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Seanad Special Committee on the Withdrawal of the United Kingdom from the European Union debate -
Thursday, 4 May 2017

Engagement with Central Bank of Ireland

Apologies have been received in advance of the meeting from Senator Frances Black, whose substitute is named as Senator Grace O'Sullivan. Before we begin, I remind members and witnesses to switch their mobile phones off or to airplane mode.

On behalf of the committee, I am delighted to welcome Dr. Gabriel Fagan from the Central Bank of Ireland and his colleagues, Mr. Mark Cassidy and Ms Mary-Elizabeth McMunn, for this very important session as we continue the work of the committee. We have already had quite a few discussions with a number of people on a range of areas, but today's sessions will focus very much on the economic impacts of, and possible solutions to, the problems presented. We very much look forward to the engagement with the witnesses. After the initial statement we will have a chance for a very good back-and-forth through questions and answers. However, before we begin, I must read out a note on privilege.

Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official either by name or in such a way as to make him or her identifiable. By virtue of section 17(2)(l) of the Defamation Act 2009, witnesses are protected by absolute privilege in respect of their evidence to the committee. If they are directed by the committee to cease giving evidence on a particular matter and they continue to do so, they are only entitled thereafter to qualified privilege in respect of their evidence. They are directed that only evidence connected with the subject matter of these proceedings is to be given and they are asked to respect the parliamentary practice to the effect that, where possible, they should not criticise or make charges against any person or entity by name or in such a way as to make him, her or it identifiable.

I again thank the witnesses for their presence. I pass the floor to Dr. Fagan.

Dr. Gabriel Fagan

I welcome the opportunity to appear before the committee to discuss the implications for the Irish economy of hard and soft Brexit scenarios. I am joined by Ms Mary-Elizabeth McMunn, head of our supervisory risk division, and Mr. Mark Cassidy, head of the financial stability division. Mr. Cassidy is also the chair of our internal Brexit task force. This task force was initiated approximately one year in advance of the referendum and indicates our proactive approach to preparing for potential Brexit-related issues. The task force comprises representatives from divisions across the bank and provides comprehensive assessments of Brexit-related matters to the Central Bank Commission and to the bank management generally.

Brexit will have significant implications for trading arrangements between the UK and the EU with effects also on labour markets, investment patterns and capital flows. The impact will depend crucially on the terms of the UK’s exit, in particular the timing and nature of a final trade deal. In addition, the impact will depend on the nature of the transitional arrangement, if any. Ireland stands out as the EU economy likely to be most affected. This reflects the size and nature of our economic and financial linkages with the UK, including our shared land Border. In my opening remarks I will set out the assessments of the Central Bank regarding the channels through which the economy is likely to be most affected, with reference both to challenges and opportunities, as well as some important policy issues for national authorities, including the Central Bank itself.

Ireland's reliance on UK markets for our international trade has reduced considerably over the past 40 years but remains significant. Before Ireland's accession to the EU in 1973, the UK accounted for over 50% of Irish trade. This has fallen to under 14% for goods exports and under 20% for services exports. Almost 26% of the goods imported into Ireland, but only 8% of services imported, are from the UK. Nevertheless, Ireland is still more reliant on the UK export market than any other EU country. Certain sectors of the economy rely more on UK markets than others. These include traditional manufacturing sectors, agrifood, materials manufacturing and tourism. Interestingly, these sectors are often quite labour-intensive, and it is notable that a large number of small and medium-sized enterprises are engaged in UK markets either through trade or tourism.

The overall impact of Brexit on the Irish economy and financial system remains subject to considerable uncertainty, depending in large part on the nature of the new trading arrangement to be agreed between the EU and the UK, including possible transition arrangements and the capacity of our economy to adjust. From communications issued by the UK Government, we know that the UK will not seek continued membership of the Single Market, or a "soft" Brexit, as red lines for the UK are the control of immigration and the ending of the jurisdiction of the European Court of Justice in the UK. It will instead seek an ambitious free trade agreement with the EU, perhaps some form of customs agreement and some form of transitional arrangement or, as the UK calls it, a "phased process of implementation". Under this scenario, an agreement would be based on tariff-free trade in goods but not services.

Over time, some regulatory divergence between the UK and EU may emerge, which could lead to an increase in non-tariff barriers. This seems to plot a middle course between a soft and hard Brexit, although until the negotiations are finalised, a hard Brexit cannot be ruled out.

Under a hard Brexit scenario, the UK would leave the EU without a trade agreement and would instead exercise its rights under the most favoured nation, MFN, clause of the World Trade Organization, WTO. Under this most damaging scenario, goods trade would be subject to tariff and non-tariff barriers, which would vary across sectors, leading to more significant negative effects on trade. Under this scenario - the hard Brexit - our estimates suggest that after ten years, GDP would be lower by 3% and the number of people employed would be 40,000 fewer, compared with a benchmark no-Brexit scenario. This estimate is in line with those of the ESRI and the Department of Finance. These aggregate figures mask the fact that certain sectors and indeed regions of the economy would be disproportionately affected and some small and medium-sized enterprises are likely to be among the hardest hit by Brexit.

