In this chapter we explore the role of the property sector in the crisis. We examine the evidence of developers and valuers in relation to their processes and behaviours, and look at interactions between the property sector and financial institutions, political parties and government. Finally, we briefly examine relationships between the property sector and the media.
Developers played a major role in the economy during the 1990s and 2000s. Property prices during the period skyrocketed, and construction-related output accounted for 23% of GDP at the peak of the boom in 2006, as compared with 12% today.1 In 2007 the construction sector accounted directly for over 270,000 jobs2 , which represented over 13% of all those in employment in the country3 and an increase of over 100,000 in just seven years.4
As the property sector grew, more and more developers with access to cheap money entered the market. The sector began to crowd out other sectors of the economy, through a combination of increased speculative construction and rapidly rising property prices.
A very significant proportion of the sector was concentrated in a small number of developers; of the €74.4 billion worth of loans taken over by NAMA, €33.7 billion was concentrated in only 29 commercial borrowers.5
When the bubble burst, the sector was left in a sundered state, its most visually impactful legacy being ‘Ghost Estates’ across the country.6
During the boom, there was an excessive reliance on property-related activity, income and taxes. In her evidence to the Inquiry, Mary Harney, former Tánaiste, said that:
“…spending was allowed to increase too rapidly as the economy overheated with continued growth and the exchequer finances becoming over-dependent on construction.”7
The Joint Committee received evidence from nine of the country’s largest developers and property investors, four of whom gave evidence in public hearing and five by written statement.
During the boom, the business models of developers differed greatly depending on the nature and scale of the business.
As evidenced in public hearings and from written witness statements, some of the more established, long-standing individuals and firms in the industry had robust and easily adaptable business strategies. The evidence indicates that, while they tended to diversify activity and investment by asset type, geography and income stream within Ireland, some developers diversified by investing in the same asset type in different regions outside of Ireland. The evidence suggests that the business was supported by highly qualified professionals, such as surveyors, economists and accountants, to assist with risk assessments and business planning.8 The evidence further suggests that they invested time and money preparing to bid on assets or submitting proposals to financial institutions.9
However, as will be seen later in the report, there was an increasing use of drive-by valuations and computer-generated valuations while other developers made bids on so-called “trophy chasing.”10
When signs of a slowdown in the Irish property market were becoming evident around the mid-2000s, some developers began to deleverage by, for example, selling their land and development assets while, at the same time, retaining income-creating assets to generate cash flow. Other developers increased their concentration and bought at the height of the boom.11 However, the sheer scale and suddenness of the downturn caught out even the most experienced developers. The property market disintegrated and the loans of most developers who had total exposures over €20 million were transferred into NAMA.12
In the lead up to the crisis, many developers had become completely reliant on bank debt to fund their developments. Brendan McDonagh noted that “the majority of debtors were, in effect, sole traders and they were totally reliant on bank debt.”13 Sean Mulryan and Michael O’Flynn both said that there should be less reliance on bank funding in the future and more emphasis placed on equity from professional investors.14
It was not uncommon for 100% financing to be advanced, or when developers’ equity was required, for it to be made up by paper equity;15 each case would ultimately result in the bank taking all of the risk.16 In his evidence to the Joint Committee, Eugene Sheehy advised that while it was not part of AIB’s business model, this method of increasing the bank’s exposure by releasing funds on the basis of an uplift in the valuation of another secured asset did happen and it would have been better if the lending structure for property in Ireland had included more private equity.17
In his evidence to the Joint Committee, Sean Mulryan said that one weakness in the Ballymore Group’s business model was its overwhelming dependency on Irish financial institutions. Having had long-standing relationships and built up a level of trust with a particular financial institution, some developers were slow to diversify and spread the risk across international banks.18
