister of State, Deputy Moran, in that regard.

I will come back to the Minister, if that is okay.

I welcome that the Minister has condemned the situation. However, the point is that there will be more incidents such as this throughout the country if we do not deal with the fact that in many cases and certainly the vast majority of those with which I have dealt the banks will not engage with people. They will not negotiate. They haunt people with letters, phone calls, emails and texts and get them to the stage where they are bullied out of their homes and hand back the keys. Five or six years later, the houses are sitting empty in the middle of a housing crisis. Many people are willing to engage and try to reach a deal, often a very reasonable deal, with the bank but the bank does not want to know about it. Nobody is holding the banks to account but a few years ago when their coffers were short they were not shy about holding out their hands for a bailout. This House has to get real and start doing something about this issue because what happened on Sunday is just the start of it. It will continue if we do not address it.

Repossession through the courts is one part of the issue but many repossessions occur when people agree to hand back their house under duress. They are put under huge pressure with which they are unable to cope.

There is often a narrative that a person whose home is repossessed must be some type of scoundrel or be in terrible trouble. That implication is being made in this case. Reference may be made, as it was in this case, to people's past debts which have been settled or to businesses in which they were formerly involved. None of that is relevant. The only thing that is relevant is that the banks are doing the dirty work.

Although the security firms and the banks have the law on their side, that is the only thing they have on their side. The people are certainly not on their side. It is time for the Government to recognise that the ordinary decent people of this country are very aggrieved that citizens can be treated in this way and that the State will stand by and watch. The footage of the events in Country Roscommon shows gardaí standing outside the gate of the property, watching the eviction. That really angered people.

Action must be taken to ensure there is no repeat of those events. It is quite clear that what happened in County Roscommon could happen elsewhere and we must ensure it does not. All Members want to work together to that end, but it will require legislation that protects the people rather than the banks.

It is quite distressing for me to see what happened to people I know for many years. Like the Minister and other speakers, I acknowledge that we must condemn all violence and all types of thuggery. However, this unfortunate event began with the eviction. Nobody in this House can condone what happened last Sunday evening. However, because a criminal investigation is ongoing, I will say no more about it.

I accept that there must be more engagement by the banks. Yesterday, I spoke to representatives of KBC bank on behalf of the family and asked them take a step back, allow the situation to calm down and begin negotiations as soon as possible. I have had four engagement in the past two years with banks in the Roscommon-Galway region, which I represent, and in each case I was able to get matters solved through negotiation. However, people must tell us if they have problems and allow us to get involved with the banks. I agree that the banks need to do more and to be more accommodating.

I call for calm in our region and, please, let everybody work to settle this situation which is currently quite critical.

Although any repossession of property is deeply regrettable, the number of repossessions is declining. The latest statistics from the Courts Service for this year indicate a downward trend in the lodgement of applications for possession orders. In addition, the total number of repossession orders granted by the courts in quarter 2 of this year is down on that in previous years. It should be noted that in quarter 2 of this year more repossession cases were refused, struck out or withdrawn in the courts than granted.

I acknowledge that there is some disquiet about private security operators who may be employed by third parties to enforce court orders. I recently requested that my officials examine the regulation of such operators with a view to bringing them within the remit of the Private Security Authority. I expect a report from an intergovernmental group chaired by a senior official of my Department in January 2019 and I will take all the necessary and appropriate steps in light of the report.

However, I reiterate my very strong concerns regarding vigilantism and criminal gangs operating outside the law. Such activity has no place in Irish society and cannot be equated with the lawful enforcement of court orders within the State. Any action outside the law is unacceptable.

Third Level Admissions Entry Requirements

I thank the Ceann Comhairle for selecting this important issue for discussion. I am glad that the Minister of State, Deputy Mitchell O'Connor, is present. She is very familiar with the import of this issue and I have no doubt she is eager to resolve it in a positive way. It is a very invidious situation affecting a large cohort of young graduates and undergraduates. Concerns over this important issue have been brought to my attention and that of my colleagues, Deputies Sherlock and Brendan Ryan, over the past month or so. I have no doubt that several other Members have also been alerted to the grave unfairness and injustice perpetrated upon students who completed their leaving certificate prior to September-October 2017 when changes to the minimum entry grades in Irish, English and maths for entry to primary teacher education programmes were introduced. My colleagues have made strong representations on the issue. Like them, I have no problem with the Minister of State or her officials raising the minimum entry requirements in those core subject areas as part of a policy objective of ensuring quality teaching and learning in primary schools. I am aware that the proposals emanate from the 2011 literacy and numeracy strategy and reviews thereto and that the Teaching Council had an input into them.

The changes in the minimum entry requirements take effect from 2019 and students who entered the leaving certificate cycle in 2017 and will graduate in 2019 are aware of it. However, I am focusing on a specific cohort of students. What will happen to the many students who entered degree courses between 2013 and 2018 and wish to pursue a postgraduate masters in primary education? What about those who completed their undergraduate degree some years before deciding to apply to the masters programme? They may have completed their primary degree in 2016 or 2017. When such students sat their leaving certificate four, five or six years ago, they were assured by guidance counsellors that the minimum entry requirements were at a particular level. However, the goalposts have now been moved by officials - I am not stating that the Minister of State did so - and deprived those students of the ability to qualify for the masters in primary education at a time when teachers are badly needed. Deputies complain that teachers are going to Dubai. The Government will drive them all out of the country. The Ceann Comhairle will have to go back to Dubai and get a donkey on which to bring the teachers back. We are driving them out of the country.