A hard Brexit may also require sudden regulatory and financial adjustments, since UK financial firms would lose passporting rights associated with EU membership. This is likely to be accompanied by a period of heightened uncertainty in the financial services sector. The importance of a transitional period to mitigate potentially disruptive cliff effects in the workings of the financial system must be recognised.

Our analysis is that the overall economic effects for Ireland in both the short term and longer term will be negative. The effects will be much worse if no free trade agreement can be reached. In the short term, before new arrangements come into effect, which is not likely to be until at least 2019, the main effects may come through the exchange rate channel and uncertainty. The value of sterling has generally traded in the range of 10% to 15% weaker against the euro since the time of the Brexit referendum in June 2016. This makes Irish exports to the UK more expensive. There is already some tentative evidence of this exchange rate effect in the economic data. For a number of important food and beverage sectors, the value of exports declined last year even though volumes increased. This may be some indication of exchange rate fluctuations having an effect on export values. Irish imports will also be affected by Brexit, that is, the prices that exporters receive for exports to the UK. Imports will also be affected by Brexit. In the near term, the weaker value of sterling has put downward pressure on import prices, which is beneficial for consumers and producers who use UK imports in the production process, but can leave Irish producers who are competing in the same markets at a competitive disadvantage.

Over the long term, slower growth in UK consumption and investment, if it materialises, and in particular, any new barriers to trade including tariffs, will also weigh on some Irish firms. In the event of a hard Brexit, the trade impact on different EU countries will depend on the share of total exports and imports accounted for by the UK, the size of tariffs imposed on exports, which differs very significantly across sectors and products, and the sensitivity of exports to price changes, which also varies across sectors. A detailed EU-wide sectoral analysis undertaken by ESRI researchers shows that Ireland is the economy most affected by Brexit due to the fact that we have the highest share of our exports going to the UK and that the tariff rate on our exports to the UK would be almost double the EU average due to the very high rates on agricultural and food products under WTO rules. Their analysis shows that under a hard Brexit, and taking into consideration all these factors, Irish exports to the UK might fall by around 30%, which would be equivalent to an overall reduction in our exports of over 4%. The imposition of tariff or non-tariff costs would not only reduce trade volumes but also increase import prices, which would likely be passed onto consumers.

From a financial stability perspective, we are monitoring the impact that Brexit will have on the Irish banking system. Weaker UK and Irish growth will negatively affect those banks which have significant UK exposures. The weaker sterling exchange rate will reduce the value of profits and assets that are denominated in sterling. Other financial sector firms may also be affected, either positively or negatively, depending upon their business models and the extent of their UK business. Since before the referendum the Central Bank has been engaging with firms from across the financial sector to ensure that they are fully accounting for risks that may arise from the Brexit process.

The risks and uncertainties regarding Brexit underline the importance of stability-oriented policies, notably in the area of public finances and financial system stability. Also, the challenges in areas of trade and investment underline the importance of maintaining competitiveness and ensuring that Ireland remains a flexible, adaptable economy that is supportive of enterprise and innovation. The risks from Brexit can be mitigated by further expansion of our trade links with other EU and non-EU countries, particularly for the indigenous sectors that are currently more reliant on UK markets.

Brexit will also present new opportunities for the Irish economy. Most notable in this regard is potentially stronger inward foreign direct investment as a result of both a relocation of existing UK-based FDI to Ireland and new FDI flows locating to Ireland instead of to the UK. It is too early yet to see any evidence of such flows but they could create new employment opportunities and add to growth in the economy, while at the same time potentially creating challenges and opportunities, including for the property sector. Already Irish commercial property agents have noted increased office accommodation enquiries from British companies. In addition to the availability of office space, sufficient housing and adequate infrastructure will be required to accommodate any additional investments in Ireland, including notably in the international financial services sector.

In the financial sector, new business lines and new firms bring new opportunities, new challenges and new risks. In addressing these, it is important to note at the outset that the Central Bank does not have a mandate to promote the development of financial services in Ireland. Rather, our mandate is to safeguard stability and protect consumers. In assessing any application, we are guided by that mandate such that each application is assessed to understand the business, its risks and how they are managed and mitigated. This is critically important for the stability of the sector as a whole, for ensuring that financial firms are soundly financed and soundly run, and for ensuring that consumers of financial services are appropriately protected.

Since the referendum, as firms weigh their options for a post-Brexit world, the Central Bank has received a large number of Brexit-related authorisation inquiries from across all sectors, including banks, insurance companies, investment firms and payment institutions. They have been considering a variety of factors relevant to their business, and wish to understand our approach to authorisation and ongoing supervision, such as substance, risk management and governance structures.

Overall, the level of Brexit-related activity and developments is in line with what we expected to see following the referendum decision. In the coming weeks and months, as firms make decisions, we expect to see a meaningful increase in applications for authorisation or for extension of existing business. As the Governor, Professor Philip Lane, has already said, we deal with inquiries in an open, engaged and constructive manner and are committed to providing transparency, consistency and predictability in our regulatory decisions. To deal with the increased level of activity, we have increased or are in the process of increasing our authorisation teams across all sectors. Since Ireland is already home to a large-scale international financial services centre, we have considerable experience in dealing with such authorisations. Our regulatory approach is in line with sound practices being agreed across Europe; our responsibility is to ensure that firms authorised to operate from Ireland demonstrate compliance with EU requirements. To this end, we seek to ensure that an entity will be substantively run from Ireland and that the set-up permits effective supervision, with local management accountable for decision making. The Central Bank has consistently said it is not sustainable to entertain proposals that fall short of these basic requirements.

