Paperless Banking: Discussion with NIB and Edelman.

I welcome Dr. Ronnie O'Toole, chief economist of National Irish Bank, and Mr. Seamus Mulconry of Edelman. There will be a presentation followed by a question and answer session. All mobile telephones should be switched off.

I draw everybody's attention to the fact that members of the committee have absolute privilege but this same privilege does not apply to witnesses appearing before the committee. The committee cannot guarantee any level of privilege to witnesses appearing before it. Furthermore, under the salient rulings of the Chair, members should not comment on, criticise or make charges against a person outside the House or an official by name or in such a way as to make him or her identifiable.

I invite Dr. O'Toole to begin.

Dr. Ronnie O’Toole

It is an honour to be here. I am grateful to the committee for putting time aside to discuss what National Irish Bank believes to be an important issue. I am chief economist with National Irish Bank and have held that position for approximately two years. I am accompanied by Mr. Seamus Mulconry of Edelman.

National Irish Bank has been part of the Danske Bank Group since it was acquired from National Australia Group in March 2005. Danske is the largest bank in Denmark and one of the leading financial institutions in northern Europe. The group employs 24,000 people worldwide, including 3,000 in Ireland, North and South. The link with Danske Bank has transformed us as a bank, particularly in terms of our technology, which is one of the reasons we are here today.

I want to talk about the issue of paperless banking and how we are frustrated by current Irish legislation, which prevents this from becoming a reality. By paperless banking, I mean a movement away from a high volume of paper documentation and switching some of this to an electronic format. It is not about less consumer communication, it is just about allowing banks and consumers to communicate in a different format if they so wish. For example, it is much cheaper, faster, more environmentally friendly and more secure to send bank statements by e-mail rather than by post. I presume all members of the joint committee have bank accounts. The fact that they get bank statements by post is not because the bank necessarily wants to use the postal system, but because the current legislation requires it.

In a typical year a customer could get a huge amount of documentation. Opening a joint account pack would involve around 83 pages, including an introduction letter and various copies of the customer agreement, as well as information on how we use personal data, fees, charges and distance marketing information. We send 12 credit card statements per year, amounting to about 36 pages depending on the size of the credit card bill. Four quarterly account statements are also issued, amounting to 16 pages. Even a relatively small personal loan — for example, for a holiday — will typically come to in excess of 60 pages, including the facility letter and follow-up documentation. All of this must be sent on paper, based on current Irish legislation. This comes to approximately 200 pages, not accounting for any mortgage the customer may have or any other servicing we might have. It is an example of the volume of paperwork we might send to a consumer in a typical year.

National Irish Bank is no better or worse than any other bank in this regard. All of us are forced to do the same according to the legislation. It is not something that we necessarily want to do.

There are two problems in the legislation. The first stems from section 45 of the Consumer Credit Act, which requires written communications relating to credit agreements to be sent in paper format only. At the time the legislation was drafted, it was not a conscious decision to do this; it was simply the way the legislation was written. When this was being discussed, the problem was that banks were sending letters to consumers with the bank logo on the envelope. That caused concern that somebody could see it was a letter from a bank and therefore somebody would take it. Those drafting the legislation insisted that all written communication must be in an unmarked, sealed envelope. Unfortunately, however, because of the way the legislation was drafted, that means that any such communication must now be sent in an unmarked, sealed envelope. Clearly, electronic mail is not sent in an unmarked, sealed envelope and neither are faxes. In an effort to make communications between a bank and its customers safer and more secure, we have ended up with a perverse situation whereby we have probably done the opposite, by an accident of legislative drafting.

Breach of this provision is a criminal offence. The effect of section 45 is to require paper-based correspondence, even where the borrower has expressly indicated that they would prefer to receive secure electronic correspondence. This is not only a problem with e-mail. On a strict interpretation, a financial institution may breach section 45 if it complies with a customer's request to send a statement by fax.

The second problem stems from the interaction of the Electronic Commerce Act 2000 and the Consumer Credit Act 1995, which circumscribe the use of electronic signatures in the provision of consumer credit agreements. When we talk about electronic signatures, it is usually a more secure version of a user-name and a password — not a signature per se. Anybody who uses electronic banking will know that there is some additional security, over and above user-name and password. Essentially, however, that is what an electronic signature means.

In other countries, consumer legislation has been updated to reflect the benefits of electronic commerce. From being a leader in this area with the signing of an e-commerce treaty by former US President, Bill Clinton, and the former Taoiseach, Deputy Bertie Ahern, in 1998, Ireland is now a laggard. In the UK, electronic signatures are permissible under existing law for credit agreements.

