I will call on the Deputies who tabled questions to the Minister for Finance in the order in which they submitted their questions to my office.
Private Notice Questions.
Insurance Industry.
Michael Noonan
Ceist:Deputy Michael Noonan asked the Minister for Finance if, in view of the statement made by the Financial Regulator that if a shortfall emerges in the Quinn Insurance group, all policy holders in the State will be subject to a financial levy; the steps he intends taking to protect policy holders both within and outside the Quinn Group; and if he will make a statement on the matter.
Caoimhghín Ó Caoláin
Ceist:Deputy Caoimhghín Ó Caoláin asked the Minister for Finance if he is monitoring the implications for employment of the appointment of administrators to the Quinn Group; and if he will make a statement on the matter.
Richard Bruton
Ceist:Deputy Richard Bruton asked the Minister for Finance the circumstances which led to the appointment of an administrator at Quinn Insurance; the implications of this move for those insured by the company, the taxpayer and for the general insured population; and if specific measures are being initiated by the Government to correct any weaknesses in existing regulatory legislation and-or to protect the public.
Joan Burton
Ceist:Deputy Joan Burton asked the Minister for Finance to outline the circumstances leading to the decision of the Financial Regulator to apply for the appointment of administrators to two firms within the Quinn Insurance group; when the investigation to be carried out by the Financial Regulator into Quinn Insurance will be completed; what steps are being taken to ensure the continued validity of policies held with the two companies; if he will ensure that the protection of jobs will be given priority in terms of any future development in regard to the company; and if he will make a statement on the matter.
Following an application by the Financial Regulator yesterday, Mr. Justice John Cooke in the High Court appointed Mr. Michael McAteer and Mr. Paul McCann from Grant Thornton to act as the two joint provisional administrators to Quinn Insurance Limited, under the Insurance (No 2) Act 1983. They have already begun their work and have an on-site presence in the company. They will oversee its actions and work with the new management.
The appointment was made after the court was informed that the Financial Regulator had a number of concerns, including that the company had significantly breached its solvency ratios, its subsidiaries had entered a series of guarantee agreements which had reduced its assets by some €448 million and it had failed to deliver a financial recovery plan that met the Financial Regulator's requirements aimed at restoring financial health to the company. In other words, the Financial Regulator had concerns about the way the company was conducting its affairs and concerns that it was not meeting the regulatory requirements. In particular the company was unable to comply with the requirements of the Insurance (No. 2) Act 1983 in that it had failed to make adequate provisions for its debts, including contingent and prospective liabilities. In that context, it is not suggested that it is not in a position to pay its debts as they fall due. The ground referred to is that it is unable to make adequate provisions for its debts, including contingent and prospective liabilities.
I understand the company's ability to comply with the solvency requirements was called into question on 24 March when the company's chairman, Mr. Jim Quigley, informed the Financial Regulator that certain subsidiaries of Quinn Insurance Limited had entered guarantees in connection with facilities made available to the Quinn Group. This arose as the Financial Regulator was in discussions with the company about its financial recovery plan for the restoration of the insurer to a sound financial footing. It was in the course of these meetings that the Financial Regulator was informed for the first time about the existence of the guarantees from the subsidiaries of advances to the Quinn Group generally.
I understand that the facility agreements which incorporate the guarantees from four subsidiaries of Quinn Insurance Limited were entered into in 2005. Three tranches of loan notes were entered into in October 2005, April 2006 and April 2007. I also understand that four additional subsidiaries of the company entered into the guarantees in 2008. The total guaranteed sum was €1.2 billion. I emphasise that this is the total guaranteed sum and not necessarily the quantum of the guarantees. I am informed that, following a meeting between the Financial Regulator and the company, it was revealed that the effect of the guarantees had reduced the insurer's assets by some €448 million and thus wiped out the company's solvency cushion. It has gone from having a surplus of assets over liabilities of €200 million to a current position where it has an excess of liabilities over assets of €200 million. The fact that these guarantees had been in place and not disclosed for some time was a matter of the gravest concern to the Financial Regulator. This raised serious governance and accountability questions about the internal control mechanisms as well as the accounting and administration procedures and practices within the company.