We are actively engaged in the work of the European supervisory authorities and with our colleagues within the ECB Single Supervisory Mechanism, SSM. It is worth noting in this regard that the SSM has recently issued important guidelines for banks looking to relocate their businesses within the euro area. The guidelines set out the ECB's supervisory expectations in a number of areas, including internal governance, risk management and outsourcing. ESAs are also advancing their work on these issues in respect of other entities such as securities firms and insurance companies. Regardless of where a firm locates, it should expect that there will be rigorous assessment of the applicable EU regulatory standards and intrusive ongoing supervision of its activities.

The Central Bank of Ireland will continue to monitor Brexit developments in this area and, via its Brexit task force, co-ordinate expert analysis from across its supervisory and economics functions to ensure an integrated and comprehensive understanding of economic, financial and regulatory risks.

I thank Mr. Fagan. Before I bring colleagues in, I have three quick questions. On authorisations, Mr. Fagan mentioned a number of inquiries. How many applications for authorisation have been received and what is the average waiting time to process them? Mr. Fagan mentioned the opportunity in respect of trade expansion. Is he interested in sharing the names of those countries or regions which are most ideal in terms of possible expansion? The first questioner on my list is Senator Joe O'Reilly.

I welcome our guests and thank Mr. Fagan for his submission. To begin where the Chairman left off, it has been alleged in some media outlets and anecdotally that the Central Bank is too restrictive and conservative in its authorisations and that we run the risk of missing opportunities. While I understand the point Mr. Fagan made on that, is he happy that the bank is going to strike an adequate balance between the need to attract new financial services and banking, employment and trading opportunities for the country and the need to operate proper restrictive practices? That has been alleged and I am interested to hear the response.

How much of a bonus will we see? One of the opportunities in Brexit is that we might attract new financial services to augment business here. We are being told that Frankfurt is going to win the lion's share. How optimistic is Mr. Fagan? I acknowledge that he will not want to be overly speculative, but what is his sense of that opportunity from Brexit in the event that our previous distinguished speaker and former Taoiseach, John Bruton, is not correct in his hope that Britain will not leave?

I turn to trading arrangements. Assuming that there is a form of customs agreement, does Mr. Fagan rule out completely the prospect of free trade? We have obviously had a huge achievement in the area of free movement of people, which has been well discussed and documented in the last few days. It is not necessarily totally a matter of Mr. Fagan's remit. In any event, the achievements there are to be noted and were a critical first set of achievements. Now, however, the major focus is on trade in respect of which there was a somewhat disappointing report this morning from accountants. Does Mr. Fagan see any hope of the status quo continuing to obtain? In the event that it does not, what levels of custom duty will apply in practice? How greatly would they devalue our exports? What sectors of the community will be hit? Am I right in thinking that agriculture is under huge threat and that some agricultural exports may not be viable?

Mr. Fagan referred to transition arrangements. Is he hopeful of a delay? Can he elaborate on what he meant in saying that we might achieve tariff-free trade in goods but not services? I am interested in teasing out, in practical layman's terms, how Mr. Fagan sees Brexit impacting on specific exports in the cost added, the degree to which value will be weakened and the degree to which the domestic economy is threatened. How will arrangements unfold? Will people have to pay direct customs? If there were no customs, would a monitoring process for goods crossing the Border still be required as it will be a frontier between the EU and UK? Will there have to be a checking of goods at that level involving a cost for exporters? What are the nuts and bolts of how Mr. Fagan envisages it working so that we can be informed in our discussions with the sectors seeking to discuss the matter with us?

There are a lot of questions for Mr. Fagan there. The notion of tariff-free services has occurred to me. To take something close to home, if a lawyer in Ireland provides services to a British firm and sends a bill, in what sense would there be tariffs on the payment made? It might be a lawyer's or a financial adviser's bill. I find it difficult to grasp how, apart from the lawyer paying VAT in Ireland or Britain, tariffs on services could operate very well.

Given that the Central Bank takes the view that Ireland is the most affected country and that the effects could be quite serious by sector, can Mr. Fagan say something about special arrangements for Ireland? The former Taoiseach, Mr. Bertie Ahern, mentioned the possibility of a common trading area as well as a common travel area. In that context, I presume the disengagement of the UK from the EU will involve a multi-annual period. Has any consideration been given, by the Central Bank or any of the State agencies with which it operates, to different phasing arrangements for Ireland? In other words, if tariffs were to come in, could they come in at a slower rate for Ireland or over a more extended period?

I welcome the witnesses. My first question is on the efforts that have been made by the remaining member states to attract banks and financial services. There are reports that there will be a race to the bottom in terms of supervisory standards, which, considering all that we have been through with the banks not only here but abroad, is shocking. My colleague has asked if there will be flexibility so that we can attract banks and financial services to Ireland. In what areas will we be allowed to be flexible? Where can wheeling and dealing be done to attract businesses without compromising standards or taking an undue risk of compromising a system put in place to protect people in member states who have had to bear the brunt of the near collapse of the banks?