Evidence to the Joint Committee suggests, however, that some large developers sought to avail of loans from a number of financial institutions. Gerard Gannon advised that it was a way of introducing an element of competition and therefore of reducing costs.19 Sean Mulryan gave evidence that spreading the risks across banks would have allowed the Ballymore Group to mitigate its level of dependence or overreliance on any one financial institution. Despite that, Ballymore Group borrowed 50% of their loans from one financial institution as a result of the long-standing relationship they had built up over twenty years.20
A syndicated loan was another form of multi-bank lending, but normally instigated by the bank to mitigate risk arising from a large development and to manage the concentration limits set by the regulatory authorities. However, the Joint Committee heard evidence that property syndicated loans were not common in the Irish market.21 Eugene Sheehy stated in his statement to the Joint Committee that “arising from the lack of syndicated lending we had a poor sight of how leveraged the sector had become.”22
In contrast, John Moran of Jones Lang La Salle gave evidence that syndicated loans were relatively common. He said that in the peak year of 2006, “Out of the total of 121 [commercial property transactions], one could probably argue that 40 or 50 were syndicated transactions.”23
Gerard Barrett commented that his company, Edward Holdings, was required to provide up-to-date positions to each of their banks vis-à-vis their other banks.24 This was also reiterated by Tom Browne, Head of Lending Ireland, Anglo, in his evidence to the Joint Committee. He stated: “…with our bigger clients, the top ten, top 20. We would have … in the latter years been looking at … their total banking obligations across all their banks.”25
Pat McArdle, Group Chief Economist in Ulster Bank, told the Joint Committee: “It was only when the loans were transferred to NAMA in 2010 that it was revealed that the big developers had multiple exposures to the different banks.”26
A Department of Finance summary of the initial business plans of the six covered financial institutions undertaken in late 2008 commented that Anglo’s lending model was “driven off the back of established relationships with net worth individuals predominantly in the property sector.”27
According to Frank Daly of NAMA, a relationship was the predominant driver of a lending decision in some instances, rather than an impartial assessment of the viability of the business proposal.28
Brendan McDonagh of NAMA also gave evidence that:
“… €34 billion of the €74 billion that came to NAMA was borrowed by 29 people … and while it was spread around by banks, there was certainly a concentration of lending around one institution. So I think the issue really comes down to the fact that … relationship lending was a big part of it.”29
In some cases, they became the developer’s business partner in a joint venture.
Michael Fingleton, former Chief Executive, INBS, referred in evidence to joint ventures between INBS and Ballymore Properties, the first such venture having been in 1992:
“In 1992 the Society acquired 70 acres of land in Lucan with planning for 650 houses for £1.4 million. It then entered a joint venture with Ballymore Properties for the development of these lands, which was successfully and profitably completed.”30
Sean Mulryan said that with this joint venture, the project was “100% debt funded” by INBS, who would “charge an interest rate of about 2.5% over the Libor and …for … putting up all of the capital, they would take 50% of the profits.”31
Michael Fingleton said that INBS:
“continued to provide finance for such ventures [as with Ballymore] right through the 90’s and expanded into the UK London market with some of our own customers and later UK-based customers.”32
In joint ventures with financial institutions other than INBS, Sean Mulryan said in his evidence that the financial institutions’ capital investments varied: “70%, 80%.”33
In his evidence to the Joint Committee, Michael O’ Flynn, O’ Flynn Group, stated that with regard to property acquisitions:
“a mix of our own cash and bank borrowings was generally applied with the exception of joint venture arrangements where a lender sought a much higher return based on profit share. In such cases funding was provided by the lender and time, skills and expertise were provided by us and profits were shared.”34
The IMF observed in 2012 that “rapidly rising property prices was a key factor that drove high fixed investment in commercial and residential property.”35 On the commercial side specifically, the Department of Finance recognised as far back as 2003 that commercial property prices presented “…a potential source of vulnerability for the Irish banking system.”36 These observations are supported strongly by the body of evidence presented to the Joint Committee.
Taken as a whole, the Irish bank sector was excessively and disproportionally exposed to commercial property lending by 2008.