The Financial Regulator has commenced an investigation into these matters within Quinn Insurance Limited that have very recently come to light and we must await the outcome of this investigation. I recognise that the Financial Regulator has taken the action to seek the appointment of the two joint provisional administrators in the best interests of the firm's policy holders and that the appointment will better protect policy holders. It will allow the firm to remain open for business and to continue to be run as a going concern under different management, with a view to placing it on an ongoing sound commercial and financial footing. This will assist in the maintenance in the public interest of the proper and orderly regulation and conduct of the business.
The Financial Regulator has directed Quinn Insurance Limited to cease writing new business in the UK and that existing UK policy holders will not be affected by this decision as existing policies will remain valid. The effect of this action is to prevent Quinn Insurance Limited suffering further financial losses from its currently unprofitable UK business. I welcome the fact that Irish policy holders of Quinn Insurance Limited can continue to renew policies, carry out new business and make claims in the normal way. Quinn Life business, which is a separate entity, is not affected by these measures.
It is important to note that at this stage there is no requirement for additional funds from the insurance compensation fund as the administration is only of a provisional nature. If the administration is confirmed on 12 April and should the administrator subsequently need additional funds to help him with the business, there is the facility of the Insurance Compensation Fund, established under the Insurance Act 1964. This fund was used in previous insurance company administrations in 1983 and 1985. This fund can be financed by a small levy on non-life insurance premium income in circumstances where the Central Bank is of the view that the state of the fund is such that financial support should be provided for. This would arise in circumstances where, for instance, the administrator has made a claim and the Exchequer has been required to advance funds. The maximum contribution from insurers is 2% of the aggregate income of the insurers in that year.
In regard to the implications of this on employment, this Government takes this issue very seriously. We remain acutely conscious that, while economic activity continues to remain weak, it is imperative that we do nothing to further erode private sector employment. I am conscious of the contribution of the financial services sector to employment in this country and it is the Government's intention that this sector emerges from the current downturn strong, competitive and able to withstand any future downturns.
With regard to the question raised by Deputy Bruton on the measures being initiated by the Government to correct any weaknesses in existing regulatory legislation, the Central Bank Reform Bill published yesterday is the first of a three-stage legislative programme to create a fully integrated structure for financial regulation, enhance the powers and functions of the Central Bank and consolidate existing legislation. However, it should be said that as soon as the matters were drawn to the Financial Regulator's attention, he took appropriate action and ample legislative machinery was at his disposal to take such action. The first Bill puts in place the new structure of the Central Bank. The second Bill will enhance and extend the regulatory powers of the new Central Bank. Should similar legislative changes be required to protect consumers of financial products provided by the insurance industry, these will be provided for in further legislation.
I fully support the action of the regulator and I commend him on the promptness with which he has dealt with this matter. It is essential that policyholders be reassured about the insurance company in question.
I thank the Minister for a very full answer. I understand Mr. Quinn has written to the Minister and all his colleagues. In the course of his letter, he states that the action taken by the regulator was highly aggressive and unnecessary. He claims it will make the repayment of outstanding debt extremely difficult and that it also endangers the 5,500 jobs in Ireland unless it is immediately reversed. Will the Minister comment on those claims of Mr. Quinn in view of his answer?
Second, will the Minister outline the precedents for imposing levies on policyholders arising from the 1963 insurance compensation provisions? Will he state whether the levy would be applied to all insurance policies except life insurance and that it would include health insurance, or would health insurance also be exempt from the levy?
First, with regard to the suggestion, which I understand was made in a press release circulated on behalf of the Quinn Group, that this was a highly aggressive and unnecessary action which endangers jobs, I make it clear that the regulator is acting in the proper performance of his functions. That is what I and, I am sure, every Member of this House would expect him to do.
The regulator has to ensure in a regulated industry of this character that the industry is being operated in a manner that can assure the policyholders their claims will be met. That is an absolute duty which he is under. This is not the first but the second occasion on which a difficulty of this type has emerged in regard to this insurance company. Whatever we disagree about, in the context of yesterday's debate, there is a particular onus on the regulator to ensure a regulated industry like this meets whatever statutory standards are laid down. Everything he has done in this context is to ensure those statutory standards are upheld. That is my response on that issue.
In regard to the previous operation of the insurance compensation fund, the Insurance Corporation of Ireland, a subsidiary of Allied Irish Banks, collapsed in 1985. The ICI has since been renamed Icarom plc. Compensation to meet certain of Icarom's liabilities has been provided through the insurance compensation fund by a combination of AIB funding, commercial loans and State loans, which have been since repaid.