There are 2,500 of them there.

Those students attained the necessary minimum requirement for the masters in primary education when they sat their leaving certificate some years ago and had a legitimate expectation, which is a principle of European Union law, that they would qualify for the course because they met all requirements that were in place at the time.

In order to meet the new minimum requirements, this cohort of students with a primary degree will have to resit the leaving certificate. Talk about Hobbe's law. A person could have a first or second class honours degree and be told that is no good because he or she does not meet the new minimum entry requirement in Irish. The Ceann Comhairle is fluent in Irish, tá sé líofa, and fair play to him. Those students have primary degrees. I only have a few words of Irish, unlike the Ceann Comhairle, but I know there is damn-all difference between a C3 and a C2. It is a semantic difference. We must ensure the Irish language is propagated and promoted but by changing the minimum requirement from a C3 to C2 we are depriving a significant cohort of students of the opportunity to become a teacher. This injustice must stop. It is likely that legal action will be taken. The officials must change this policy. I have made them fully aware of the difficulties it is causing. The officials are decent and reasonable and are wondering about opening Pandora's box. One should not do so. A defined cohort of students has been affected.

We must address this immediately. The Minister of State knows more about primary education than I will ever know, and she knows exactly how to resolve this.

I thank Deputy Penrose. I have received the same queries that were raised with him and his colleagues.

I was in the United Arab Emirates and met a number of Irish teachers there. There are more than 3,000 of them there. The one message I received there was about the great respect for Irish teachers teaching abroad. Often this is not evident in Ireland. A really proud individual running a school in the United Arab Emirates ran over to me and told me she would employ only Irish teachers. My face dropped because I am aware of the lack of teachers in the system here but the comment indicated how good Irish teachers are. I am highly cognisant of the importance of having a teacher at the top of the classroom who is able to deliver quality teaching to the children. With regard to the question the Deputy asked, I realise he knows all the details. The changes were identified. We came up with a literacy and numeracy strategy. This occurred under former Minister Ruairí Quinn. I pay tribute to him in this regard because our standard of literacy has gone right up. Ireland is one of the best in Europe in English reading and mathematics.

Many of the issues have been identified. The officials feel these issues are very complicated and complex. The Teaching Council provided advice. It commissioned the Economic and Social Research Institute to carry out research on its behalf to inform deliberations on the grades students should have in their leaving certificate examinations. The grade for English is now H4 and that for mathematics is H7 or an O4. This reflects the new grading system. The changes had regard to the Department's 2015 policy, Supporting a Better Transition from Second Level to Higher Education: Implementation and Next Steps. The changes were announced in October 2017 to take effect for entrants to primary initial teacher education programmes from 2019 onwards. This was to ensure account was taken of students who had already commenced the senior cycle and would be sitting the leaving certificate in 2018. However, to exempt all students with a degree from meeting the new requirements, as suggested, would take away any benefit arising from the changes. In practical terms, this would mean that, years from now, those who met the old entry requirements could apply for the professional master of education course alongside those who would have to meet the new requirements. It would also mean a difference straight away between the standard for students on the postgraduate course and those who have just done the leaving certificate examination and who are starting an undergraduate teaching degree. On behalf of the Department, I appreciate the Deputy's concern for students who had planned to apply to pursue the professional master of education qualification for primary teaching and who no longer meet the minimum entry requirements. I have past pupils in that category. The Department has received a number of submissions in this regard, and these are currently under consideration to ascertain whether a solution can be found for the students most affected.

I have no doubt that the Minister of State understands the details of the issue very well. The change, however, is not a trivial or small one. For those concerned, it represents a considerable setback, and it is causing great stress, anxiety and upset. The Minister of State will agree that upsetting students is nothing to be proud of. The Minister of State can achieve the objective by ensuring the minimum requirements will apply only prospectively. The Department announced that, from 2017, every leaving certificate student knew what requirements had to be met, in the view that there was no problem. The response circulated is the glib Department answer. It does not pass legal muster. The point is that the students were assured that a C3, for example, was adequate, and they did their undergraduate degree on that basis, with a view to moving on having obtained their C3 along with their music degree, arts degree or whatever. The Department unilaterally changed the goalposts, however. That is not right in law. Under European law, this falls. The Minister of State's officials better get off their butts and make sure what I propose is done immediately. We need the students to be notified in January or February in order they can start their master's in education course in September. The answer circulated suggests somebody who qualified in 2011 would be affected if applying to do the master's course in education in 2021. These individuals are probably out in Dubai or elsewhere and are married and settled down. The last thing they are worried about is the master's degree in education.

The reply adds insult to injury. How dare the officials say there is something on the website that can take the place of the leaving certificate grade. Does the Minister of State think we came up the River Liffey in a banana boat with a goose pulling it? That is nonsense. In other words, a student who has achieved a 1.1 or 2.1 in his or her primary degree is told to buzz off to some place to try to get a C2 or C1 in Irish or whatever is required. That is a typical gobbledygook bureaucratic reply that I resent. I want the Minister of State to solve this problem because, if she does not, we will see the students in court.

I said to Deputy Penrose that the Department has received the submissions and that they are currently under consideration. I expect a further update from officials in January, which I will share with Deputies.