Danske Bank, which trades in Ireland as National Irish Bank, is investing heavily within the Danske Bank Group to develop its electronic offering and aims to become a world leader in this respect. We have already invested €150 million on both sides of the Border to transform the technology of National Irish Bank and Northern Bank to Scandinavian banking levels.

In Danske Bank a project has been initiated that will lead to the automation of a large number of processes, implying that most of the documents currently available in hard copy will be replaced by electronic documents to be signed by the customers via a digital signature. Most of the group's bank customers will be electronic in the space of a year or two. Unfortunately, within the 11 countries where Danske Bank operates, Ireland is the only country that does not allow electronic signatures for credit contracts.

Electronic banking entails significant streamlining of the entire bank. The savings obtained will benefit customers both in terms of cheaper products and faster processing, using technology which has now become an integral part of customers' daily lives. The customer has exactly the same protection with electronic signatures as with traditional ones, such as the disclosure of information and a cooling-off period. That does not change.

The environmental benefits of e-banking are immense. Transferring all customer agreements from paper to electronic form will allow Danske Bank to offer more efficient services and reduce its use of natural resources. Danske Bank reduced paper use last year by more than 500 tonnes through the use of electronic banking.

Another problem more specific to Ireland is our pay-on-time culture. Those countries with an intensive use of electronic transfers, generally speaking, have a much better pay-on-time culture, which is a big issue for small and medium-sized enterprises. It might be a spin-off benefit of a greater use of electronic banking.

In terms of a solution, the Department of Finance is currently engaged in a process of consultation concerning the EU directive on credit agreements for consumers, which must be transposed before next summer. National Irish Bank believes this represents an important opportunity to modernise Irish legislation to take account of the rapid technology improvements seen in banking over the past two decades. If we miss this opportunity, it could take another three or four years before this issue is revisited.

There is likely be a continuing difficulty with the discharge of on-line banking in Ireland, in the absence of specific confirmation by law that: (i) where a consumer so desires, credit agreements may be concluded electronically; and (ii) where certain material must be provided to a customer, it is permissible to provide such information in an electronic format. Both of these provisions, as they currently stand, are retarding innovation in Irish banking, adding unnecessarily to the environmental impact of banking, and adding costs and delay for bank customers. The directive separates mortgages and contracts under €75,000. What we are specifically seeking relates only to loans under €75,000.

There is a compelling case that modernisation of the legislation is required. While the current focus of policy-makers and this committee is, rightly, on the stabilisation of the economic crisis, it is important that we take every opportunity to reform outdated legislation to promote efficiency in all areas of enterprise. Through the use of technology being developed by Danske Bank, we can bring this cutting-edge technology and innovation to the Irish market, but we are frustrated in doing so by the current legislation.

Before moving on to questions, I wish to ask Mr. Mulcrony if he has any comments to make. I understand that he was involved in the Forfás report on electronic banking.

Mr. Seamus Mulconry

Some years ago, I worked on a Forfás report on e-commerce, which examined national and international developments. We also looked at ways in which Ireland could leap ahead of the competition. As Dr. O'Toole said earlier, with the initial legislation, Ireland was moving faster than the rest of Europe, but I now fear that we have fallen far behind.

I thank the delegation for its presentation. It is clear that if we move to electronic transactions the system will be more efficient. Dr. O'Toole did not indicate the scale of the efficiencies or savings from the viewpoint of individual banks or of the sector as a whole. It would be interesting to know the scale of saving he envisages. How does he see those savings being shared out between consumers and the banks in terms of the benefit of moving to an electronic system?

The other question that arises, I suppose partly from the recent EU study on Irish banks, which showed that the banks in Ireland have a notorious record in concealing charges from consumers and in offering poor advice on the choice of financial product and came in for quite a drubbing from the EU overseer of banking standards, is that, naturally, people will be suspicious that where a banking system which has a somewhat bad record of consumer protection proposes to go electronic, there is scope for even more concealment and poorer standards of advice and alerting people to their rights and obligations. In the context of changing this legislation, what would be the quid pro quo in tightening up consumer protection standards which, clearly, have become shoddy in Ireland by international standards?