I have heard comment and discourse in the media suggesting that if we do not get what we want in the event of a hard Brexit, we should leave or threaten to leave the European Union. This does not appear to be a sensible proposition. It is not clear what the British want from Brexit or even if they know what they want or know how they propose to get it. All we have heard is what they do not want and everything seems to point towards a hard rather than a soft Brexit.

The witnesses described how our dependence on the UK market has declined since we joined the European Economic Community in 1973. Sectors such as agrifood and indigenous manufacturing continue to rely on the UK, however. People in the west are not expecting financial services companies to wing their way over to us. Galway city is probably the only location in the region that stands a chance of securing such investment. We are preparing in whatever way we can for Brexit. I ask the witnesses to comment on the suggestion that the Government's position was weakened by its failure to threaten the European Union with leaving.

On the rules associated with the fiscal compact, the witnesses and speakers at previous meetings described the need for businesses to restructure and find new products and markets. The Government intends to assist companies to do this. This will require an increase in expenditure, which could put pressure on the Government to increase the fiscal space. Should the Government seek a derogation from the expenditure rules under the exceptional circumstances provided for in the treaty? Is such a derogation being considered and would it give us flexibility to deal with the fallout from Brexit, especially given the current trajectory of the negotiations?

On state-aid rules, certain regions, specifically in the west, are especially disadvantaged and are not experiencing the economic recovery to the same extent as other regions. Figures from the 2016 census show that the population in the west is declining and ageing. The reason for these trends is that young people are leaving owing to a lack of job opportunities. Another critical factor is that areas in the west do not have good infrastructure and did not benefit from investment in roads and rail during the Celtic tiger period.

Ireland West Airport Knock is strategic infrastructure in which has been earmarked for growth. State-aid rules present an impediment to its expansion, however. I understand a temporary arrangement in respect of state-aid rules was in place in 2009 which allowed us to deal with the banking crisis. Could we do something along these lines again and invest in infrastructure in disadvantaged areas to stave off the negative effects of Brexit and address infrastructure deficits? This would allow us to fund Ireland West Airport Knock without seeking the European Commission's approval every time the airport requests additional funding. I understand the maximum percentage of funding that can be provided is 90%, whereas Ireland West Airport Knock needs 100% funding in certain areas. Under current rules, the airport can only be offered assistance in safety and security measures, which precludes capital investment for expansion. I ask the witnesses to address the issues I have raised, especially my final point.

I thank the witnesses for attending. My concern with respect to Brexit is in finding out what solutions the witnesses may be able to offer. The problems associated with Brexit have been well rehearsed in the public domain and the discussion appears to be focused on whether it will be a hard or soft Brexit. In my view, it will be a somewhat disorganised process in which some solutions may be negotiated at an early date, while it may prove very difficult to negotiate solutions in other areas. My focus, therefore, is on what solutions the witnesses are in a position to offer to the committee or the Government.

Does the Central Bank have all the expertise it requires or does it need to employ or acquire additional expertise in specific areas? If additional expertise is required, has the Central Bank sought Government approval to employ additional staff and, if so, what has been the Government's response?

The areas highlighted by the witnesses include materials manufacturing, agrifood and tourism. Agrifood and tourism will be two key areas in terms of the downside of Brexit. Has the Central Bank modelled different scenarios and solutions to the problems that will arise based on certain outcomes? If so, does it have a best and worst case scenario, particularly in agrifood and tourism?

Reference was made to the possibility of a 30% fall in exports to the United Kingdom, which is a significant figure by any measure. Michel Barnier and various other people to whom we spoke in Brussels indicated that the Commission would take a favourable view of requests for support for market diversification activities and the construction, if one likes, of better infrastructure with European Union partners, for example, the establishment in the south east, perhaps in Waterford, of a major port that would provide a direct link to Europe, thereby precluding the need for goods and people to traverse the United Kingdom. Has the Central Bank examined this possibility, including construction costs and the savings that would be achieved in respect of tariffs levied on entering and departing Britain?

I am particularly concerned by the statement that exports could decline by 4% overall. The documentation is very clear in this regard. However, the figure masks a very serious impact on companies that are almost married, as it were, to the UK market. We have been somewhat lethargic in developing markets in countries whose languages we do not speak. England has always been a safe bet. Has the Central Bank explored this issue? Several Irish suppliers in the agrifood sector are recognised worldwide. However, we also have many small indigenous companies, including one-man and two-man operations in certain niche areas, which export solely to the United Kingdom. A 30% decline in trade with Britain would effectively knock these companies out of business. EU rules limit the supports that can be provided to such companies. Has the Central Bank examined which rules need to be relaxed to provide the supports that would be needed during a transition period?

I am more interested in solutions than problems because the latter have been so well rehearsed that the dogs in the street are barking about Brexit. That discussion does not give us an idea as to where we are likely to go and the Central Bank appears to be the only organisation that is focused on the impact of Brexit on the entire economy, sector by sector.

