Tuesday, 6 Feb 2018

Written Answers Nos. 125-141

Departmental Staff Data

Ceisteanna (125)

Clare Daly

Ceist:

125. Deputy Clare Daly asked the Tánaiste and Minister for Foreign Affairs and Trade the number of secondees from companies (details supplied) who work in his Department. [5835/18]

Freagraí scríofa

Tánaiste and Minister for Foreign Affairs and Trade

There are no secondees from the companies named in the Deputy’s question working in my Department.

Middle East Peace Process

Ceisteanna (126)

Tony McLoughlin

Ceist:

126. Deputy Tony McLoughlin asked the Tánaiste and Minister for Foreign Affairs and Trade the degree to which Ireland and the EU continue to maintain a positive influence on the Israeli-Palestinian peace process, with particular reference to President Trump's administration growing partiality in the matter; and if he will make a statement on the matter. [5935/18]

Freagraí scríofa

Tánaiste and Minister for Foreign Affairs and Trade

Ireland, along with our EU partners, supports the achievement of a two state solution to the Middle East conflict. This support includes political efforts to encourage a resumption of direct negotiations, which are ultimately the only way to achieve peace. It also includes action on the ground on human rights and justice issues affecting Palestinians under occupation, including settlement activity, which are progressively endangering the prospects of such a peace agreement.

During my recent working visit to Israel and Palestine, on which I have reported to the House, I met with both President Abbas and Prime Minister Netanyahu, as well as other representatives of the Government of Israel and the Palestinian Authority, and discussed with them reinvigorating the effort towards peace in the Middle East. In recent months the new United States administration has been exploring the possibilities for re-launching the process to reach a comprehensive peace agreement. This engagement is very welcome, and I have met myself with the US team to encourage their work and to underline to them the key parameters for an agreement which the EU has long espoused.

I was very disappointed at the US announcement recognising Jerusalem as the capital of Israel and initiating steps to move the US Embassy, a move which I believe was premature and unhelpful to efforts to resolve the conflict in the Middle East. High Representative Mogherini issued a similar statement on behalf of the EU. However, I have continued to encourage Palestinian representatives, including President Abbas, to keep an open mind on the potential of the US peace efforts.

In discussions with my EU colleagues, most recently at the Foreign Affairs Council on 22 January, I have stated that the EU must continue to encourage an appropriate US initiative, but also that the EU continue our own work, including work on the ground, to help preserve and create the political and physical space in which the two state solution can be achieved. I am actively exploring with EU colleagues how this can best be done.

Primary Medical Certificates Data

Ceisteanna (127, 148)

Caoimhghín Ó Caoláin

Ceist:

127. Deputy Caoimhghín Ó Caoláin asked the Minister for Finance the number of appeals lodged by persons refused a primary medical certificate to the Disabled Drivers Board of Appeal in the past five years, by county; the number of these appeals which were successful; and if he will make a statement on the matter. [5738/18]

Éamon Ó Cuív

Ceist:

148. Deputy Éamon Ó Cuív asked the Minister for Finance the reason persons who have lost one arm are not eligible for a primary medical certificate under the disabled drivers scheme; his plans to review the criteria of the scheme; and if he will make a statement on the matter. [5875/18]

Freagraí scríofa

Minister for Finance

I propose to take Questions Nos. 127 and 148 together.

I am advised by the Disabled Drivers Medical Board of Appeal that the total number of appeals lodged and the number of successful appeals in the period 2013-2017 is as set out in the table. However the Board do not have a breakdown of these figures by county.

Year	No. of Appeals Lodged	No. of Successful Appeals
2013	529	53
2014	585	44
2015	600	16
2016	720	22
2017	680	12

Note: not all appeals lodged are presented at hearings due to cancellations and 'no-shows'.

In accordance with Regulation 6(1)(e) of S.I. 353/1994 (as amended) the Board is independent in the exercise of its functions.

Household Debt Statistics

Ceisteanna (128)

Fiona O'Loughlin

Ceist:

128. Deputy Fiona O'Loughlin asked the Minister for Finance if figures are available that measure the level of credit card debt to household income; if so, the detail of same in each of the years 2011 to 2017, in tabular form; and if he will make a statement on the matter. [5319/18]

Freagraí scríofa

Minister for Finance

I understand that the Central Bank of Ireland does not publish data on the level of credit card debt. However, the Household Finance and Consumption Survey 2013, which was carried out by the CSO on behalf of the Central Bank of Ireland provides a snap shot of credit card debt in Ireland. The survey, which was published in January 2015, shows that the median value of credit card debt for households was €1,400 in 2013 or around 4.1 per cent of median household disposable income.

