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Public Affairs

The ILCU proactively engages with Government and public representatives on a number of issues on behalf of its affiliated credit unions. This is to ensure that credit unions are part of any political and legislative agendas affecting the future personal finance landscape on the island of Ireland.

Increasingly, credit unions are the only open, accessible financial service located in the heart of local communities. Credit unions are not simply an alternative to banks. They are a model of community banking that can deliver a much wider range of services and an alternative financial platform. 
 

2022 will see the Minister for Credit Unions publish a draft policy on the future of the credit union movement. The context is that the Irish League of Credit Unions, on behalf of its affiliated credit unions, lobbied successfully for commitments in the Programme for Government to move us on from political platitudes to practical action.
 
The commitments in the Programme for Government include
● Enable the Credit Union movement to grow as a key provider of community banking in the country.
● Review the policy framework within which Credit Unions operate.
● Enable and support the Credit Union movement to grow.
● Support Credit Unions in the expansion of services, to encourage community development
 
There are a number of priority areas which require immediate attention.
 
COMMUNITY BANKING
The commitment for credit unions to become a provider of community banking has wide support. In December 2019, Minister Donohoe published an independent report by Indecon International Economic Consultants on Community Banking in Ireland which stated: “Credit unions are considered to be a ‘community bank’ with an increasing offering of financial products for their members.” The recommendations advocated support for the “Credit Union Market to deliver an Expanded Range of Community Banking Services.”
 
The commitment for credit unions to become a provider of community banking has wide support. The ILCU is advocating for the necessary supports and legislative change from Government to enable credit unions, who are the de facto Community Banks, to develop the full range of banking services to their members in communities across the country. This is about creating an alternative, people owned, financial services pillar.
 
ENABLE AND SUPPORT THE CREDIT UNION MOVEMENT TO GROW
POLICY FRAMEWORK REVIEW
Without legislative change, little will change for credit unions. The ILCU believes that there are three essential things which must be fixed for credit unions to work better
 

  • Credit unions must be effectively enabled, as distinct from being nominally permitted, to deliver additional services across the board to really become a community banking platform.
  • Notwithstanding the proposal for Lending in Common,, the community basis of credit unions, underpinned by the Common Bond, must be a pillar of policy and regulation.
  • There must be a legislative refit of the institutional relationship between the Minister and the Central Bank, that fully upholds the regulatory independence of the bank, while enabling the Minister to set out key principles and objectives, including the power to set minimum reserves, which the Regulator must take account of
 
POLICY FRAMEWORK REVIEW
 
The ILCU, in our submission to the Department of Finance on the Policy Framework Review, outlined proposals to strengthen the long term viability of credit unions. These include
 
  • Lending in Common - where one credit union could introduce a member to another for the purposes of applying for a loan from that credit union. This may occur if the initial credit union did not have the capacity or capability of providing that loan. The proposal also suggests that one or more credit unions could share a particular lending opportunity.
 
  • Business Model Development Taskforce - The ILCU supports the establishment of a Business Model Development taskforce solely to assist co-ordination of development of new products and services at the origination stage to assist in avoiding fragmentation.
 
  • Modernise additional services - The ILCU proposes the modernisation of the Additional Services regime in the Credit Union Act to reflect the current financial services landscape, to recognise the regulated nature of some additional services, and to streamline the approval process required. This will assist credit unions in providing the services of a Community Bank.
 
  • Policy Committee - the ILCU proposes the establishment of a Regulatory and Legislative Credit Union Policy Committee, preferably on a statutory footing, to discuss potential regulatory and legislative changes in advance of the relevant authority commencing a public consultation.
 
 
CAPITAL REQUIREMENTS
The Regulatory Reserve ratio of 10% is out of step with the risk profile of credit unions assets. Unbelievably, a 10% regulatory capital requirement is applied to an Irish Government Bond and to an unsecured loan to a credit union member
 
Our ILCU “Credit Unions in a Time of Change”, of July 2021, shows that regulatory capital requirements for credit unions are significantly higher than ROI banks and credit unions elsewhere. We are disadvantaged in the financial services market and undermined in delivering competitive pricing of loans, and in the development of new services.
 
