Property Taxation Application

Questions (156)

Noel Grealish

Question:

156. Deputy Noel Grealish asked the Minister for Finance if, in regard to local property tax, he will outline the situation that will apply when a taxpayer has declared a particular value in good faith but the property is sold for a higher figure during the period of the valuation and if in that scenario, any additional local property tax will be charged; the way the reverse situation will be handled whereby a higher valuation does not equate with the realised market value in a sale; and if he will make a statement on the matter. [12342/13]

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Written answers (Question to Finance)

The Finance (Local Property Tax) Act 2012 sets out how the tax is to be administered and how a residential property is to be valued for Local Property Tax (LPT) purposes.

I am advised by the Revenue Commissioners that LPT is a self-assessed tax so in the first instance it is a matter for the property owner to calculate the tax due based on his or her assessment of the market value of the property. As property values for properties under €1 million are organised into valuation bands for the purposes of LPT, property owners will not be required to provide a precise value for their property.

I am further advised by the Commissioners that the initial valuation of a property on 1 May 2013, assuming it is made in good faith, will be valid up to and including 2016 and will not be affected by any increase or decrease in property prices, during this period. This will ensure a measure of certainty for all property owners.

The Revenue Commissioners have prepared valuation guidance which, taken together with the owner’s own knowledge of the property, will assist him or her in assessing its value. The guidance includes an on-line guide that provides indicative property valuation bands depending on the property type, age and location and is available on the Revenue website.

When using Revenue’s valuation guidance, property owners should consider the specifics of their own property and if they feel that the guidance is not indicating a reasonable valuation, they should make their own assessment. As I have previously advised the House, where the Revenue guidance is used in an honest manner, the property valuation made by a property owner will not be challenged by Revenue in accordance with its normal Customer Service Charter and, consequently, additional charges will not be applied.

Property Taxation Application

Questions (157)

Noel Grealish

Question:

157. Deputy Noel Grealish asked the Minister for Finance if any outstanding amount of local property tax in a repossession or forced sale scenario will rank higher for payment purposes than an outstanding mortgage when the realised sale price is insufficient to fully discharge a mortgage liability; and if he will make a statement on the matter. [12343/13]

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Written answers (Question to Finance)

Under the Finance (Local Property Tax) Act 2012, unpaid Local Property Tax (LPT), together with any accrued interest, will be a charge on the property to which it relates. The Act does not confer any preferential creditor status on the Revenue Commissioners, other than that which they would have in the normal course of events. The usual rule is that the priority of a Revenue charge vis-à-vis other parties who also have a charge on the property will depend on the timing of the various charges. Therefore, in the event of a repossession or forced sale of the property, the proceeds must be used to discharge charges in the order in which those charges arose. The Revenue Commissioners will only have preferential creditor status over a mortgage provider where the LPT liability was due and payable before the mortgage provider advanced a loan in respect of the property. On that basis, unpaid charges for LPT should not have an effect on currently outstanding mortgages.

Ministerial Expenditure

Questions (158, 159, 160, 161)

Robert Troy

Question:

158. Deputy Robert Troy asked the Minister for Finance the costs of providing telephone in the homes of Ministers and Ministers of State in his Department; and if he will make a statement on the matter. [12385/13]

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Robert Troy

Question:

159. Deputy Robert Troy asked the Minister for Finance the cost of telephones and ICT provided to constituency offices including monthly phone bills of Ministers and Ministers of State in his Department since March 2011; and if he will make a statement on the matter. [12404/13]

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Robert Troy

Question:

160. Deputy Robert Troy asked the Minister for Finance if any additional costs other than telephones, ICT and monthly phone bills are being paid to constituency office by his Department; and if he will make a statement on the matter. [12422/13]

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Robert Troy

Question:

161. Deputy Robert Troy asked the Minister for Finance the number of mobile phones in use by him, Ministers of State and politically appointed staff; the total costs of the mobile phones since March 2011; and if he will make a statement on the matter. [12440/13]

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Written answers (Question to Finance)

I propose to take Questions Nos. 158 to 161, inclusive, together.

The information requested by the Deputy is as follows:

I can confirm that no telephones, ICT, monthly phone bills or any additional costs are provided in the constituency offices of the Minister or Junior Minister in my Department. However an office is set aside in my home for use as my constituency office. The cost of providing telephony service to my home was €3,998.28 inclusive of VAT from March 2011 to date. No cost was incurred on home telephony service on behalf of a Junior Minister.