I thank the witnesses for their time. I am sorry for throwing all these questions at them.

I thank Senator Craughwell. We have 20 minutes remaining with three more speakers indicating and the responses from the Central Bank. Let me repeat that I ask all Senators to keep their contributions to questions, and ideally, to limit them to one to two minutes. That applies to everyone and I am not just picking on the most recent speaker.

I thank the witnesses for their presentation. Ireland is in the unfortunate situation, and the Central Bank in particular, of suffering from a post-banking crisis stress disorder. Unlike other European member states, having gone through a banking crisis and regulatory issues around it, the human reaction is to over-regulate. That happened and was due to a lack of oversight and regulations, issues with which the officials are well aware. As a result, we now are seen to be more cautious than anybody else.

How many applications, if any, has the Central Bank rejected? My concern is that companies will not even bother to apply but will think Ireland is far too regulated at this time. When people do not apply, we do not know how we are doing compared with other countries. Is there an analysis of how many financial service companies in Britain have made applications to other European countries and whether they made multiple applications? Will they hedge, as they would in any other financial situation, and apply in Ireland, Frankfurt and Luxembourg? While I acknowledge the Central Bank does not have a role in attracting companies, the critical question, which is directed at Mr. Mark Cassidy, is whether, since the task force was established and especially since Brexit, the Central Bank has introduced reforms to make Ireland more attractive. That is the only thing the Central Bank can do that is within its gift. Has the Central Bank made changes to itself since Brexit to make it more attractive? If the Central Bank has not done that, that is of concern to members. If the Central Bank has not done it, is it planning to do it?

A number of the questions I had intended to ask have been covered. My question is on similar lines to that of my colleague, Senator Mark Daly. We have not fully emerged from the major banking crisis and now Brexit has been sprung on us. Recently I used the analogy of a carpenter with the ingrown toenail who hits his thumb with the hammer. He soon forgets the ingrown toenail but it has not been cured or gone away. His focus comes on to his throbbing thumb. Is there a possibility of that scenario playing out here? While Brexit is very important and has to have a major focus, could it take all our focus away from other areas that still very much need remedial care as we have not fully turned the corner? I seek the views of the witnesses from the Central Bank, not only from its perspective but possibly whether we as a nation, have a tunnel vision on Brexit. What potential and possible fall-off could there be because of it?

I thank members for their contributions. I will now revert to Dr. Fagan and his colleagues.

I have one tiny question. In respect of the depreciation of sterling, is that regarded as permanent or semi-permanent or is it something that might disappear? Have the witnesses any views on that?

I thank Senator McDowell.

Dr. Gabriel Fagan

I thank the Chairman and Senators for those questions. I propose to hand over to my colleagues and Ms McMunn can address some of the questions related to authorisations and related matters.

Ms Mary-Elizabeth McMunn

I thank Dr. Fagan. I thank the Chairman and Senators for their questions. I will group a number of questions together as they are variations on a theme.

I will deal with the position around conservatism and the questions on the other jurisdiction in terms of attracting their share of financial services companies.

From our perspective, we are very conscious of the potential for companies to move to Ireland as a result of Brexit. As we have outlined in our opening statement, however, we do not have a role in attracting businesses to Ireland. That promotional role has been explicitly removed from our mandate because it was felt that it compromised our authorisation and supervisory stance.

Let me take a step back. Central to the concern from our perspective is implementing our mandate, which is about financial stability, the protection of customers and that there is a well-functioning and well-regulated financial system. For any authorisation process, one must think in terms of where one is starting from. We are starting from an understanding of what is the business that is being presented to us; what are the risks associated with that business and how those risks are managed and mitigated. Our starting point is not what is the most conservative position we can adopt in respect of this applicant firm. It is about understanding the risks of that particular business. We also seek to ensure that customers are very central to the business proposition. From a financial stability perspective, we would stand back and ask what would be the potential harm to the citizens, to the economy and so on were this firm to fail. From that perspective, the Governor mentioned at our press conference on the annual report yesterday that it was his ambition that regulatory issues would not play a role in decisions around relocation. Many different factors go into influencing the relocation of a firm to a particular jurisdiction and I can go into those. We are not proposing to comment on individual firms' specific relocation decisions to various different jurisdictions because as I said, a range of factors influence where firms chose to locate.

When we look at supervision, the EU has a harmonised approach to regulation of financial services and our approach to authorisation is firmly embedded in the European system of financial supervision. What is important from our perspective is that regulatory authorities ensure that any migration of those firms does not lead to any disjointed or fragmented supervisory system. Regardless of where an entity seeks to locate, firms should expect a rigorous application of both authorisation standards and ongoing supervision. We are actively engaged at a European level with our colleagues in the ECB and in the other supervisory authorities to ensure that UK firms' Brexit-related decisions reflect a consistent approach across the EU. We have referred in our opening statement to some guidelines that have been issued by the ECB recently with regard to frequently asked questions, FAQs, about what one should expect in the context of a bank, for example, relocating to the euro area. It also sets out supervisory expectations on a number of key issues and we are very supportive of that. Other European authorities are moving in the same way.