AIB’s business became increasingly dependent over time on commercial lending. Eugene Sheehy acknowledged in evidence that at the peak of the boom the bank had “650 customers who had property and construction loans of over €1 million.”37 In the case of Bank of Ireland, it was acknowledged that:
“…while property lending as a proportion of the Group’s balance sheet was not considered disproportionate; the actual quantum of property lending was too large…”38
By mid-2008, Anglo had a “sizable degree of exposure” to the commercial investment property market39 and INBS sought to fill what was perceived as a void “…by expanding its activity in the commercial lending market.”40
EBS – originally a building society for funding of mortgages for teachers – had moved into this form of lending, with commercial property loans having grown from €460 million in 2001 to €2.3 billion by 2008.41
In the case of IL&P/PTSB, commercial lending expanded as well such that, by 2008, it had grown to almost €2 billion.42
Ulster Bank also had an exposure to commercial lending. In his evidence to the Joint Committee, Robert Gallagher, CEO Corporate Markets Division, said:
“On my arrival into the business [in 2004], Ulster Bank already had a well developed and long-standing property division. The commercial property loan book was then approximately 60% of the corporate loan book. On joining, a key objective of mine was to diversify the portfolio.”43
The Construction Industry Federation (CIF) - the main representative body for the construction industry in Ireland - played a major role in lobbying the Government on taxation policy, public capital spending and other issues affecting the construction sector. Its responsibility was primarily to represent the needs of members.44
90%47 was spent on services, such as health and safety expertise, industrial relations & employment advice, advice on payment disputes and planning & development advice for their members. When asked by the Joint Committee if the CIF had undertaken or commissioned research into the construction or property sector in 2007, Liam Kelleher responded: “The short answer is no, to the best of my knowledge.”48 The CIF relied heavily on the research of others, which was taken at face value; Liam Kelleher also told the Joint Committee that he wished he had paid more attention to contrarian views.49 The CIF continued to actively pursue property-based tax incentives and income tax incentives, even in light of the evidence that house prices were beginning to fall.50
From the late 1990s and well into the 2000s, a large variety of tax incentives were introduced which greatly benefitted developers. From 2000 to 2007, developers enjoyed a reduced tax rate on the sale of land for development purposes, which was halved from 40% to 20% by the former Minister for Finance, Charlie McCreevy.51
Over the ten year period from 1997 to 2007, Fianna Fáil received an average of €54,600 and the Progressive Democrats received an average of €8,900 annually in disclosed donations from the property and construction sector. Other parties did not disclose any donations from property interests.52 In the opinion of Elaine Byrne “…the property barons of the 1990s and 2000s had replaced the beef barons of the 1980s.”53
We raised the issue of personal contacts between larger developers and senior politicians. Several politicians said that they were not influenced by developers on policy matters. We learned of some personal friendships between politicians and developers.54 In response to a question on the issue of relationships between developers and politicians, Elaine Byrne said:
“often … it is indirect and is a case of doing someone a favour and thereafter, down along the line, that person will return the favour in an indistinct way. Were one intent on committing corruption, one would no longer be doing it the old-fashioned way. I mean giving money for a favour committed because these things can be traced. What the Moriarty tribunal in particular exposed was benefits in kind through different land transactions that may have arisen. Decisions were made and perhaps down along the line, certain benefits were conferred on individuals. Corruption is not black and white and is not direct. It is indirect and these relationships are very difficult to examine.”55
The journalist, Simon Carswell, said:
“I would characterise the relationship between the major players in the property sector, the construction industry, government, certain elected representatives and the banks, as well as the relationship between the Government, the banks and the financial supervisory authorities, as extremely cosy in the period leading up to the 2008 banking crash. To take a phrase from former Finnish civil servant Peter Nyberg’s thorough report on the causes of the banking crisis, the various players, including politicians, builders, bankers and regulators, displayed 'behaviour exhibiting bandwagon effects both between institutions (herding) and within them (groupthink).' Nothing I came across in my research would contradict that statement.”56
He went on to say:
“These relationships appear to have been too cosy to have allowed any one of these collective groups, be it banks, government, builders or regulators, to shout stop and offer the kind of critical dissent that might have changed the behaviour of all and the direction in which the country was heading. If one of these groups had had the courage to put its head above the parapet, I believe there might not have been the crisis we had or at least it might not have been as severe as it was. For these parties, it was too comfortable and self-serving for some to stay in the crowd and stick with the consensus, particularly when so many were making so much money. The result was that contrarians were ridiculed, silenced or ignored to ensure the credit fuelled boom continued for years as their past warnings did not come true. These cosy relationships would prove extremely costly. While the cost of the banking bailout to the Irish people stands at €64 billion, excluding recoveries coming from the sale of shares in the banks or better than expected returns from the National Asset Management Agency, it is worth stressing that the overall losses and capital wiped out by the crash amount to far in excess of this sum. The losses on loans, mostly to the property sector, across all of the banks in Ireland came to well in excess of €100 billion, including tens of billions of euro covered by the UK Treasury. This is sometimes forgotten.”57
A number of economic factors led to a considerable increase in property values from the early 2000s. As the boom gathered pace, property valuations gained greater importance and there was a major growth in large multinational and local property service advisers.