The collapse of the ICI did not require a levy on the industry itself. The collapse of the PMPA, on the other hand, did involve a certain element of levy. The Insurance Act 1964 made provision for contributions to be made to the insurance compensation fund from insurers, other than insolvent insurers, to meet the liabilities of insolvent insurers. This provision was brought into effect by section 10 of the Insurance (No. 2) Act 1983 and set the levy at 2% of gross premium income. It was introduced on 1 January 1984 following the collapse of PMPA in October 1983. At that time, there were not sufficient moneys in the fund to meet the liabilities of PMPA. The levy was paid by all non-life insurers at this rate until 31 December 1991. The rate was reduced to 1% from 1 January 1992 to 31 December 1992. The levy ceased to apply from 1 January 1993 as it was felt sufficient funds had been collected to enable the successful completion of the administration of the former PMPA.
The position here is somewhat different in that we are at the stage where an interim appointment has been made returnable on notice to the court and, clearly, there is no call on the need for a levy at this stage. When the administrator has conducted a preliminary view of the company in question, we will be in a better position to know exactly how to proceed.
In regard to the question of health insurance, I am advised that health insurance and marine, aviation and transit insurance are excluded from the operation of the levy.
I thank the Minister for his comprehensive reply. My primary concern, as I am sure it would be for many Deputies, is for the 2,800 employees of Quinn Insurance Limited in Cavan, Enniskillen, Navan, Dublin, Cork and in Manchester. We recognise the Quinn Group is one of the biggest employers in the Border region and in the country as a whole.
What is the Minister's Department doing in specific terms to secure and protect those jobs? Will the Minister confirm the number of jobs involved in Quinn Insurance, which I have just indicated as being 2,800? Does this square with his Department's tally? Is the Minister concerned that the situation now presenting could affect other parts of the Quinn Group and involve further thousands of jobs?
As Deputy Noonan noted, Mr. Seán Quinn has alleged that the appointment of the administrator endangers 5,500 jobs in Ireland — "endangers" is the word used in the text as reported in this morning's media. How would the Minister respond to that claim by the Quinn Group?
With regard to the Financial Regulator and the appointed administrator, is it a primary part of its remit that it would, as it should, take every step to guarantee to help ensure the safety of the jobs concerned in Quinn Insurance Limited, as the focus at this point in time, and the Quinn Group in a further sense if, God forbid, that were to be the case?
First, I would like to put certain facts on the record of the House in regard to Quinn Insurance Limited generally, which might assist the House in understanding the significance of the company, the number of employees involved and the prospects of the company in the home market. Quinn Insurance Limited has approximately 1.3 million policyholders — 920,000 in the State and 365,000 in the United Kingdom. The total premium income is in excess of €1 billion and approximately 60% of that is sourced in the State. The business is broken down into motor business, 52%; health business, 28%; general liability business,16%; and property and household business, 5%. To take approximate shares of the Irish market, that represents 23% of the health market, 20% of the motor market, 3% of the property market and 10% of the liability market. In regard to the United Kingdom business, that is split between motor business, 68%; property business, 6%; and liability business, 27%.
Quinn Insurance Limited employs approximately 2,800 personnel in the State and the UK out of a total of approximately 8,000 persons in the overall group, which includes non-insurance business and a life company. The Government is, of course, concerned about these jobs. However, one cannot have jobs if one does not have a credible regulatory framework underpinning them and one cannot have jobs in a company that is not meeting basic statutory requirements. Those statutory requirements have to be enforced.
If we have learned anything from what we have discussed yesterday and since September 2008, it is the paramount importance of this point. We must ensure that, in the eyes of the world, this insurance company is in a position to meet all regulatory requirements. Clearly, the company has a large amount of business. Clearly, the regulator had the confidence to go to court to ensure the company continues to carry on its business in the State, which is positive in terms of these positions and positive in terms of the continuity and jobs which the administrator wishes to see sustained in the company. However, the Financial Regulator is under an obligation to ensure that the company is properly regulated. He cannot be criticised on the basis that he is being aggressive and unnecessary in the context of the matters which I set out in my initial reply.