Credit unions are trusted savings institutions but Regulatory capital requirements mean an additional capital cost to us holding savings for members. For every €1,000 of savings received, a credit union must put aside a capital requirement of 10%, i.e. €100 in this example.
 
The ILCU advocates a risk weighted approach to capital/reserves for credit unions and proposes that the power to set minimum reserves be withdrawn from the regulator and assigned to the Minister for Finance or another Government department or agency.
 
LEVIES
The ILCU successfully campaigned for the reductions in the Credit Institutions Resolution Fund Levy (CRIF Levy). Reductions mean that credit unions will pay €4.2m for the CIRF levy in 2022 versus €8.6m in 2019.
 
However, the Central Bank is planning, and has Ministerial approval to increase the Industry Funding Levy in stages up to 50% (of Industry Funding costs) by 2022. This levy costs our affiliated credit unions approximately €1.5m per annum, and the increase proposed would cost approximately €5.7m. This is a tax on social capital and a levy on volunteers.
 
The ILCU strongly advocates that the increase in the Industry Funding Levy be reversed. On the Credit Union Stabilisation Levy, the reduction by the Minister means credit unions will pay €2.7m less in 2021 than they paid in 2020. Instead of having to pay €3m next year, they will only pay €300,000. While welcome, the ILCU position remains that there should be no such levies and amounts previously collected, but not spent, should be refunded. It hasn’t fulfilled its function and the ILCU has its’ own SPS fund.
 
In relation to the Deposit Guarantee Scheme (DGS), costing credit unions over €13m per annum, the ILCU believes that the movement’s schemes, such as the League’s Savings Protection Scheme (SPS), should be taken into account when levies are being set.
 
Support Material
Credit union personnel can access support material to assist their local lobbying activities on the affiliate area of the website.
 

Across Northern Ireland the credit union movement has been extraordinarily successful but we cannot afford to stand still if we are to rise to the many challenges ahead.
 
We can do more to help grow the economies of all the communities that we serve, we can roll out new financial services, for individuals, small businesses and community organisations.
 
We want to build on this so that, in the next 60 years, we can improve access to community financial services and help power the economy. Crucially we’d like to be able to invest some of our surplus assets to address social needs.
 
We are committed to working in partnership with government and all our other stakeholders to rise to the challenges thrown up by these rapidly changing times to ensure that credit unions remain fit for purpose for the next 60 years and beyond.
 
We want to build sustainability within our movement and to play a full part in future economic growth. These are areas where we would like you to pledge your support, and where we pledge ours to you.
 
COMMUNITY WEALTH BUILDING

  • Support for investment and lending for social purposes/partnerships with local authorities and other stakeholders, helping to address pressing social needs.
  • Filling the void left behind by banks and improving access to community financial services.
  • We will be playing our part to support economic recovery after Covid-19 and are offering our expertise to those charged with implementing the government recovery plan.

 
MAKING CREDIT UNIONS FIT FOR PURPOSE FOR THE NEXT 60 YEARS

  • Updating legislation and regulatory rules, to reflect a changing landscape and enable us to fulfil our mission in a new age, refreshing and renewing our offerings to meet new and emerging demands on our services.
  • Fairer regulatory capital rule which reflects risk, allowing us to invest more and to support community wealth-building.
  • Support for new digital platforms and services, to reflect changing consumer needs.

 
FINANCIAL WELLBEING

  • Combating financial exclusion and helping individuals manage their finances.
  • Continuing to offer fair and affordable credit to all.
  • Building payroll partnerships with the public and private sectors.
  • Building Financial Literacy and Education.

 
Support Material
Credit union personnel can access support material to assist their local lobbying activities on the affiliate area of the website.