While data on credit card debt is very limited, the Central Bank of Ireland regularly publishes data on broader measures of household debt. Over the period 2011 to the second quarter of 2017, short-term loans of Households and Non-profit Institutions serving Households fell from €7.9 billion or around 9.1 per cent of disposable income to €3.9 billion or around 3.9 per cent of disposable income.

This improvement reflects both a decline in the value of debt outstanding and solid growth in disposable income which has averaged 2.7 per cent over the period 2012 to the second quarter of 2017.

Help-To-Buy Scheme

Ceisteanna (129)

Pat Deering

Ceist:

129. Deputy Pat Deering asked the Minister for Finance when a person (details supplied) will receive their rebate from the Revenue Commissioners regarding the help-to-buy scheme. [5332/18]

Freagraí scríofa

Minister for Finance

I am advised by Revenue that the claim made by the person concerned for a refund under the Help-to-Buy scheme has been approved.  Contact has been made by Revenue with the person concerned to clarify certain matters as regards bank account details supplied.

When this clarification is provided, Revenue advise me that they will be able to finalise the refund.

NAMA Social Housing Provision

Ceisteanna (130, 131, 132)

Barry Cowen

Ceist:

130. Deputy Barry Cowen asked the Minister for Finance his plans to expand the National Asset Residential Property Service, NARPS, model to increase the supply of social housing; and if he will make a statement on the matter. [5335/18]

Barry Cowen

Ceist:

131. Deputy Barry Cowen asked the Minister for Finance the number of staff employed by NAMA; the annual operating costs; the number of staff engaged with the NARPS model per annum in each of the years 2011 to 2017, and to date in 2018, in tabular form; and if he will make a statement on the matter. [5336/18]

Barry Cowen

Ceist:

132. Deputy Barry Cowen asked the Minister for Finance the amount spent to date through the NARPS model; the number of units acquired; and if he will make a statement on the matter. [5337/18]

Freagraí scríofa

Minister for Finance

I propose to take Questions Nos. 130 to 132, inclusive, together.

I am advised that to date, NAMA has delivered 2,472 houses and apartments for social housing, excluding houses provided under Part V arrangements. NAMA provides whatever funding is required to ensure that social housing units are habitable and in full compliance with all statutory requirements and to date, it has invested approximately €350 million in remediating, completing and purchasing properties for social housing use. NAMA established a special vehicle, NARPS, to purchase suitable units for onward leasing to local authorities and approved housing bodies.

Demand has been confirmed by local authorities for 2,684 residential properties and 2,472 of these properties were delivered or contracted for delivery by end-2017. This included 1,372 units which are leased, or contracted for lease, by NARPS to local authorities and approved housing bodies. I am advised that, as set out in the NARPS’ Financial Statements for 2016, the most recent to be published, the acquisition cost of NARPS’ property assets as at the end of 2016 was €189m.

I am advised that as NAMA is now well advanced on its deleveraging programme, there is no longer any suitable stock available for purchase from debtors and receivers and accordingly there is no scope to expand the NARPS portfolio further.

I would remind the Deputy of the announcement this week by the Minister of State with Special Responsibility for Housing and Urban Development of the Enhanced Long-term Social Housing Leasing Scheme. This scheme, which involves the Department of Housing, Planning and Local Government, the NDFA and the Housing Agency, was established on a similar basis to the NARPS model and will enable the private sector to invest in providing properties that can be leased to local authorities for use as social housing on a long-term basis for up to 25 years. This initiative is targeted at delivering housing units additional to those delivered through Part V arrangements.

I also wish to advise the Deputy that at the end of 2017, NAMA staffing figures stood at 255 (net of resignations). Administration costs for the Agency in 2016, the last full-year for which accounts are available, were €80m.

The NAMA team which manages NAMA’s social housing interests has since 2012, comprised two full-time staff members. These two members of staff are NTMA staff assigned to NAMA and are not exclusively dedicated to NARPS work. They are supported on a part-time basis by staff from NAMA’s Legal and CFO divisions.