Do I take it then that the Minister rejects the statement that the appointment of the administrators is placing 5,500 jobs at risk, which is attributed to the board in this morning's newspapers? I ask him to comment. Will he also indicate to the House the role of the administrators? We understand the importance of regulation in terms of public confidence. Is it part of the remit — as I had asked him — that they would also keep a careful eye to the importance of guaranteeing employment for the many people and their families who depend on this entity for their daily lives?
At least two other Members are offering. I call Deputy Burton.
Is it not a case of calling Members in the order in which the questions were put?
Yes. Does the Deputy wish to ask a question?
My question is next up in order.
Without wishing to cut across Deputy Bruton, could the Minister respond to those two questions first?
The suggestion was that this was a highly aggressive and unnecessary action. I was anxious in that context to underline the statutory functions of the Financial Regulator and to express my full confidence in him. I do not accept the suggestion that this is a highly aggressive and unnecessary action.
On the question of the risk to jobs and employment, the Financial Regulator, the administrators and I, are fully aware of those risks. However, an estimation of those cannot be arrived at today. I outlined certain facts about this company which show there is sufficient confidence in it to sustain it as a trading concern in the State on an interim basis and that is now happening. In the forefront of the administrator's mind and of the Financial Regulator's mind, will be an anxiety to bring this matter to a conclusion as rapidly as possible with a minimum of disruption to the operation of the insurance company.
I share Deputy Ó Caoláin's concerns about both employment and the scale of this company which covers about one fifth of all insurance. How could this business come to have been jeopardised by a practice that was going on over five years, according to the Minister's report? This company had trouble of this nature in the past. Would these transactions that occurred here have required regulatory approval? Would such guarantees have required the approval of the regulator and were they ever sought?
Could the issue of such guarantees have occurred within any insurance company without the risk management committee or the board being informed or without the knowledge of the auditors? Who was under an obligation to reveal these transactions to the regulator? Was it the obligation of the board, of the risk management committee, of the auditors? This practice appears to have been of very long standing. The Minister in his reply suggested it went right back to 2005. Would those in receipt of these guarantees have had any obligation to report the source of the guarantees if they knew they were coming from funds set aside for meeting regulatory insurance cover?
Deputy Bruton will appreciate that the amount of information at our disposal at this stage is necessarily interim in character. It is not possible to arrive at a final assessment on some of the questions he asked. It is clear that when the regulator saw the difficulty, his immediate and proper instinct was to apply to the court to protect the position. With regard to the persons for whose benefit the transactions were executed, they are creditors of the general group who lie outside the insurance company position and in that context, any instruments executed for their benefit create rights in them outside the insurance company and deplete the insurance company's assets thereby. That is the essential difficulty which has arisen here. As to the parties who executed those transactions, that is an investigative matter for the particular companies in question. As outlined in my reply, they are subsidiaries of the insurance company.
As to the degree of regulatory participation or consent or assent sought, as I understand the position at this stage, no such asset or consent was sought and these transactions——
Or was required.
——or was required. These transactions existed entirely outside the regulatory system. Beyond that I am not in a position to go further this afternoon.
Like everybody else, I have two main concerns. I am concerned for the policyholders that they continue to have confidence in their insurers. I am also concerned for the many thousands of people employed by the Quinn Group, some of whom are on the insurance side and are in our constituency.
The events he described seemed to relate to off-balance sheet contingent liability accounting relating to guarantees. They go back to October 2005, April 2006 and April 2007 and were modified in 2008. Is the Minister aware that the total guaranteed sum was €1.2 billion? Will the Minister say if there is any relationship between this large total figure and the issues of the indebtedness of the Quinn Group to Anglo Irish Bank in the context of the Quinn Group having acquired through contracts for difference up to 28% interest in Anglo Irish Bank? Are these events related and are they to be part of the subject of the investigation?
A very distinguished retired Secretary General of the Department of Finance was a director of Quinn Insurance until he resigned in 2007, when he was to become chairman of the investment committee. Reports in today's newspapers state that this company seems to have suffered losses on the investment side. The insurance business is understood to be profitable but the structural lapses, defaults, are on the investment side of the company. I ask the Minister if this is so. If that is so, what about the report in today's newspapers that Mr. Quinn, the principal figure in the Quinn Group — he is the owner or shareholder as I do not know what is the structure of the group — made significant gifts of €200 million each to family members, in a company which was having difficulties on the investment side? Was the regulator aware of this? It has been the practice of companies within the overall Quinn Group to make gifts to other companies. Gifts in tax law are for love and affection and companies do not usually gift. Has this been the subject of any inquiry by the Revenue Commissioners and what is the background to this practice?
