I have been informed by the Central Bank that a key element of their 3 year funding strategy is to increase the overall recovery rate of the cost of regulation from industry, thereby reducing the level of taxpayer subvention.
Since 2015, following a public consultation, the financial services industry has moved from paying approximately half of the costs of financial regulation to paying approximately two-thirds of these costs in 2018. The Central Bank recently published the expected path towards 100% industry funding over the next five years. While the majority of industry funding categories (regardless of size) will move to 100% funding over the period 2020 to 2024, the recovery rate for credit unions will move to 50% for the 2021 levy cycle (payable in 2022) with any further proposed increases subject to public consultation and Ministerial approval.
The impact of the increase in recovery rates is set out in Table 1 which assumes that the baseline cost of regulation is the same as the 2018 cost of regulating the sector.
While in 2018 all other industry funding categories funded a minimum of 65% of the cost of financial regulation, the credit union sector contributed 9% of the cost of regulation (due to the cap on the levy payable by credit unions) and 1.2% of levy income.
Table 1: Estimated impact on levy income from credit unions of increase in recovery rates
Cost of Regulation
|
Cost of Regulation
|
Implied Recovery Rates
|
Levy Income
|
|
€'M
|
|
€'M
|
2018 Actual
|
16.4
|
10%
|
1.7
|
|
Assumed baseline cost of Regulation
|
Ministerial Approved Recovery Rate
|
Projected Levy
|
Additional Levy Income
|
Projected
|
€'M
|
|
€'M
|
€'M
|
2019
|
16.4
|
20%
|
3.3
|
1.6
|
2020
|
16.4
|
35%
|
5.7
|
4.1
|
2021
|
16.4
|
50%
|
8.2
|
6.5
|
2022
|
16.4
|
50%
|
8.2
|
6.5
|
The Central Bank has further informed me that there is no requirement to carry out an impact assessment for the Industry Funding Levy, nor has one been carried out as levies have increased in recent years across all industry sectors other than credit unions. While there is a requirement under legislation for the Minister for Finance to have regard to the financial viability of credit institutions when prescribing certain levies, no such legislative requirement applies to the Central Bank when introducing a levy to fund the cost of regulation.