Year	Full-time staff	Staff (part-time basis)
2011	2	2
2012	2	3
2013	2	3
2014	2	3
2015	2	4
2016	2	4
2017	2	3
2018	2	3

Commercial Property

Ceisteanna (133)

Pearse Doherty

Ceist:

133. Deputy Pearse Doherty asked the Minister for Finance his views on the reliance since 2012 on commercial mortgage backed securities, CMBS, by some property investment funds operating here; and if his Department conducted risk analysis as to the exposure of the property market here to CMBS. [5344/18]

Freagraí scríofa

Minister for Finance

In respect of commercial property funds, the Central Bank is responsible for the authorisation and supervision of all investment funds established in Ireland. In conjunction with the Central Bank, my Department continually monitors developments in the commercial property sector. This includes tracking investment, transactions and the profile of market participants.  In addition, last year’s International Monetary Fund Article IV report assessed the commercial property market as performing strongly.  The Central Bank’s Macro Financial Review, published biannually, contains detailed analysis of the commercial property market, including important information on the vacancy rate, rent/competitiveness pressures, and the funding sources of investments. 

The supply of funding for commercial property development is important to maintain our international competitiveness and as such the funding for the market should preferably be drawn from a variety of sources. The use of a wide range of international funding models, including potential structures like commercial mortgage backed securities (CMBS), has been particularly important in supporting the necessary deleveraging of the Irish State and economy through National Asset Management Agency (NAMA) and Irish Bank Resolution Corporation (IBRC) sales.

The aforementioned analyses illustrate a market that is currently seeing strong demand and a supply response, which is primarily being funded (70%) by foreign investors.  These analyses and the balance of risks across the property sector informed my decision in Budget 2018 to increase the rate of Stamp Duty on Non-Residential Property from 2% to 6%. 

In terms of additional analysis, my Department works with the Central Bank and the National Treasury Management Agency on the Financial Stability Group (FSG), which monitors a wide range of risks to financial stability.  The FSG’s emphasis is on forward-looking assessments of financial stability with a particular focus on identifying risks.  The FSG’s work programme for 2018 is currently being finalised and work on commercial real estate is being considered as part of that work programme.  This emphasis is in line with the recommendations of the Banking Inquiry and the IMF’s 2016 assessment of the Irish financial sector.

Brexit Issues

Ceisteanna (134, 135, 136)

Stephen Donnelly

Ceist:

134. Deputy Stephen S. Donnelly asked the Minister for Finance the estimated impact on Ireland of the reduction of economic growth in the United Kingdom by 5% for the next 15 years (details supplied); and if he will make a statement on the matter. [5425/18]

Stephen Donnelly

Ceist:

135. Deputy Stephen S. Donnelly asked the Minister for Finance the estimated impact on Ireland of the reduction of economic growth in the United Kingdom by 8% for the next 15 years (details supplied); and if he will make a statement on the matter. [5426/18]

Stephen Donnelly

Ceist:

136. Deputy Stephen S. Donnelly asked the Minister for Finance the estimated impact on Ireland of the reduction of economic growth in the United Kingdom by 2% for the next 15 years (details supplied); and if he will make a statement on the matter. [5427/18]

Freagraí scríofa

Minister for Finance

I propose to take Questions Nos. 134 to 136, inclusive, together.

My Department has been to the fore in producing and funding a number of Brexit-related studies, both before and since the UK's referendum decision. In addition, regular updates of the Department’s Macro-Economic forecasts take account of the impact of Brexit. Published Brexit-related studies by my Department include:

- 'Scoping the Possible Economic Implications of Brexit on Ireland' – A scoping study of scenarios for the future relationship between the UK and the EU. Published under the Department of Finance-ESRI research programme in November 2015;

- ‘An Exposure Analysis of Sectors  of the Irish Economy’. An in-depth analysis of the possible sectoral and regional impacts of Brexit arising from Ireland's trade relationship with the UK, published by Department of Finance in October 2016  (Updated March 2017);

- 'Modelling the Medium to Long Term Potential Macroeconomic Impact of Brexit on Ireland' -  Published under the Department of Finance-ESRI research programme in November 2016; and

- ‘Trade Exposures of Sectors of the Irish Economy in a European Context’ – An analysis of trade exposure to the UK in comparison to other EU Member States, published by Department of Finance in September 2017.