The Minister indicated in his statement that one of the insurance companies is not permitted to take new business in the United Kingdom. Quinn Insurance Limited is to cease writing new business in the UK. Were concerns expressed by the UK Financial Services Authority about issues arising in that country?
Everybody here is conscious that we are dealing with a huge employer in this country. Yesterday we heard appalling news on our banking system but given Quinn's repeated mention over the past three years and more in connection with investments in Anglo Irish Bank, I ask the Minister to indicate whether it has a bearing on these developments.
According to my information, the creditors in whose favour these instruments were executed did not include Anglo Irish Bank or parties associated with it.
In regard to a former Secretary General of my Department, I have no information on that issue. I am not aware that a former Secretary General was involved with the Quinn Group at any stage.
As to gifts between companies, Deputy Burton is correct that tax implications may arise. There would also be a fundamental incapacity for a company to make a gift out of its own capital. However, this is altogether separate from the core question of a regulated insurance business which has to maintain its own capital levels. This is where the difficulty arises for the regulator.
On the Deputy's question on the United Kingdom position, I outlined the nature of the business in that country. It involves routine insurance activities and is not unduly hazardous. I understand the regulator took the view in his application that the UK operation was loss making in general and, therefore, it was not desirable to continue taking business there. As the Deputy noted, he may have been influenced by a more general concern about a possible reaction by a regulatory authority in another jurisdiction but the administrator is happy to permit the bulk of the business located in this State to continue for the present and to apply to the court on that basis. As I outlined in my earlier reply, the company remains in a position to pay policy makers and the concern for solvency ratios is contingent rather than actual in respect of any claim falling due now.
Is it contingent or off balance sheet? There is a difference between the two.
I am using the term "special contingent" in the context of insolvency law and not in regard to balance sheet operations. It is important to assure policy holders that their claims can be met as they fall due. The basis for the concern about solvency outlined in the application to the court related to contingency rather than an actual position.
I thank the Minister for his frank and open responses to Deputies' questions. I will not deal with the legal technicalities which others have raised because I simply want to describe the absolute shock with which the people of Cavan-Monaghan reacted to this administration decision. Few others have ever done as much as Seán Quinn for that region. I welcome the guarantee by the Minister that policy holders will be safe but I also ask him to do whatever needs to be done to protect the jobs created by the Quinn Group in its insurance and other operations. Maintaining these jobs, which are vital to my part of the country, may require the intervention of more people than the regulator.
I concur with Deputy Crawford. I visited one of the main units of the Quinn Group which was located not far from where the Deputy lives. Hundreds of young people from counties Cavan, Monaghan, Leitrim, Donegal and Sligo were working in open plan offices in an atmosphere of high morale. If these jobs are put at risk in any way, it would be devastating for this part of the country. The letter from Mr. Quinn states that 5,500 jobs may be put at risk.
When an administrator went into ICI, the number of employees at the company was reduced from 2,500 to 800 by the time it was sold off and trading profitably as a private enterprise. If it is legally possible to do so, I ask the Minister to communicate to the regulator and, through him, the administrators that this House regards the preservation of employment as a priority.
I am very concerned for the policy holders and employees. Why is it only now that the Financial Regulator has intervened? Any insurer would have to answer the question of whether it has the appropriate solvency cushion and is not compromised by guarantees to other subsidiaries. That insolvency and contingency cushion is vital in health insurance companies, which is the area I know best. Can the Minister explain how this was overlooked until now? Given the strict regulation under which the health insurance market supposedly operates, it is extraordinary that this issue did not come to light earlier.
In regard to the group's health insurance activities, the Minister informed us that the excess of liabilities over assets now stands at over €200 million. Every hospital that provides a service for a patient who is insured by Quinn Insurance must be concerned about the potential credit risk. Can we expect that hospitals will seek upfront payment from the company?