I will deal with Senator Paul Daly's point on specifically taking away the focus from existing areas. There is a significant ongoing effort across the organisation on Brexit-related activity. We also continue to fulfil our mandate and I will speak specifically to supervision from an ongoing supervisory perspective. We are not taking the focus off our existing mandate in respect of ongoing supervision, intrusive supervision, enforcement and so on. While we have an incumbent population for which we need to seek to do our job, perhaps specifically in the context of the authorisation processes and the Chairman's direction on time, the most important perspective from our side is that we are keen to be very transparent about the process. We regulate more than 10,000 financial services providers in Ireland. We have alluded to the sectors in our opening statement. The nature of any application is very particular to the type of entity that is presenting itself. That flows directly through to the timeline around authorisation.

For example, while the principles of our authorisation and gateway roles are the same, their practical implementation is very particular to the type of application on the table. If, for example, we were considering a qualifying investor fund, the authorisation could be turned around in a matter of days. A banking licence, however, is an entirely different proposition and the SSM regulations speak to at least six months in the context of turning around a banking application but a decision must be made within a year.

We publish six-monthly reports on our regulatory performance against standards we set for ourselves regarding authorisation timelines so we measure ourselves against timeliness standards. This outlines not only the number of applications that are live, but also how we have performed against our own protocols for meeting them. The last report in this regard was published in February. It dealt with the period from July to December last year. The next report is due in the summer and will cover the period from January to July. Regarding authorisation, it is important to say that our goal is to be engaged, open and pragmatic and that it is a rigorous process with the firm. However, as we recognise, particularly for complex applications, that firms may need some help, we have a pre-application process whereby we engage with institutions to give them some assistance. As for what a completed application might look like and what might be the key areas one might need to address, without trying to evade the question, it is very difficult to give an indication as to the time it takes to authorise a firm because it is very particular to the type of authorisation with which one is dealing.

We have received a large number of inquiries since the referendum and they have been pretty steady. What we are starting to see with that pipeline activity is that it is migrating as Article 50 has been triggered but also as firms are starting to narrow down their own options and make decisions about possible relocation choices. We expect much of that activity to take place over the rest of 2017. The difficulty - and the Governor mentioned this yesterday - is that when one talks about numbers of inquiries, some are very marginal in nature and some require quite extensive engagement with us. Both cases are represented as a single number so it is often not useful to talk about the number of inquiries in that regard. In addition, as I think alluded to by one of the Senators, many firms are making inquiries across a number of jurisdictions at the same time and there are reasons for not pursuing an inquiry further. In some cases we do not know and, in others, it can be just as the firm gets a clearer understanding of the implications of Brexit for its own strategic planning. There can also be some of the additional factors - infrastructure, culture, language - that are outside of regulation and supervision. What we can say is that we are engaged with firms at all stages through that process and we have been very open to doing so. In addition, we will publish the number of applications. They will come through in the summer because they will be linked to our performance against the standards. However, there could be a number of institutions that might reflect a small amount of financial services activity. There could be one application that is very significant in terms of its financial services presence, so again, there is the difficulty in outlining a few numbers. However, to return to one of the Senator's other questions, we do expect, given our engagement with those firms, that a good proportion of those will come through to actual live applications. It is very difficult at this stage to be definitive about what that proportion is for some of the factors as outlined but also because many of the firms have not made decisions at this point in time. However, given our engagement with the firms, it seems likely they will translate into live applications.

Ms McMunn raises a question. Because of the financial crisis, the Central Bank's rules were changed so that it is not out there championing the cause of Ireland being a location for financial services investment and that has changed the bank's remit. How many other central banks in the EU have the same standard, the same rule, that they are no longer advocates and that they just process the application and that is it? This goes back to my earlier question to Mr. Cassidy. Is that making us uncompetitive? If the Central Bank of Luxembourg is out there championing Luxembourg and the Central Bank of Ireland is not championing Ireland, we had better change that rule because if we do not, we will lose out.

Ms Mary-Elizabeth McMunn

To answer the Senator's question directly, I do not know the extent of comparability across other central banks that are responsible for regulating and whether that forms part of their mandate or otherwise. I am not sure.

Perhaps Mr. Cassidy could answer the question. From a competitive point of view, this is a fundamental issue for Ireland for examination by the task force. If other central banks are not only being regulatory bodies but also are actively engaging on behalf of their countries, we will not be able to attract financial services. We will be looking at this in two years' time wondering why we did not get these guys. It will be because Luxembourg was championing its banks, Germany was championing its financial services centre and the Netherlands was championing its own but our Central Bank was not doing likewise. That is not the Central Bank's fault but that is the rule in place at the moment and it is one of the regulations I am talking about that needs to be changed.

Ms Mary-Elizabeth McMunn

With all the authorities that are linked to the same European standards, there should not be any loosening of standards simply to attract industry-----

I am not saying that. We have changed our standards. That is the financial crisis and post-traumatic stress disorder I am talking about. We changed our standards because the Central Bank was out there looking for business. This is a hangover from the financial crisis that will now affect our performance. I suggest that the task force should have answered the question when it was examining the opportunities of Brexit. Was this one of the things it examined? I am not talking about the standards; I am talking about the basic rule of central banks in other jurisdictions. Are they out championing their financial services? We do not know and we need to find out. They are out championing their causes for their financial services sector and we are not allowed to do so for ours. If that is the case, we need to find out and we need to change our rules.