A valuer is an individual who appraises property, land and developments in order to reach an opinion of the market value of the asset. In its simplest form, this is an estimate of the amount for which an asset should sell on the valuation date between a willing buyer and a willing seller in an arm’s length transaction in which each of the parties acted knowledgeably, prudently and without compulsion and after the property had been properly marketed.58
Witnesses from INBS and Ulster Bank gave evidence that they established valuer panels and sought independent valuations to underpin their credit decisions.59 Donal Forde, former Managing Director, AIB, said that “…the seeking of an independent valuation would be confirmatory more than anything else.”60
Richard Burrows, former Governor, BOI, told the Joint Committee, “…it always is a subjective process, except when the loans were issued, there was a free market operating. Properties were being bought and sold, landbanks were being bought and sold, there was a determination of what market value was.”61
There were two professional bodies representing valuers in Ireland during the boom years: the Institute of Professional Auctioneers and Valuers (IPAV) and the Irish Auctioneers and Valuers Institute (IAVI), the latter having since merged with the Society of Chartered Surveyors (SCS) to form the Society of Chartered Surveyors Ireland (SCSI).
In evidence, Patrick Davitt, CEO, IPAV, stated that there were no national valuation standards for valuers in Ireland prior to the property crash and that remains the position today.62 Thus the professional bodies like IPAV were left with the role of self-regulating their members by, for example, ensuring that appropriate qualifications were held and continuous professional development (CPD) was up to date.63
Ireland also had no national property register. According to Marie Hunt, CBRE, a national property register would have enabled valuers “to track the market better” – for example in terms of quantifying the size of the commercial market.64 The need for a national register of commercial property prices in Ireland was also reiterated by John Moran, Managing Director, Jones Lang LaSalle Ltd (JLL), in his evidence.65
Features of the valuation model included a methodology to arrive at the valuation figure and the standards used in writing the valuation report, such as the financial institution’s instruction to the valuer, the basis and purpose of the valuation, the valuation date, a property description, the legal context, commentary on the market for the property, the market value, the methodology and analysis involved, any assumptions made, any limitations on the report, and the Valuation Standards applied.69
Methodologies depended on a number of assumptions and judgements70 and the very nature of a value being attributed on a given day left it open to variance as circumstances changed from day to day. According to Patrick Davitt, “…the open market valuation is going to be … a moving figure at any time…”71
Even in the case of large developments, valuations were not done in all cases. Gerard Gannon of Gannon Homes, which had debts of €214 million in respect of Irish assets and £22 million in respect of UK assets at 30 September 2008, gave evidence that “it was not our policy to engage third party valuers to value my property assets either at time of acquisition or during the development phase”
, instead leaving it to the relevant financial institution to engage valuers as required.72
On differences between the Irish banks and non-Irish banks, three of the developer witnesses, Sean Mulryan, Derek Quinlan and Michael O’Flynn, did not observe any difference in the level of rigour applied to valuation requirements for large loans.73
More widely, however, the demand for asset valuations increased significantly as the property boom took hold and reliance on informal valuation standards, such as ‘desktop’ and ‘drive-by’ valuations, became more prevalent. These did not involve any physical inspection of the property, but were a limited (and sometimes fully automated or computer generated) process of estimating value. A Central Bank review of financial institutions found that many used these informal valuations as if they were formal valuations.74 A number of developers gave evidence that they continued to rely on professional valuations.
Valuations exert significant impact on a financial institution’s credit risk management. As mitigation against risk, it is imperative that the valuation process is robust and that the value attributed to the underlying assets can be relied upon when fully assessing the risk of a credit decision or the ongoing management of the loan. For that reason a reliable valuation document is central to the credit risk decision.75 Patrick Davitt, IPAV reiterated this in his evidence to the Joint Committee:
“…The valuation figure derived becomes the critical part of the valuation, as it helps banks and other financial institutions to decide the worthiness of the risk it’s going to lend on.”76
Valuations were not always carried out for assets that were indirectly securing a loan. For example, Kieran Bennett, former Group Chief Credit Officer for AIB, gave evidence that “in most cases, an independent valuation would only be sought for assets directly securing a project. Otherwise AIB would have relied on a Statement of Net Worth from the borrower.”77
Around the mid-2000s, there were a number of commentators and analysts with contrarian views who raised the possibility of a collapse. Amongst them was Morgan Kelly, who accurately predicted a potential 40-60% fall in real house prices over an 8 year period, in a feature in the ESRI’s Quarterly Economic Commentary during the summer of 2007.78
Shortly afterwards in October of that year, the ECOFIN Council warned that in Ireland’s case, “…more work is needed on standards to ensure reliable valuation of assets, particularly of those assets where markets are potentially illiquid in time of stress…”79
Around that time and even before then, developers began to see the escalation of property prices in Ireland as a challenge; by then, development prices had gone into a state of complete disequilibrium. In the experience of Sean Mulryan, assets bought in Dublin’s Docklands were up to five times more expensive than assets bought in the equally strong London Docklands market during the period.80 The PwC Project Atlas Report suggested: “The acquisition of large ‘trophy’ development sites has put some major developers/property investors under significant cash flow pressure.”81
According to Sean Mulryan, owning a prestigious ‘trophy’ site became a measure of success.82 There are many well-publicised instances of such sites having changed hands for multiples of what they had been worth a few months previously, often purchased without planning permission for re-development.