The number of political staff with business mobiles in this Department is four including myself and the total cost incurred for the 2 year period since March 2011 is €5,263.99 exclusive of VAT.

Ministerial Transport

Questions (162)

Robert Troy

Question:

162. Deputy Robert Troy asked the Minister for Finance the cost of drivers of each vehicle assigned to him and Ministers of State in his Department since March 2011; the mileage and other costs claimed in respect of each since March 2011; the overall yearly costs of ministerial cars in 2010; and if he will make a statement on the matter. [12458/13]

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Written answers (Question to Finance)

There are no state vehicles assigned to me as Minister for Finance. In relation to the use of my car for Ministerial travel, the total cost has been €202,966 for the period May 2011 to date in March 2013. This cost included mileage (which is to cover car related expenses), the salaries paid to civilian drivers, travel and subsistence paid to the drivers and Employer PRSI contributions in respect of the two drivers. This amount is significantly below the €280,000 average annual cost under the previous domestic Ministerial transport regime for each Minister.

Departmental Expenditure

Questions (163)

Robert Troy

Question:

163. Deputy Robert Troy asked the Minister for Finance the number of credit cards issued to staff and Ministers in his Department; the total costs of each card since March 2011; and if he will make a statement on the matter. [12477/13]

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Written answers (Question to Finance)

In the period in question three new credit cards were issued in my Department. Two of the cards were issued in 2011 to myself as Minister for Finance and my Private Secretary and a further card was issued in respect of the Press Officer in 2012. Annual fees in respect of the cards came to €62 in 2011 and €93 in 2012. It is the Departments policy to ensure that all credit card payments are cleared at the end of each month to avoid penalty interest payments.

IBRC Liquidation

Questions (164)

Clare Daly

Question:

164. Deputy Clare Daly asked the Minister for Finance if his attention has been drawn to the fact that payments have been made to unsecured creditors by the liquidator of Irish Bank Resolution Corporation in return for their co-operation; and the reason he has not authorised the liquidator to make ex gratia payments to the workforce, as has been done in other cases by the State, to match the previously agreed redundancy terms. [12493/13]

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Written answers (Question to Finance)

I have been advised by the Special Liquidators that, in an insolvency situation, duress payments to unsecured creditors are often required to be made to ensure the on-going provision of services. Such payments are a matter for the Special Liquidator and I have no role in the initiation or authorisation of these payments. On the appointment of the Special Liquidators on 7 February 2013, the employment contracts of the employees in the Republic of Ireland were terminated. I have been advised by the Special Liquidators that 802 of the 809 employees in the Republic of Ireland were re-hired to assist with the liquidation of IBRC.

As the Deputy is aware, the legislation surrounding liquidation ranks employees as preferential creditors in respect of certain amounts owing to them on a winding up, including accrued wages and salaries, holiday pay, sick pay, statutory redundancy, pensions contributions and claims for damages arising from accidents. Any claims over and above that described above will rank as an unsecured claim in the liquidation process.

There are standard rules which apply to the distribution of the assets of companies in liquidation and it would not be appropriate for me to interfere with these rules. Any action taken by the Minister which might divert the assets from IBRC creditors to employees could be challenged in the Courts.

The Special Liquidators have said that it is their key priority that all employees are fully kept up to date on all developments during the course of the special liquidation. They have indicated that their approach will be to talk with employees directly either in small groups or on a one to one basis and they also plan to communicate by email general updates to employees during the course of the special liquidation.

IBRC Staff

Questions (165)

Clare Daly

Question:

165. Deputy Clare Daly asked the Minister for Finance his views on the pressure being experienced by the Irish Bank Resolution Corporation workers following the change in the terms of their redundancy package; and if he is prepared to meet with their representatives as a matter of urgency to discuss these issues. [12494/13]

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Written answers (Question to Finance)

As the Deputy is aware, the legislation surrounding liquidation ranks employees as preferential creditors in respect of certain amounts owing to them on a winding up, including accrued wages and salaries, holiday pay, sick pay, statutory redundancy, pensions contributions and claims for damages arising from accidents. Any claims over and above that described above will rank as an unsecured claim in the liquidation process. I can advise the Deputy that officials within my Department met with the IBOA last month and issues surrounding the status of the employees of the IBRC (in special liquidation) were discussed. The special liquidators have advised that there is on-going interaction between them and the IBOA in relation to these matters. I am advised that the special liquidators are highly cognisant of the issues being raised and that significant steps have already been taken to address those concerns including the confirmation that no further staff would be terminated in the first 3 months of the liquidation. I have further been advised that 802 of the 809 employees in the Republic of Ireland were re-hired to assist with the liquidation of IBRC.