I am not trying to lecture the Deputy when I say it is important to understand that the issue does not pertain to assets and liabilities but to the ability to pay obligations as they fall due. The statement in my earlier reply on assets and liabilities is the current position on solvency buffers as a result of the information which came to the attention of the Financial Regulator. The company remains in a position to deal with its obligations as they fall due in this State and that ability will be maintained. The Deputy rightly asked why the basic solvency cushion has disappeared. This happened because of the conduct which the regulator became aware of last week and he has taken prompt action in response. Detailed investigation remains to be conducted on the precise nature of these transactions, in whose benefit they were executed and who was aware of them.
I have already communicated to the regulator the concerns raised by Deputies Noonan and Crawford and I am confident he will outline to the administrator our desire to safeguard employment and activities as much as possible.
We are all concerned for policy holders and employees. I welcome the statement that the levy will not affect health insurance policy holders. Can we be sure that the morass that surrounds many of these issues does not confuse the possibility that they lead back to Anglo Irish Bank? I hope the Minister will be able to revert and give us an assurance on this matter.
I welcome that the regulator is being proactive but has it considered the situation in respect of the VHI, which is not solvent by the 40% figure demanded by the regulator currently and which has diversified into other areas? Are the Minister and the regulator satisfied no cross-subsidisation is taking place in that company? Will the Minister comment on the need for a 40% solvency fund for insurers in this country when a 25% fund is the norm elsewhere in the EU?
Are there any particular obligations in respect of the auditors in dealing with the accounts of an insurance company? It is a very difficult and different set of accounts than those of any other business. Does the Minister agree there should be a responsibility and that a certificate should be issued every year by the auditors to the Department or the regulator indicating clearly satisfaction with the type of reserves such a company holds? Does the Minister agree that there should be some restrictions on insurance companies in respect of the type of investments in which they may invest because of the unique nature of the business?
This may be a matter for the Minister's colleague, but will the Minister contact his colleague in the Department of Enterprise, Trade and Employment in respect of the capacity problem? If some 20% of the motor market was held by Quinn Insurance, is the rest of the market capable of taking up that 20%? There may be a capacity problem from the point of view of someone who holds a policy with Quinn Insurance.
I refer to the employees and the policyholders. It appears there are eight subsidiaries of Quinn Insurance involved in providing guarantees for facilities. Will the Minister elaborate on exactly what form these facilities took? Were they in the form of bank loans or otherwise? Normal practice would dictate that if they were in respect of banks, bank letters would be sent to the bank every year and the guarantees would be disclosed in those bank letters. That would represent normal practice. Will the Minister elaborate on exactly what form these particular facilities took and their nature?
I refer to Deputy O'Donnell's question. The hearing will take place in the High Court on Monday, 12 April. That will provide the regulator with an opportunity to make a fuller case for the appointment of the administrator. It will allow Quinn Insurance to either address the concerns of the regulator or counter them. The court will then have to make its decision on the evidence submitted. The nature of these transactions will require investigation in that context. The suggestion to date has been that they were in the nature of a pledge or a security of such type in respect of the documents in question and the court must evaluate that. The Deputy will appreciate that I am not in a position today to provide information to the House about matters before the courts which await determination there.
I refer to Deputy Barrett's query. I shared his response to the question of the large amount of physical and unrealisable, relatively illiquid assets involved in these subsidiaries. This is a matter we must examine for the future. However, in respect of the question of accountants, I refer to the point I have already made. The hearing will take place before the courts on 12 April and I have no wish to prejudge that in respect of to what extent accountants did or did not know of these particular transactions.
Deputy Reilly raised concerns about the health insurance market, which is not affected by the levy. His concerns related to the solvency ratio that operates in the health market. I must refer that to my colleague, the Minister for Health and Children, because it is a question for another market and the way in which that is regulated. All these markets require a basic solvency assurance. I am aware that in the context of the VHI we have had some obligation throughout the years but it has not been as onerous as it could have been had international standards varied to a greater degree. As Deputy Reilly is aware, significant issues exist in this regard. Is there another query outstanding?
I asked about capacity.
Deputy O'Sullivan asked about credit to hospitals and credit risk.
It is business as usual as far as hospitals and policies are concerned. That is the position and I see no credit risk at this stage.
Will payment be later rather than sooner?
The administrators will do their work, we will have a far clearer picture on 11 April and we will proceed from there. As I indicated already to Deputy Burton in respect of Anglo Irish Bank, on the information available to date the creditors in question were not Anglo Irish Bank.