Dr. Gabriel Fagan

Regarding the promotion of Ireland as a location for financial services, we already have in Ireland very effective organisations such as the IDA-----

I understand that.

Dr. Gabriel Fagan

-----that are covered by that-----

Are other central banks able to champion their financial services? The Central Bank was doing so previously, so obviously EU regulations allow for it. Are other central banks doing it where we are not?

Dr. Gabriel Fagan

We do not know that but it is very important to realise that it is particularly in banking that there is the Single Supervisory Mechanism. There is essentially a more or less fully harmonised approach to banking supervision across Europe. Therefore, an individual competent authority in another country cannot offer a better regulatory deal than it will get in Ireland. It is very important to recognise that this is part of a Europe-wide framework. It is very strong in banking. There is a single institution. However, even for the other sectors of finance - for insurance, funds and so forth - there is a kind of common set of standards applied.

The Senator makes a very interesting point. There are other dimensions that countries can exploit. For example, some countries are talking about having lower tax rates for British bankers that come to their jurisdictions. That is not a supervisory matter; that is kind of a governmental matter. A range of other things are being done, for example, changing the language in which forms are written and so forth, which makes it more attractive to the UK. However, many of these are outside the realm of supervision and the supervisory authority. They constitute government action. I do not think it is fair to say Ireland is not being promoted; it is being promoted by the IDA and other institutions.

I know, but there is a fundamental difference-----

I do not think we want to dwell on this too much.

We are looking for solutions to problems. This comes back to the task force. What has been highlighted here is that we have changed our rules regarding the Central Bank promoting Ireland as a location for financial services. If that does not change - and obviously, other European countries have not changed - we need to find out who they are and whether we are going to change it. If we are not, we are at nothing. I agree with Dr. Fagan that other State agencies are out there championing the cause but if other central banks in Luxembourg and elsewhere are championing their financial services centres and the Irish Central Bank is not allowed to do likewise, it needs to go to Government and say the reason we are not going to get them is because we are hamstrung.

If this does not change, we will be back here in two years time saying, "I wonder why we didn't get those?"

Mr. Mark Cassidy

A number of questions related to the nature of the new trade deal and the impact it may have on tariffs and particular sectors. It is reasonably fair to say that in terms of trade arrangements, it would suit all parties in the negotiations to have reasonably free trade arrangements. The effects of that would certainly be much more benign for Ireland, the UK and Europe in terms of trade and investment links. Of course, this does not mean that this will be the eventual outcome. I think this depends on the other factors in an overall comprehensive deal so we cannot rule out the possibility that the outcome will be the more unfavourable one of trading goods reverting to WTO arrangements. In the more benign scenario, we would have either no tariffs or relatively low tariffs on trade between Ireland and the UK. In that case, many of the effects would come through the impact on the exchange rate - I will come back to the permanence of that in a moment - and the fact that the economic outlook for the UK might be slightly lower over the short and medium term than it would be otherwise. Those effects would be much more short term and limited for Irish exports so while I am not ruling out the fact that some sectors may be affected, the economic impact of a free trade arrangement or close to free trade arrangements would be much more benign.

In respect of the more unfavourable situation whereby trade in goods reverts to WTO conditions, we refer to no tariffs on services possibly because the WTO covers goods. It is much more difficult for some reasons that have been mentioned to impose tariffs on services but, over time, the regulatory requirements for services can differ across countries which can impose the main restrictions on trade in services, very notably in the financial sector. In terms of trade in goods, a very useful and granular ESRI analysis looks at what sectors and countries could be most affected. It is important to know that the impact on a particular country does not just depend on how much of our trade goes to the UK but the sectoral composition of that trade. Some notable facts in this regard include the fact that tariffs on agricultural and clothing products, particularly agricultural products, are at the highest end of the range. This is largely because trade in goods under the WTO rules tends to be trade as a percentage of the value but, very significantly, trade as a percentage of the weight of the good. Often these goods are among the weightier goods traded. Ireland would fare unfavourably because of our sectoral composition of the goods. In fact, the ESRI analysis suggest that the average tariff on Irish exports could be between 10% and 18%. That compares with the European average of closer to 6% so we are talking about significant effects in addition to the other effects that might arise because of the exchange rate and any downturn in the UK economy. Clearly, while a number of sectors, including tourism and computer services, would be significantly affected, those most affected would include those where the tariffs are also particularly high in addition to the other effects.

With regard to the exchange rate effect, it is fair to say that the value of the exchange rate that currently pertains reflects the expectations in the market regarding what a future trade deal might look like. If the adverse scenario materialises, a further weakening of sterling compared to the euro may be expected. One does not like to predict exchange rates too far into the future but some weaker level into the future may be expected. If more favourable outcomes materialise, some closing of the change that has already occurred may be expected. With regard to exchange rates, economies tend to adjust to those changes over time. It does not mean that there will no short-term effects. Services will also be affected by the exchange rate. For example, the tourism sector would be mainly affected by the exchange rate without tariffs on goods. Over the longer term, tariffs might be the more important effect.