The special liquidators have said that it is their key priority that all employees are fully kept up to date on all developments during the course of the special liquidation. They have indicated that their approach will be to talk with employees directly either in small groups or on a one to one basis and they also plan to communicate by email general updates to employees during the course of the special liquidation.

Mortgage Interest Relief Application

Questions (166)

John Lyons

Question:

166. Deputy John Lyons asked the Minister for Finance his views on a matter (details supplied) relating to a person's interaction with their bank on their mortgage interest relief; and if he will make a statement on the matter. [12495/13]

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Written answers (Question to Finance)

As the Deputy will appreciate, it is not appropriate for me to comment on individual disputes between a bank and its customers. The 30% rate of mortgage interest relief for those who took out their first qualifying home loan between 2004 and 2008 came into effect with the enactment of the Finance Act in March 2012. The regulations governing mortgage interest relief provide for the granting of the relief due to the borrower by the lender within the tax year.

I am informed by the Revenue Commissioners that to apply the new 30% rate, specific technology developments were required to Revenue’s and to each of the lenders computer systems. While Revenue’s computer system was upgraded in late 2011 the speed of upgrading across the lenders was inconsistent. For that reason in January 2012, as an interim relieving measure, Revenue advised lenders to grant tax relief at the rate of 25% to those entitled to the new 30% rate of relief, given that the 25% rate was already a feature of the first time buyer mortgage interest relief regime and was not dependent on new IT upgrades taking place.

Due to ongoing technology problems, Ulster Bank was unable to implement the 30% rate until the end of 2012 but did pay the interim 25%, as advised by Revenue, throughout the year. In December the bank credited the additional 5%, including arrears, to the mortgage accounts of each customer entitled to the 30% rate. Ulster Bank confirmed to Revenue that it wrote to each customer affected by the rate change offering to transfer the money to a current account of choice.

In regard to 2013, Ulster Bank has assured Revenue that the required IT changes will be implemented in March and the increased rate will be reflected in customers’ loan repayments from April 2013 onward. Any arrears due in respect of the January to March 2013 period will also be paid without the need for any action on the part of mortgage account holders.

However, in relation to the details supplied by the Deputy in respect of this customer, it is open to the person affected to make a formal complaint to the bank in question about the delay in the payment involved. If satisfaction is not received and all avenues are exhausted with the bank, then the customer may take his complaint to the Financial Services Ombudsman.

The Financial Services Ombudsman can investigate, in an impartial and independent manner, complaints from individual customers and small businesses who have unresolved disputes with regulated financial service providers.

The Financial Services Ombudsman can be contacted at:

3rd Floor, Lincoln House,

Lincoln Place,

Dublin 2

Lo Call: 1890 88 20 90

Email: enquiries@financialombudsman.ie

Website: www.financialombudsman.ie

EU Directives

Questions (167)

Nicky McFadden

Question:

167. Deputy Nicky McFadden asked the Minister for Finance if he will outline the details of the EU agreement on capping bankers' bonuses; when the agreement will come into effect; and if he will make a statement on the matter. [12534/13]

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Written answers (Question to Finance)

Remuneration is just one small part of the CRDIV Regulation and Directive on which the Irish Presidency has concluded an agreement between the European Council and Parliament. It is important not to lose sight of what this CRD package is really about: It is about protecting taxpayers into the future by building stronger European banks. We have seen how banks went into the financial crisis without sufficient capital and had to be bailed out by taxpayers across the EU. These new rules will make sure that our banks can better withstand future crises. CRDIV is also about providing a foundation for banking union and giving the future single supervisor a single rule book. The proposed rules on bonuses are part of the CRD package of measures to better manage risk taking by banks. The aim is to make sure that bankers are taking decisions in the long term interest of the stability of the bank and that this is taken into account in their remuneration package. The agreement reached on remuneration contains the following principles:

- a basic ratio of pay to bonus of 1:1 which can only increase to 1:2 with shareholder approval (with a quorum of 50% of shareholders, 66% of votes in favour would be required, and, if that quorum is not reached, 75% of votes in favour).