Dr. O'Toole will probably appreciate that sentences such as that the existing provisions are retarding innovation in financial products, are not music to the ears of most people at present where financial innovation in this territory is what has been the root of many of our problems. That is not to say that moving to electronic transactions cannot be introduced in a way that provides adequate protection and ensures that the efficiencies are fairly shared out. However, what was notably lacking from his presentation was any consciousness of the impact on consumers of this or how they would be seen to benefit other than a remark that if it is cheaper to do business, there is scope for cheaper financial products — there is also scope for higher margins. That area seems to be missing from Dr. O'Toole's presentation and would be needed in the context of moving to bring in the legislative provisions of which he speaks.

Dr. Ronnie O’Toole

If I do not deal with all of the points, please come back to me.

What we mean by innovation, which mirrors the debate in the public service, is streamlining the back-office operations of banks and focusing on what banks should do, which is talk to and advise their customers, as opposed to bright new financial products per se.

The scale of savings involved is difficult to quantify and has never been quantified. To give it a sense, along with all of these documents there is obviously a stamp and there is always the processing and so on. A ream of photocopy paper will cover approximately five customers or so in the space of a year. We are talking about a significant amount of paperwork most of which, entirely unnecessarily, goes out to consumers.

On whether all banks will pass the saving on or how that process will work, the present system is an open competitive one. In National Irish Bank, Danske Bank initially invested €150 million here to become the leading e-bank. For example, anyone who conducts a cross-Border payment between National Irish Bank and Northern Bank electronically does so for free now. We can introduce such innovations for people who use these efficient forms. We have done so and we will continue to do so. We invested €150 million in the electronic platform exactly for this purpose. However, where we, who have invested so heavily, are required to follow paper routes, obviously, that prevents us from passing on the true benefits of electronic.

The other point about scale is that approximately one third of adults now use e-banking. Obviously, a customer who does not use e-banking will continue to get whatever current communications on paper he or she receives. Much of the success of this and the cost benefits that arise depend on people taking up e-banking. The customer has a choice in that regard. This will be beneficial only as soon as e-banking becomes more acceptable but if we follow the route of what has happened in Scandinavia and in Europe, one will see that e-banking take-up will increase over time.

I can understand why Deputy Bruton raised the banking standards issue. This is a separate issue. We are not talking here about the type of communication, what they must communicate or how they communicate it, and that is obviously an issue for the regulator and for the bank. We have no difficulty with that. The difficulty here is that it does not make sense where we must send the guts of 100 pages for a relatively small loan, for example, for a holiday. It is the way one communicates as opposed to the volume one communicates, and that is a matter which we, the industry and the regulator, must get right.

In the nature of such legislative changes, Dr. O'Toole must be up-front with the sort of changes that the banks will offer as a quid pro quo for being able to secure this sort of saving. He and the banking federation need to put more thought into how the banks will put something into the balance where the State can see we are getting something more than the efficiency gains and getting something that is fair to the users of their services. I suggest there is a little more work to be done on how to deliver better advice, better information and all of the other matters with which the EU is clearly unhappy.

I thank both gentlemen for coming in. Dr. O'Toole referred in his presentation to efficiencies in the public sector and that they are looking for similar efficiencies in the private sector. One would expect that the savings in the public sector will bring about savings to the taxpayer. The question is, will efficiencies in the banking sector bring about savings to the banks' customers. Deputy Bruton touched on that point. Dr. O'Toole referred to €150 million of investment Danske Bank has put into the area, and I ask him to expand on that. If he uses the comparison with the public sector which is about savings to the taxpayer, I want him to deal with how this will translate into less charges for bank customers.

Dr. Ronnie O’Toole

On efficiency, I can speak not for the banking industry but for my bank. As I stated, National Irish Bank has been a strong innovator in this area. It has put its money where its mouth is when it comes to investing in technology. I particularly referred to the cross-Border trade example. While I am open to correction on this, I still think National Irish Bank is the only bank that offers free cross-Border banking.

Incidentally, this is exactly what electronic commerce allows. We see that in our home markets in Copenhagen but within the Republic of Ireland, we simply cannot do much of what we would like to do. We have invested a great deal of money. We are a relatively small player in terms of the overall market. Given our investment, we would like to be a bigger player and we can be, particularly in the e-banking space. We are limited in so far as we want to pass on these benefits but all of this added cost makes it difficult to do so.

The other immediate beneficiary is our customers. We speak only of those who want this. It is, if you like, between consenting adults. We agree to communicate with someone electronically and he or she is happy with and wants that. The person does not want this paper. That is one of the paradoxes that has come out of this. The original legislation was framed with this sealed unmarked envelope precisely to make it more secure and it has ended up meaning that many letters and much paper is going around about people's e-banking, which the people do not want sent, which could lead ultimately to identity theft because it all must be disposed of. It has ended up closing off a technology route that is more secure. It is unfortunate. It comes from the drafting of it. Nobody consciously wanted letters necessarily going out when the customer did not want it.