All of these studies have been made public.

My Department's own published research shows that the potential impact of Brexit on the Irish economy is significant.  The joint paper my Department published with the ESRI, assessed the medium to long term potential macroeconomic impact of Brexit on Ireland, under three scenarios, (i) an EEA type arrangement, (ii) an FTA agreement, and (iii) a WTO arrangement. The study shows that ten years after a UK exit from the EU, the level of Irish output, could reduce in a range from 2.3 per cent to 2.7 per cent and 3.8 per cent (i.e. under a EEA scenario, a FTA scenario and a WTO “hard Brexit” scenario, respectively), below a baseline of what it otherwise would have been. Most of the negative impact would occur in the first five years, under each scenario.  These results are on a no policy change basis. To that extent, the results of the reported UK analysis show a similar impact to those identified for Ireland, with the EEA type arrangement showing the lowest impact, and the WTO arrangement showing the biggest impact.

In addition, to the three scenarios assessed in the 'Modelling the Medium to Long Term Potential Macroeconomic Impact of Brexit on Ireland' paper, simulations published in Budget 2018 (last October), show that a permanent reduction of 1 percent in the level of global output would reduce Irish output by 1.1 percent lower after 5 years, relative to a baseline projection.  However, as we cannot control the international environment, it is crucially important that we prepare our economy for the challenges ahead.

In this context, the Government has already taken a number of important steps including in Budgets 2017 and 2018, the Action Plan for Jobs, Ireland Connected our Trade and Investment Strategy and the preparation of a new 10-year Capital Plan. The best way to deal with the uncertainties arising from Brexit is to continue the Government’s competitiveness oriented policies and prudent management of the public finances.

Tax Code

Ceisteanna (137)

Michael McGrath

Ceist:

137. Deputy Michael McGrath asked the Minister for Finance the position on the planned introduction of a tax on sugar-sweetened drinks as set out in the Finance Act 2017; when he plans to bring this tax into operation; the position regarding his Department's contact with the European Commission in relation to state aid; the work that has been carried out on the introduction of this tax since budget 2018; and if he will make a statement on the matter. [5478/18]

Freagraí scríofa

Minister for Finance

As announced in Budget 2018, a Sugar Sweetened Drinks Tax (SSDT) is to apply to the first supply in the State of sugar sweetened drinks. Primary legislation for the SSDT was included in the Finance Act 2017 and is subject to a commencement order.  

The commencement of the SSDT is subject to approval from the European Commission on State aid grounds. In the first instance, Ireland submitted a notification under the Technical Standards Directive (2015/1335) which informed the European Commission and other Member States of the introduction of the SSDT. The obligatory 3 month standstill period has expired and that process is completed.  Following a pre-notification process, a formal notification of our intention to introduce the SSDT was submitted to the European Commission under article 107 (3)(c) of the TFEU, and we are awaiting approval.

The expected commencement date for the SSDT is 6th April 2018, which coincides with the introduction of a similar tax being introduced in the UK on that date.

In addition, I am advised by Revenue that the following further preparatory steps for the introduction of the tax have been made:

- Detailed discussions have taken place with the soft drinks industry on practical issues in relation to implementation of the tax;

- Draft guidance for the industry on the operation of the tax was provided to interested parties and tax advisors in January;

- Systems development work on Revenue IT infrastructure, payments processing and other tax administration, accounting and collection processes are underway and will be completed in time for the introduction of the tax.  

Tracker Mortgage Examination

Ceisteanna (138)

Pearse Doherty

Ceist:

138. Deputy Pearse Doherty asked the Minister for Finance if lenders subject to the tracker review have indicated to the Central Bank that they will reduce the number they are of the view are impacted by the tracker scandal compared with their statement of December 2017; and if he will make a statement on the matter. [5631/18]

Freagraí scríofa

Minister for Finance

The Central Bank has advised that, based on its most recent progress update report on the Tracker Mortgage Examination which was published on 20 December 2017 and on certain updated data that the Bank provided to the Joint Oireachtas Committee on Finance, Public Expenditure and Reform and Taoiseach on January 18 last, lenders have included c.33,700 customers as affected by tracker mortgage failings with €316 million paid in redress and compensation so far. T his includes 7,100 impacted tracker cases which were remedied outside of the examination framework.