- in order to incentivise deferral of bonus pay, and facilitate claw-back of remuneration, a portion of the total bonus can consist of long term financial instruments, discounted with reference to factors reflecting risk inherent in the instruments (guidelines on the applicable discount factor will be issued by EBA).

- the EU Commission shall review and report on the application of these provisions, in close cooperation with the EBA, taking into account its impact on competitiveness and financial stability.

ECOFIN on 5 March asked Member State's Ambassadors to finalise the negotiations with the Parliament on the basis of these principles.

What is clear from discussions at EcoFin is that Member States want to move ahead to finalise these new capital rules. We hope to iron out the outstanding technical issues with the Parliament over the coming weeks so that we can finalise this key file during our Presidency.

IBRC Liquidation

Questions (168)

Pearse Doherty

Question:

168. Deputy Pearse Doherty asked the Minister for Finance the total value of unsecured creditors at the Irish Bank Resolution Corporation when it was placed in special liquidation on 6 February 2013. [12622/13]

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Written answers (Question to Finance)

I have been advised by the Special Liquidators that they are currently identifying the exact amount of all creditors’ claims and it is therefore too early in the liquidation to ascertain the level of unsecured creditors. It should be noted that creditors have been asked to forward a statement of their account at the date of the appointment of the Special Liquidators, together with any other documentation to support their claim, by 30 April 2013.

Deposit Guarantee Scheme

Questions (169)

Pearse Doherty

Question:

169. Deputy Pearse Doherty asked the Minister for Finance further to Parliamentary Question No. 181 of 26 February 2013, which showed that deposits in Irish banks, based on which these banks hand over 0.2% at the end of each year to be held by the Central Bank of Ireland in its deposit guarantee scheme, had declined from €217 billion at the end of 2011 to €190 billion at the end of 2012, if this is correct; and the apparent discrepancy between this decline and statements from his Department which suggest a stabilization and modest growth in deposits. [12623/13]

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Written answers (Question to Finance)

The Deposit Guarantee Scheme (DGS) in Ireland was established under Irish and European legislation to protect depositors in the event of a bank, building society or credit union authorised in Ireland being unable to repay deposits (e.g. where a liquidator has been appointed). The DGS is administered under the Deposit Protection Account by the Central Bank of Ireland and is funded by the credit institutions covered by the scheme. The Deposit Protection Account (DPA) at the Central Bank covers retail deposits up to €100,000 for all institutions regulated by the Central Bank of Ireland. This includes branches of Irish institutions operating in other EU Member States. However, it should be noted that Eligible Liabilities Guarantee (ELG) deposits at the covered institutions, amounts above €100,000 held at other institutions or corporate deposits at other institutions are not included.

The operation of the Deposit Protection Account is governed under European Communities (Deposit Guarantee Scheme) Regulations 1995 (SI No. 168 of 1995). The following table shows the balance held at year-end in the Deposit Protection Account at the Central Bank of Ireland. Each deposit-holding institution is required to maintain a balance on their DPA account of 0.2% of their total deposits (with a minimum amount of €50,000 in the case of all institutions except credit unions). This percentage is calculated annually in December. Interest is paid by the Central Bank on the DPA balances (1).

In the following table, it is shown that at the end of 2012, the Central Bank held €379 million, which represented 0.2% of the €190 billion on deposit in Ireland at the end of 2012. It is true to say that this was down 12.9% from the €435 million held by the Central Bank at the end of 2011, which represented deposits of €218 billion. The decline in the DPA balance reflects the drop in deposits in Irish credit institutions.

DPA Balances

Year End

Banks

Credit Union

Total

2012

379,390,200.00

23,633,580.57

403,023,780.57

2011

434,740,900.00

0

434,740,900.00

2010

537,900,500.00

0

537,900,500.00

2009

608,262,200.00

0

608,262,200.00

2008

669,408,300.00

0

669,408,300.00

2007

526,093,100.00

0

526,093,100.00

A comparison between the figures for deposits covered by the Deposit Guarantee Scheme (DGS) and the statements from my Department on the level of deposits in general is not entirely comparable. The Department of Finance Deposit Note on Deposit Trends at Irish Covered Banks of 14 February 2013 to which I presume the Deputy refers in his question, concentrates solely on the covered institutions - that is AIB Group, Bank of Ireland Group and permanent tsb. Thus it covers both the DGS and the Eligible Liabilities Group (ELG) as covered in Ireland and the UK and to corporate and retail deposits at the three covered institutions.