Sean Mulryan also provided an indication in evidence of the time and resources spent relating to preparing for a number of high profile projects, such as the Irish Glass Bottle site and the Jurys and Burlington Hotel sites in Dublin. In those cases, Ballymore subsequently learned that its bids had been as much as 35% off the pace at the time.83 The highest price Ballymore were willing to offer for the Irish Glass Bottle site was €140 million; it was subsequently sold for €412 million in 2006.84 In 2010 its long term economic value was estimated to be in the region of €62.5 million.85
Some developers reacted to increased asset prices by diversifying into foreign markets, such as London and Eastern Europe.86 In turn, Ireland’s property market experienced a slowdown in property turnover culminating in house prices falling from early 2007. A Central Bank review indicated that financial institutions’ over-reliance on out-of-date professional valuations and weak internal valuation methodologies did not warn them in time of the ever increasing fall in property values which would in turn impact on the recoverability of their loans.87
In late 2008, after the Government Guarantee had been issued, PwC were engaged to review the loan books of each of the covered institutions, known as the ‘Project Atlas’ report. PwC instructed Jones Lang LaSalle (JLL) to carry out an analysis of the financial institutions’ underlying valuations. JLL uncovered many issues of concern. The following small sample88 of valuation findings illustrates those concerns forcefully:
a) a site was independently valued at €3 million in March 2008 on the assumption that the zoning status could be amended from industrial/commercial to retail. That did not transpire and JLL gave a ‘normalised value’ of only €1.85 million a few months later in November 2008.89
b) an internal memo in November 2008, with an independent summary figure attached, valued a 6 acre site (with mixed-use planning permission) at €140 million. JLL suggested the approach was not appropriate and gave a ‘normalised value’ of just €25 million.90
c) a 97 acre site independently valued at €150 million in October 2005 was still being relied upon in late 2008. JLL gave it a ‘normalised value’ of €55 million in November 2008.91
d) a development site and work in progress was internally valued by a financial institution in September 2008 at €429 million. JLL gave it a ‘normalised value’ of €325 million in November 2008 and advised in their report that the financial institution's methodology for valuing the asset was not market practice.92
However, with the property market experiencing a number of adjustments which were unprecedented in their speed and severity, and exacerbated by the sudden effective withdrawal of credit from the property market,93 JLL also found that in a number of cases the market value of an asset had fallen and an updated valuation was provided.94
The true extent of the fall in value of underlying collateral was not realised until loan tranches began to transfer out of the financial institutions to NAMA in 2010. That culminated in an overall discount of 57% being applied.
As part of the Context Phase, the Joint Committee received evidence from academic commentators and media professionals under the theme of the role of the media during the property boom.
Harry Browne, a lecturer in journalism in the School of Media of Dublin Institute of Technology, gave evidence that:
“Print and broadcast media in Ireland played a difficult-to-measure but almost certainly significant role in the inflation of the property bubble and the legitimisation of risky behaviour by the financial services sector in the lead up to the crisis of 2007 and 2008.”95
He also said that glossy magazines, property and lifestyle sections were significant sources of income:
“Those supplements were, after all, paying the bills. When The Irish Times Limited infamously paid €50 million for myhome.ie in 2006, it appeared to confirm the company’s dedication to what increasingly looked like its core business – the advertising of property sales.”96
Property advertising was a considerable source of income for some media organisations. Maeve Donovan, former managing director, “The Irish Times”, gave evidence that property revenue for that newspaper ranged from €10 million in 2002 to €22 million in 2006;97 at its peak, this accounted for 17% of the newspaper’s total revenue from all sources.98 The Joint Committee also heard evidence that the equivalent figures for the “Irish Examiner” and Independent News and Media were 7%99 and 14%100 respectively.