Danske Bank has put €150 million into the project. The bank will encounter the elderly and others who will not have access to computers and Internet banking. Has that €150 million investment given rise to extra charges to the existing customer base?

As legislators, we look at matters in terms of the benefits to customers. If we were to go the electronic route, would this be a rising tide that would lift all boats? Will it be the case that those who are less well off will not be obliged to pay significantly higher charges than people who go the electronic route?

Dr. Ronnie O’Toole

I do not know what the future will bring. The change we seek will not raise costs for any other consumers. I would have thought that consumers who choose much more efficient routes and who do not want everything to be provided in paper form would be charged less than others. This would not leave traditional bank customers any worse off, although it will probably not make their lives a great deal better either. That is just the way of the world.

National Irish Bank is quite an old institution, while Danske Bank has only been operating in Ireland for four years. A large proportion of our customer base would be quite traditional and in light of the bank's origins, is probably clustered near the Border in Donegal and other areas where access to the Internet might not be great. As a result, the level of take up might not be great. We will continue to service the needs of these traditional customers. We only want to change things for people who want to move on and do their banking in a different way.

I would not like customers who do not have access to the Internet to be penalised because the bank is going the electronic route.

Mr. Seamus Mulconry

It is important to realise that bank charges in Nordic countries are lower. One of the reasons for this is that banks are able to deliver services cheaper. There is a renewed focus on the part of all consumers — this was lacking during the boom — on obtaining value for money, whether it be from banks, retailers or whomever. This renewed focus will assist in driving competition in the banking and every other sector.

With regard to the adoption of computers by people who are elderly or who belong to marginalised communities, there are a few matters to note. Earlier this week, the winner of the "Silver Surfer" award was announced. The individual in question is 95 years of age. We have found that, in international terms, older people are taking up the use of e-mail, mainly to communicate with their grandchildren when they go to college. The idea that all of the elderly are not embracing computers is not quite accurate. I accept that more probably needs to be done to include various groups of people in marginalised communities. The Department of Communications, Energy and Natural Resources ran a very good scheme, namely, the CAIT, or community application of information technology, initiative, which reached out to these individuals. Something similar to that scheme is necessary, not so much from a banking perspective but rather from a social one.

I welcome our guests. Unfortunately, I did not arrive until midway through Dr. O'Toole's presentation. However, what we are discussing seems to be a "no-brainer". It is an extremely good idea. What has been the response of the Department of Finance to what is proposed? What is preventing our guests from proceeding as quickly as possible? I accept that there is a legislative requirement. Will our guests indicate the response they have had from the Department of Finance? I am of the view that there is no reason the legislation could not be amended.

Dr. Ronnie O’Toole

We agree. It is merely a case of priorities. Section 45, which holds sway in this area, was a drafting error and if other events had not intervened, it would definitely be changed. Understandably, however, there is a great deal happening at present and what we are discussing is not the first priority.

The position with regard to electronic signatures might be somewhat different. There might still be a traditional mind set in this regard and people may feel that it is better to get someone's signature on paper. This is despite the fact that in 1998 Deputy Bertie Ahern and President Bill Clinton provided a signal, by signing a document electronically, that the world was moving on. It is mostly an issue of priorities. The difficulty is that we are loading a huge cost on to the economy which is entirely unnecessary and also it will be three or four years before this matter will be revisited. If we could make the change now, the banking sector could proceed to introduce these efficiencies without——

Did the Department of Finance raise any objections?

Dr. Ronnie O’Toole

We have spoken to everyone and no arguments have been put forward to us. If people have concerns, we will be happy to deal with them. However, no one has raised any such concerns. We discussed this matter with the Financial Regulator, the National Consumer Agency and everyone else involved.

I thank our guests for attending. Is Dr. O'Toole aware of any breaches of the Consumer Credit Act by any of the banks? What kind of checks and balances does the Financial Regulator insist upon at present? How can we be confident that banks are ignoring the regulator and sending out information by electronic means? I do not refer specifically to the NIB in this regard but perhaps Dr. O'Toole might indicate the checks the Financial Regulator carries out in respect of it.

Dr. O'Toole stated that in a year or two most of the bank's customers will use electronic means to do their business. Does the delay in this regard relate to the time it takes to scan documents on to the bank's systems? Why is there such a delay if this is the perfect system?