I would also refer to the latest available figures from the Central Bank of Ireland, released on 28 February 2013 "January 2013 Money and Banking Statistics", which show that Deposits from households were 1.2% higher on an annual basis at end-January 2013, while deposits from insurance corporations and pension funds and Other financial intermediaries increased by 8.2%. Deposits from Non-financial corporations rose by 5.2% over the same period.

(1) Section 4 of the Financial Services (Deposit Guarantee Scheme) Act 2009 for credit unions provides that from 30 November 2012, each credit union will be required to maintain in the Deposit Protection Account at the Central Bank of Ireland, an amount equal to 0.2% of the deposits and shares held on behalf of members.

Banking Sector Regulation

Questions (170)

Pearse Doherty

Question:

170. Deputy Pearse Doherty asked the Minister for Finance if he will confirm the policy of Allied Irish Banks in which he is the shareholder of 99.8% of the shares in writing down debt owed on commercial loans and if ordinary shareholders in companies where debt write-offs will be agreed by AIB, will be 100% wiped out before any debt write-off is agreed by AIB. [12624/13]

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Written answers (Question to Finance)

I have been informed by AIB that the bank is committed to operating its business activities on a commercial basis as it seeks to return to profitability. The bank assesses each customer in detail on a case by case basis to ensure the appropriate commercial outcome for the bank is achieved. As each case is dealt with on an individual basis, there is no blanket policy applied in respect of capital hierarchy.

Eligible Liabilities Guarantee

Questions (171)

Pearse Doherty

Question:

171. Deputy Pearse Doherty asked the Minister for Finance if he will provide in tabular form a breakdown by covered institution of the €1,235,980,000 in 2011 and €1,024,786,000 in 2012 of eligible liabilities guarantee fees received by the State; and if he will provide a projection of the fees payable in 2013 by covered institution and the projected fees in budget 2013. [12625/13]

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Written answers (Question to Finance)

Fees paid by the covered institutions in respect of the ELG Scheme guarantee are paid quarterly in arrears and therefore there is a time lag before the fees are paid into the Exchequer (i.e. fees received as cash in Q1 of 2012 are in respect of fees accrued in Q4 of 2011). Accordingly, the published figures for fees received in respect of 2011 and 2012 are on an accrued basis and are €1,234.6 million and €951.2 million, respectively. The corresponding cash figures are €1,230.8 million and €1,024.2 million.

The following tables show a breakdown of fees accrued in 2011 and 2012 by credit institution.

Breakdown of ELG fees accrued in 2011

€millions

€millions

€millions

€millions

Total

Q1

Q2

Q3

Q4

IL&P

38.0

42.0

42.8

42.4

165.2

BoI

107.9

97.2

96.8

73.5

375.4

A.I.B

95.8

93.5

67.3

75.4

332.0

IBRC

9.9

5.7

4.8

3.5

23.9

EBS

11.8

13.0

14.4

15.5

54.7

Total

263.4

251.4

226.1

210.3

951.2

Breakdown of ELG Fees accrued in 2012

€millions

€millions

€millions

€millions

Total

Q1

Q2

Q3

Q4

IL&P

38.0

42.0

42.8

42.4

165.2

BoI

107.9

97.2

96.8

73.5

375.4

A.I.B

95.8

93.5

67.3

75.4

332.0

IBRC

9.9

5.7

4.8

3.5

23.9

EBS

11.8

13.0

14.4

15.5

54.7

Total

263.4

251.4

226.1

210.3

951.2

The ELG Scheme fee estimates used in Budget 2013 of €435m were prepared as part of the normal budgetary process in November 2012.

For the purpose of Budget 2013, assumptions were made regarding the volumes of deposits, their maturity profiles and the mix of deposit books across each of the Covered Institutions. These assumptions are subject to change.