The evidence from the academic witnesses was that, as a result of the significant revenue streams that came from relevant sources, it was necessary for media outlets to (at least unconsciously) protect these sources. Harry Browne gave evidence that:
“Much of the mainstream media seems to me to be very conflicted because of their reliance on real-estate and recruitment advertising. That doesn’t mean reporters consciously avoid writing bad news stories, but it’s hard to run against the tide when everyone is getting rich.”101
On the other hand, he also said:
“… journalists and the organisations that employ them do also have an interest in producing strong stories that challenge conventional thinking, and afflict the powerful.”102
Tim Vaughan of the “Irish Examiner” gave evidence that property advertising was an important source of revenue but that in the case of that newspaper “…advertisers did not seek to influence the editorial policy of the newspaper.”103
It is clear, however, that property advertisers did attempt to put pressure on “The Irish Times”. Geraldine Kennedy, former Editor, gave evidence that she was aware that many telephone calls were made to her colleague Maeve Donovan, former Managing Director of the newspaper, by the property sector about coverage in not just the property supplement, but the main newspaper also.104 As Editor, she was aware of statements made by some in the property sector that “The Irish Times” would never get an advertisement again after the publication of an article by Professor Morgan Kelly which predicted a drop in property prices.105
Media outlets only occasionally featured contrarian views that might undermine the property sector. For instance, Geraldine Kennedy gave evidence that “The Irish Times” was:
“…the only newspaper to publish the article by Morgan Kelly, professor of economics in University College Dublin, predicting there would be a property crash with prices falling by between 40% and 60%.”106
Newspaper editors said in their evidence, however, that their editorial policy had not been influenced.107 Gerry O’Regan, former Editor of the “Irish Independent”, expressed his views that there was “…no hidden agenda in the Irish Independent to try to artificially bolster the property market for the period under review.”108
4. In 2000, there were 166,300 engaged in the construction industry, which represented just under 10% of the total number in employment and close to 100,000 fewer than in 2007. (Source: CSO, QNHS).
8. Sean Mulryan, Developer, Ballymore Group, statement, SMU00001-005/012; Michael O’Flynn, Developer, O’Flynn Group, statement, MOF00006-009; Joe O’Reilly, Developer, Castlethorn Construction and Chartered Land Group, statement, JOR00001-006
9. Sean Mulryan, Developer, Ballymore Group, transcript, INQ00119-004; Michael O’Flynn, Developer, O’Flynn Group, transcript,
INQ00121-003; Joe O’Reilly, Developer, Castlethorn Construction and Chartered Land Group, transcript, INQ00126-007/029; John Ronan, Developer, RGRE, statement, JRO00002-005/006; Michael O’Flynn, Developer, O’Flynn Group, statement, MOF00006-008/009; Joe O’Reilly, Developer, Castlethorn Construction and Chartered Land Group, statement, JOR00001-003/004; Sean Mulryan, Developer, Ballymore Group, statement, SMU00001-005/009; Gerard Gannon, Developer, Gannon Homes, statement, GGA00001-003/004; Gerard Barrett, Developer, Edward Holdings, statement, GBA00001-004 to 007
13. Brendan McDonagh, CEO, NAMA, transcript, PUB00331-011; Derek Quinlan, Developer, Quinlan Private, transcript, INQ00092-007 also says that “…there was definitely, in some instances, you know, too much leverage being given…” by way of bank debt.
15. A charge over the unrealised equity position in another development.
42. IL&P Group Annual Report 2008, page 13.
50. CIF Pre-Budget 2009 Submission, 30th September 2008, DOT00717; CIF Submission to the Department of the Taoiseach on Ireland’s Economic Recovery, 23rd January 2009, DOT00718; CIF Pre-Mini Budget 2009 Submission, 24th March 2009, DOT00721
58. Market Value as defined in Article 4, par 76 of EU Regulation No. 575/2013.
59. Michael Fingleton, former CEO, INBS, statement, MFI00001-018; Robert Gallagher, Chief Executive, Corporate Markets Division, UB, transcript, INQ00088-040; Cormac McCarthy, Group Chief Executive & Director, UB, transcript, INQ00086-051
66. The Royal Institution of Chartered Surveyors (RICS) has published valuation standards in the UK known as ‘Red Book’ since 1974.
67. The European Group of Valuers Associations (TEGoVA) has published the ‘Blue Book’ valuation standards since the early 1980s.
73. Sean Mulryan, Developer, Ballymore Group, transcript, INQ00119-013; Derek Quinlan, Property Investor, Quinlan Private, transcript, INQ00092-037; Michael O’Flynn, Developer, O’Flynn Group, transcript, INQ00121-035; Joe O’Reilly, Developer, Castlethorn Construction and Chartered Land Group, transcript, INQ00126-026