While the Central Bank’s view is that the vast majority of impacted customers have now been identified, it will continue to review, challenge and verify the work undertaken by the lenders and complete its intrusive on-site inspection programme. The examination continues to be a priority for the Central Bank and it will continue to challenge lenders in respect of the conduct of the Examination to ensure that all affected customers are identified and any emerging issues are addressed.  I look forward to receiving a further progress update report from the Central Bank based on end-March 2018 data in due course.

European Central Bank

Ceisteanna (139)

Pearse Doherty

Ceist:

139. Deputy Pearse Doherty asked the Minister for Finance if the banks here or the Central Bank have engaged with the ECB requesting supervisory guidance on the appropriate use of non-performing mortgage splitting; and if he will make a statement on the matter. [5633/18]

Freagraí scríofa

Minister for Finance

All lenders in Ireland engage on an ongoing basis with their Joint Supervisory Team (JST) on their lending and recovery activity, this would include supervision of the use of loan restructuring solutions such as split mortgages. JSTs are an effective means of cooperation between the ECB and the national supervisors in overseeing banking practices in supervised institutions. This co-operation on all supervisory issues is a core principle of the Single Supervisory Mechanism (SSM).

The Central Bank of Ireland has also informed me that it is providing input into the ECB’s review of warehoused debt - such as that which may be used as part of a mortgage split restructuring - and that this process has yet to be completed. The output from this process will be communicated to the relevant institutions through the regular supervisory channels.

Financial Services Regulation

Ceisteanna (140)

Pearse Doherty

Ceist:

140. Deputy Pearse Doherty asked the Minister for Finance the action he is taking or has taken to ensure returning emigrants are not disadvantaged in areas such as, but not limited to, the provision of motor insurance and unreasonable demands for paperwork that emigrants typically do not possess on the opening of a bank account or applying for a mortgage; and if he will make a statement on the matter. [5705/18]

Freagraí scríofa

Minister for Finance

The issues raised by Deputy are quite distinct therefore I will respond to the insurance part of the question first and then address the bank account and mortgage part of the question.

In relation to the issue of motor insurance for returning emigrants, Recommendation 6 of the Report on the Cost of Motor Insurance aims to address the problems faced by those returning to Ireland.  Pursuant to this recommendation, a protocol has been agreed between the Department and Insurance Ireland under which insurance companies have committed to accepting the driving experience of returning emigrants gained while abroad, when the driver has previous driving experience in Ireland. The guiding principle of the protocol is to ensure that a returning emigrant is not treated any differently to any other driver subject to their ability to demonstrate, and the insurance company to verify, their continued driving experience and the normal acceptance criteria of the company. What this means is that the returning emigrant will not be disadvantaged from spending that time abroad.  Furthermore, under the protocol insurance companies will not distinguish between countries on the basis of which side of the road driving takes place therein.

In addition to the above, insurance companies have agreed to provide relevant and helpful information on their websites to make it easier for consumers to understand the implications of their move abroad from a motor insurance perspective. As part of this exercise they will outline what people need to do under a number of different circumstances depending on the length of time they intend being away from Ireland.  

Insurance Ireland submitted a report on the implementation of this recommendation to the Department of Finance on 22 December 2017.  This report confirmed that Insurance Ireland members have agreed to publish the wording of the agreed protocol on their company websites and any other forms of social media, in addition to providing training for staff who can work through issues with emigrants before they leave, whilst they are out of the country and when they return to Ireland.  The stated intention is “to resolve any issues well before they arise and for the consumer to be aware of the considerations when moving abroad”.  The wording of the agreed protocol is also available on the Insurance Ireland website.  

Insurance Ireland's report also outlines some sample cases which demonstrate how the rolling-out of the protocol has already led to disputed cases being resolved to the benefit of returning emigrants, and provides figures indicating that the number of such cases being processed under the Declined Cases Agreement is decreasing.

If however, a returning emigrant is continuing to have difficulty in obtaining insurance, Insurance Ireland operates a free Insurance Information Service for those who have queries, complaints or difficulties in relation to obtaining insurance. The relevant contact details are: [e-mail] or [e-mail] or 01-6761914.

In relation to opening bank accounts, the Payments Accounts Directive was transposed into Irish law on 18 September 2016. In Ireland, all banks offering payment accounts are required to offer an account with basic features free of charge for at least one year to consumers who do not already have a bank account.

