The CRD IV legislative package is made up of the Capital Requirements Directive - 2013/36/EU and the Capital Requirements Regulation 575/2013. The Capital Requirements Directive will be transposed into Irish law by 31 December 2013. The Capital Requirements Regulation is directly effective in Irish law and will come into force on 1 January 2014. CRD IV is the EU implementation of the agreements reached by the Basel Committee on Banking Supervision (i.e. the Basel III requirements), which have been endorsed by the G20 leaders. Credit unions are excluded from the scope of the CRD IV legislation in accordance with Article 2(5)(8) of Directive 2013/36/EU.
Credit union deposits held at credit institutions do not meet the definition of retail deposits as outlined in Article 411 (2) of Regulation 575/20131. As the Directive and Regulation were agreed and published in the Official Journal of the EU earlier this year, the classification of credit union deposits in this regulation cannot be reviewed at this stage.
Footnote:
1. Article 411 (2) of Regulation 575/2013 - (2) 'retail deposit' means a liability to a natural person or to an SME, where the natural person or the SME would qualify for the retail exposure class under the Standardised or IRB approaches for credit risk, or a liability to a company which is eligible for the treatment set out in Article 153(4) and where the aggregate deposits by all such enterprises on a group basis do not exceed EUR 1 million.