I am afraid we are not privy to the type of special deals that may be available. Those more directly involved in the negotiations over the next two years would be better able to answer those questions in terms of whether special deals in terms of transition arrangements reflecting Ireland's closer trading links with the UK could be put in place but it is certainly very welcome to hear European and UK representatives highlight the importance of the Irish trade and economic links with the UK.

In respect of issues and authorisations, I cannot really add to what Ms McMunn has said. There have been many initiatives within the banks in terms of our engagement with firms, the numbers involved and ensuring we have the appropriate skills. I am not aware if the mandates of central banks elsewhere contained or have contained the requirement to promote the financial services industry. What other banks are doing on the ground is very difficult to ascertain and we are not familiar with that. The supervisory and authorisation activities that have taken place in the Central Bank have been highlighted by Ms McMunn. Of courses, we are interested in other policies. We have a role in terms of providing our views publicly in respect of macro-economic stability and the importance of maintaining stable public finances to protect ourselves against any economic shocks that may be coming down the line. Ensuring we can maintain flexibility for any additional public expenditure requirements that come down the line is particularly important. We must also be aware of the potential shocks to the economy either via international financial markets or any volatility that may emerge in residential or commercial property markets. In that regard, we have an important financial stability mandate and in terms of policy measures taken, have developed a comprehensive macro-prudential policy framework to reduce the risks of cyclical financial shocks occurring and to protect or enhance the resilience of the economy and financial sector against any shocks that may come down the line, including but not restricted to those related to Brexit. I am not sure whether Dr. Fagan has anything to add.

Dr. Gabriel Fagan

Mr. Cassidy covered most of the issues that have been raised. In terms of the special arrangements, I would add that, as Mr. Cassidy has highlighted, it is very important that both the European and UK authorities have signalled their recognition of the special nature of the problems facing Ireland so there is quite a lot of goodwill there and an awareness of the problems. That is very welcome. There may be scope to achieve some adjustments in terms of special programmes for Border areas and stuff like that - all sorts of arrangements that could be considered. The goodwill seems to be there.

In respect of the fiscal space, as Mr. Cassidy highlighted, despite the considerable improvements in the public finances we have seen since 2012, we are still in a fiscally vulnerable position. The debt is high. It may be flattered by a GDP number which is very large but when one uses a more realistic measure, one can still see that the public finances in Ireland are relatively vulnerable to shocks so we should be very cautious in saying that because of Brexit, we need to relax in some sense in terms of the fiscal programme for the country. That might be going in the wrong direction.

What the Central Bank has done has been raised. It is important to state that we have increased considerably the amount of resources we have in the bank to deal with Brexit-related issues such as authorisations and are planning to increase them considerably. The bank is an independent organisation so it does not need permission from the Government to increase its staff. It does that in the context of its own board - the Central Bank Commission - which makes the decision. That has been done. The budget for 2017 envisages quite a significant Brexit-related increase in staff mainly in the area of supervision. The basic point is that there will be no constraint caused by lack of resources in the Central Bank for financial firms to locate in Ireland if they wish to do so.

I asked about a temporary framework.

If the Senator would allow me to speak, I will address this. I am not saying she cannot speak.

I shall allow both Senators back in very briefly for a 30 second intervention, just for follow-up questions as we are very pushed and against the clock. I will start with Senator Daly as he indicated first and then Senator Mulherin.

Has the Central Bank changed any of its regulations in its own organisation as a direct result of Brexit? Are there changes to which the witnesses can point and say that the rules have been changed in order to assist Ireland as a result of Brexit?

I repeat my question about putting in place a temporary framework for state-aid rules to give more flexibility for investment by the State in infrastructure in disadvantaged areas. My initial question was not answered.

Dr. Gabriel Fagan

I apologise for the second point. There were a lot of questions and we could not necessarily address each question. I am not sure that the specific point raised by Senator Mulherin is within our area of competence. That is more an EU legal issue. It could be said, however, that there is a lot of goodwill towards Ireland and there is recognition that there are problems, as highlighted by the Senator, specifically affecting Ireland. I believe there would be scope within the interaction with the EU to identify possible programmes that could alleviate those problems, but it is not really a matter for the Central Bank.

With regard to what we have done, it is important to recognise that we are now part of a broader EU framework. The regulation of banking supervision and the rules are all part of the Single Supervisory Mechanism so we are not really in a position to change our rules. It is not like the old days when we were fully detached from the rest of Europe and we could make our own rules. Now we are part of a broader European framework so it is not possible to do that.

On the issue of promotion, there is very little scope for any supervisory authority anywhere in the EU to attract business by changing or by adopting a lax regulation. Regulation and supervision are now harmonised across the EU. There are other dimensions by which countries can compete such as in taxation or promotion. IDA Ireland is actively promoting Ireland as a location for financial services. It is not right to say that because the Central Bank is no longer in this business that Ireland is not being promoted and that other countries are doing the same. Countries cannot compete on the basis of supervision and regulation; we are now within a harmonised framework.

I thank Dr. Fagan. I thank all the witnesses for their excellent responses to the vast range of questions from all colleagues. I thank members for their contributions.

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