Does the €150 million purely relate to signature-based technology or does it represent a total investment in information technology? More work must definitely be done in respect of how much money will be saved. In addition, such money would have to be ring-fenced and passed on to customers.

Dr. Ronnie O’Toole

I simply do not know the answer to the question relating to the Financial Regulator. I do not have a day-to-day involvement with the regulator in respect of the checks it may carry out. The fact is that we send these out all the time because we are obliged to do so. I can communicate further with the Deputy in respect of that specific issue when I have spoken with those who know the actual position. It is just not my area.

With regard to transforming the business, there has been a great deal of investment on the part of Danske Bank to encourage people to transfer their business and get used to the new system. If someone applies for a personal loan on-line, he or she merely has to get used to the new system. Bank staff and others have to be educated in this regard. We are introducing the technology product by product. It is happening in other countries but it takes time.

The figure of €150 million refers to the entire island of Ireland. It, therefore, reflects the investment in Northern Bank as well as NIB. It relates to the initial transformation of our old technology. When NIB was owned by National Australia Bank, its technology was probably the worst in the entire banking sector. I am not an expert in technology. However, if one compares photographs of our branches now with ones which show how they used to look, one will see that they are very different. The €150 million represents the initial investment required to bring the technology in all our branches up to par with that which obtains in Scandinavian bank branches and to transfer all our customers over. I have not added in the additional investment that has been made in the interim. Any other investment by the group into the e-banking platform will be additional to that. The figure reflects the initial investment in the island of Ireland and the transfer of the technology.

In the context of savings, I reiterate that it is a free market sector. Any large costs such as that under discussion will ultimately be recouped. On the question of driving down costs, we are referring here to customers who do not want the information which, by law, we are being forced to provide. No one is really benefiting here. All I can do is speak to members as a representative of NIB. We have shown in the past that, where we are allowed to do so, we will introduce prices to make our products competitive. That will continue to be the position in the future. Danske Bank has reaffirmed its presence in Ireland and is here for the long haul. I would not be attending this meeting if that were not the case. However, we need the requisite legislation to be in place so that we might use our technology to compete effectively with the other banks.

I thank the delegation for the interesting presentation. I am learning a great deal. I am particularly impressed by the fact that we passed a law that states all communication must be in unmarked, sealed envelopes and, therefore, e-mail and fax cannot be used. It was the right thing to do five years ago but not now. How much time will it take to make the change? Can the change be introduced in the Finance Bill or how can it happen?

I am a great believer in competition. NIB is in competition with other banks. The bank needs to generate additional income and it will, therefore, not do something that will lose customers. The move towards paperless banking must be attractive for the bank and its customers. Mr. Mulconry said the Scandinavian bank had lower costs because it used more electronic means of communications and that should be an encouragement to us. If the bank moves too fast, it will lose customers who do not have access to electronic communication. Ryanair is doing away with check-in desks in airports because it has worked out it will make more money with customers being able to adjust to that change regardless of whether the company has tried it out.

The interchange fee is my main concern. I have been involved with EuroCommerce in Brussels. It took ten years for the organisation to win a case against Mastercard and Visa regarding this fee, which is charged to retailers for using credit cards. The case referred to cross-border communication in this regard but in the long term, the fee, which is of no value to customers, is a percentage of the transaction on a credit card whereas the cost of the transaction is the same whether the customer spends €10 or €2,000. We must find a way to ensure that we reduce the costs, which result in additional profits for banks associated with the credit card companies. I am anxious to encourage paperless and cashless banking but that will not happen unless it is cost effective. Banks and credit card companies do not have a major incentive to encourage this form of banking. Will customers benefit with a reduction in costs if paperless banking is introduced?

Dr. Ronnie O’Toole

With regard to legislation and how the change can be made, the directive on consumer credit has to be transposed by next summer. Its wording is open and it is all the things one would expect. It is open to documentation, whether it is sent electronically or by paper and to whether an individual signs electronically or on paper and, therefore, we could use the fact legislation will be passed anyway to deal with these issues as well. This directly relates to consumer credit and it is the natural way to do this. The Department of Finance is working on this and it will probably publish something in the next few months. If we miss this boat, we will probably have to wait another three or four years before the proposal is revisited. This is a no brainer. It was a legislative accident in the first place, as the Senator said. The wording of the legislation was not technology neutral, which it should have been. That can be corrected now and costs reduced.