The Budget 2013 fee estimates have not been revised following the announcement of the ending of the ELG Scheme which is due to end at midnight on 28 March, 2013. The fees have not been re-forecasted because the final mix of deposits and the maturity profile of covered liabilities will only be known once the issuance window is closed i.e. after 28 March. My Department will then re-forecast ELG fee estimates for 2013 onwards. I do not expect any negative budgetary implications as a result of the ending of the ELG Scheme.

The fee estimates included in Budget 2013 were €435mn on a cash basis. As such information is regarded as commercially and price sensitive going forward, it cannot be provided on a bank-by-bank basis.

IBRC Liquidation

Questions (172)

Pearse Doherty

Question:

172. Deputy Pearse Doherty asked the Minister for Finance further to Parliamentary Question No. 63 on 27 February 2013, if he will confirm if it is KPMG corporate finance that will provide the independent valuation of the Irish Bank Resolution Corporation mortgage loanbook. [12626/13]

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Written answers (Question to Finance)

As part of the role of the liquidators, the assets of IBRC will be valued independently before being sold. Any assets not sold to third parties (including loan counterparties and other financial institutions) at or above the valuation price will be sold to NAMA at the independent valuation. As such, I have been advised that KPMG corporate finance will not be appointed as part of this process and that the valuation will be undertaken by independent professional advisor(s) or valuer(s).

IBRC Liquidation

Questions (173)

Pearse Doherty

Question:

173. Deputy Pearse Doherty asked the Minister for Finance further to Parliamentary Question No.63 of 27 February 2013, if he will provide an assessment of KPMG’s capabilities in disposing of the Irish Bank Resolution Corporation mortgage loan book. [12627/13]

View answer

Written answers (Question to Finance)

Kieran Wallace and Eamonn Richardson of KPMG have been appointed as Special Liquidators to IBRC. I am satisfied that each person appointed as Special liquidator has the appropriate level of skill, knowledge and qualifications required to perform the functions of a Special Liquidator pursuant to the Irish Bank Resolution Corporation Act 2013. The Special Liquidators are still in the process of devising and implementing a sales process in respect of IBRC’s assets including the mortgage portfolio. Once this is devised I am advised that the Special Liquidators will be appointing independent sales advisors to manage the sales process. This process will be overseen by the Special Liquidators to ensure that deadlines are being met and that the best value is achieved.

Bank Debt Restructuring

Questions (174)

Pearse Doherty

Question:

174. Deputy Pearse Doherty asked the Minister for Finance the involvement of KPMG in the sale of mortgage loan books at Permanent TSB and to provide an assessment of that company’s performance in selling PTSB’s loan books. [12628/13]

View answer

Written answers (Question to Finance)

I can inform the Deputy that KPMG advised Permanent TSB on the potential sale of Capital Home Loans (CHL) and Springboard mortgage loan books. I am advised that the sale of CHL was postponed while a revised Restructuring Plan was being prepared by management. The revised plan now includes CHL as a stand-alone unit as part of Permanent TSB. The decision to engage KPMG to advise on the sale of these loan books was made by the board of Permanent TSB whose management team were responsible for monitoring KPMG’s performance.

IBRC Liquidation

Questions (175)

Pearse Doherty

Question:

175. Deputy Pearse Doherty asked the Minister for Finance if he will provide an assessment of the disposal price of the Irish Bank Resolution Corporation mortgage loan book if sold as one job lot and if broken down into subportfolios or individual mortgage sales. [12629/13]

View answer

Written answers (Question to Finance)

I have been advised that it is the intention of the special liquidators to package and sell the mortgage book as a portfolio. I am advised that the special liquidators are currently devising a process where borrowers, third parties and other financial institutions will be given the opportunity to bid for specific portfolios (or component parts thereof) as part of an open and transparent process. The special liquidators will not be providing an assessment of the disposal price of the IBRC mortgage loan book if sold as one job lot or if broken down into sub portfolios as this could potentially have a detrimental impact on asset recovery from the impending sales process.

IBRC Liquidation

Questions (176)

Pearse Doherty

Question:

176. Deputy Pearse Doherty asked the Minister for Finance the number of individual mortgage accounts that comprise the Irish Bank Resolution Corporation mortgage loan book. [12630/13]

View answer

Written answers (Question to Finance)

Details of the number of individual mortgage accounts that comprise the IBRC mortgage loan book can be found on page 170 of the Bank’s 2011 Annual Report & Accounts.