These basic features include:

- An ATM card

- Direct debits

- Ability to pay for goods and services online

It is a matter of good commercial practice that any firm should know its customers.  It is particularly important that a financial institution confirms the identity of their customers because financial institutions often undertake high value transactions on behalf of their customers. In addition, EU directives require that financial institutions ascertain the identities of their customer in order to prevent the use of the financial system for the purpose of money laundering and terrorist financing.

Section 33 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended, sets out the requirements in relation to customer due diligence ('CDD').  Pursuant to section 33, designated persons are required to identify the customer and verify the customer's identity on the basis of documents (whether or not in electronic form) or information, that the designated person has reasonable grounds to believe can be relied upon to confirm the identity of the customer.  The Central Bank does not prescribe what documents or information designated persons should obtain from a customer in order to satisfy the requirements of section 33.  This is a matter for each designated person to determine.

General Principle 2.11 of the Consumer Protection Code 2012 (the CPC) provides that '[a] regulated entity must ensure that in all its dealings with customers and within the context of its authorisation it: without prejudice to the pursuit of its legitimate commercial aims, does not, through its policies, procedures, or working practices, prevent access to basic financial services'.

Guidelines on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing are available on my Department's website at http://www.finance.gov.ie/wp-content/uploads/2017/05/Criminaljustice2012.pdf . Appendix 2 of these guidelines is a non-exhaustive and non-mandatory list of alternative documents that can be used to verify identity in circumstances where a prospective customer cannot, for justifiable reasons, meet the standard identification and verification requirements, or has experienced difficulties in the past when seeking to open accounts. If an individual has difficulty with a bank, I would advise them to examine this list to see how they can meet identification requirements and then approach the financial institution again.

If the consumer is not satisfied with the financial service provider’s decision(s) to refuse the provision of services (including a refusal to provide a bank account or a mortgage), they can make a complaint, using the bank’s internal formal complaints procedure.  If the consumer is not satisfied with the outcome of the complaint, they may wish to refer the matter to the Financial Services and Pensions Ombudsman to have it independently investigated.  Contact details are as follows:

Office of the Financial Services and Pensions Ombudsman, 3rd Floor, Lincoln House, Lincoln Place, Dublin 2 Locall:  1890 88 20 90; Email:  [e-mail];  Website: www.fspo.ie .

Regarding mortgages, there are a number of statutory and regulatory provisions in place governing the provision of such loans to consumer borrowers.  These include the European Union (Consumer Mortgage Credit Agreements) Regulations 2016, the Central Bank Consumer Protection Code and the Central Bank macro-prudential rules for residential mortgage lending.  When taken together these require lenders to, inter alia, carry out a credit worthiness assessment (and for that purpose lenders will be required to gather relevant information about a borrower’s personal circumstances and financial situation such as information on the borrower’s income, expenses, assets, debts, employment status, known future change in circumstances etc.), and to offer mortgage credit only where the results of the assessment indicates that the borrower is likely to be in a position to meet the terms of the proposed credit agreement.  In addition, subject to a limited discretion available to lenders, the maximum amount of residential mortgage credit lenders will be in a position to provide in any individual case will have a regard to the value of the residential property which will act as security for the loan and the income of the borrower(s).  Other than the requirements which apply to the provision of residential mortgage credit generally, it should be noted that there are no Central Bank regulatory provisions which specifically prevent or restrict the ability of a lender to provide mortgage credit to recently returned residents.  However, it should also be noted that, subject to complying with all relevant legal and regulatory requirements, it remains a commercial matter for each lender to determine its overall lending policies and to make its own underwriting decisions on individual loan applications.

Central Bank of Ireland

Ceisteanna (141)

Pearse Doherty

Ceist:

141. Deputy Pearse Doherty asked the Minister for Finance if the Central Bank has received a copy of the Financial Conduct Authority's report into the actions of an organisation (details supplied); and if he will make a statement on the matter. [5719/18]

Freagraí scríofa

Minister for Finance

I am informed by the Central Bank of Ireland that it has an ongoing engagement with the Financial Conduct Authority (FCA) on a range of issues. However, the Central Bank is not in a position to comment on individual cases or the specifics of its engagement with the FCA.