I will have to get back to the Senator on the interchange fee issue. I am a big fan of debit cards. Cash costs money. It costs money to get Securicor vans going around and it costs money as a retailer. If I could contact the Senator separately about this issue, I would appreciate it because it is not my area.

I warmly welcome much of what has been proposed. Dr. O'Toole drew two conclusions and stated the law should be updated in order that "where a consumer so desires, credit agreements may be concluded electronically; and where certain material must be provided to a customer, it is permissible to provide such information in an electronic format". I agree with the second conclusion but not the first, which is not right. When people download banking documents, 99% agree to the terms and conditions without reading a page. They could have agreed to go to Seattle to wash Bill Gates's car. Where there is a credit or investment transaction, the only way to know for certain the person is aware of his or her responsibilities is if an official co-signs it with him or her. I do not agree with the first conclusion but I warmly welcome the second.

A great deal of misselling is happening currently with consumers saying they did not understand the products they purchased. With the Financial Regulator saying people have been missold products, it is essential that somebody is available face to face to explain in detail the terms, conditions and responsibilities applying to the credit and investment agreement being signed. It would be wrong of us to signal that anything else would be correct.

This would be hugely beneficial to NIB and this is the way banks should go forward. The days of banks replacing the lost income of the past 20 years by increasing fees are well over and I doubt current or future Oireachtas Members would tolerate that. The way NIB is moving forward by cutting costs is the way forward for banks generally.

Dr. Ronnie O’Toole

It is important to clarify a few issues. Credit transactions are treated differently for a good reason. As the Senator pointed out, more protection must be in place for credit transactions rather than for other transactions. For example, as an e-banking user, I have on-line share trading. I could buy shares in Smurfit tomorrow but I do not have a two-week cooling off period if, four days later, I decide I do not like them and I want to go back. All the protections that are there for credit transactions are identical and that is important. When a customer says "Yes", the credit agreement goes through the credit department of the bank which will do all the things the bank should do in checking out how well they know the customer.

I am worried about the consumer, not the bank. The consumer is agreeing to something on-line that should be explained to him or her in detail in person to make sure he or she understands. My view will not change on this. I worked for 17 years in a financial institution and I know products were missold. Customers did not understand products even when officials were standing in front of them. How could they understand when all they have to do is sit in front of a computer and click on a box saying "Yes, I agree"?

Danske Bank is affiliated to the Irish Bankers' Federation. What is its approach to this?

Significant savings would accrue if paperless banking were introduced. As an incentive for the State to proceed quickly and amend the legislation to provide for this change, could the IBF agree a proposal whereby the banks would give a proportion of the savings they make back to the community or the State or as a dividend to the customers of each institution rather than use the savings to increase their margins while nothing is reduced for the customer, as Deputy Bruton said? I assume this is a long shot.

Dr. Ronnie O’Toole

The IBF has a view and it is strongly supportive of both. Officials from every bank will come before the committee and discuss section 45, in particular, which relates to the volume of paper. We are more likely to talk about electronic signatures because, frankly, it is a competitive advantage of ours as we have got a better e-banking platform so it is more advantageous for us than it is for the other banks. We are ahead of the game because we have that Danske Bank technology. Everybody is supportive of this and the IBF has been very clear and has talked about this. There is really not a great deal of disagreement on this topic. I would not be able to answer the second question about the IBF but I am happy to send on the Senator's comments to them and to the chief executive.

I am their nominee to the Seanad so I would be able to do that myself. On the second point to do with the level of savings, is it feasible to expect that financial institutions could save 15% of all savings as a result of new legislative parameters with regard to e-commerce, that there could be a kick-back either to the customer or to civic society, to some group yet to be established by IBF, Danske Bank or whoever?

Dr. Ronnie O’Toole

I am not sure how feasible that would be as we do not even have an estimate of the savings. I am sure we can think about that as a result of talking to the IBF. Being a very small player, we want to offer cheaper products to win customers and we think the cheaper product in this sense is a much better product. The e-banking product is a much better product than the more expensive paper-based one. It is a result of our self-interest. In order for us to grow as a bank we offer cheaper products.

I thank Dr. O'Toole and Mr. Mulconry for their attendance and for their presentation to the committee which was very interesting. I propose that a transcript of this meeting be sent to both the Minister for Finance and the Minister for Enterprise, Trade and Employment along with a covering letter stating that the committee considers this a matter deserving of serious and immediate consideration. I am sure we will have further discussions on this matter in the future. I thank the delegates for giving the committee the benefit of their knowledge and experience.

Sitting suspended at 3.02 p.m. and resumed at 3.05 p.m.