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Back to Appendix 10: European Responses to the Crisis: Budgetary, Fiscal and Banking Changes
As part of our Terms of Reference, the Joint Committee heard evidence on the extent of changes in the Central Bank and the Department of Finance since the crisis. This evidence was primarily based on self-assessment by witnesses on behalf of those two institutions and only a limited number of external witnesses gave evidence on this issue.
Due to the limited number of witnesses, we did not have sufficient external, balancing evidence on which to base conclusions or findings. We have, however, decided to include a narrative summary of the evidence which we heard, which may be of public interest, in conjunction with our publication of witness statements and transcripts.
One of the reports previously prepared on the crisis is the report entitled “A Preliminary Report on the Sources of Ireland’s Banking Crisis”(the“Regling and Watson Report”). The Regling and Watson Report identifies failures in corporate governance as one of the primary causes of the financial crisis: “Errors of judgement in bank management and governance contributed centrally to Ireland’s financial crisis.”1
Patrick Honohan was also critical, particularly in respect of the absence of effective codes for both corporate and internal governance or fitness and probity reviews.2
Alan Gray, former board member of the Central Bank, observed that: “Regulatory systems did not cause the crisis, but did not prevent the practices which led to the crisis.”3
In response to such failings, a concerted effort was made to strengthen the corporate governance framework for financial institutions.
In June 2010, the European Commission issued a Green Paper on corporate governance in financial institutions and remuneration policies.4 The Commission noted that, because of the systemic nature of many of the main players in the financial services sector, corporate governance requirements should take into account the interests of all stakeholders including depositors, savers and policy holders, as well as the stability of the financial system.
In the Irish context, the Central Bank issued a paper on 21 June 2010 on a new approach to banking supervision.5 This paper proposed new principles guiding governance of financial institutions, fitness and probity requirements for directors and senior management requirements and remuneration standards. Following on from the publication of this paper, the Central Bank issued the Corporate Governance Code for Credit Institutions in November 2010 (the Code).6
The Code set out minimum statutory requirements on how banks should organise their governance. It contained provisions on the membership of the board of directors, the role and responsibilities of the Chairman and other directors and the operation of various board committees. The Code provided that it was to apply to existing directors and boards from 1 January 2011.7 The largest banks became subject to additional requirements under the Code, reflecting their significance from a risk perspective8 .
EU and Irish law now require that the directors and senior managers of financial institutions must meet prescribed standards of competence and probity – generally referred to as the “fit and proper” standards.9 These standards primarily fulfil a “gatekeeper” role in ensuring that key positions at board and senior management level within financial institutions are filled by people of competence and integrity.10
In May 2006, the Irish Financial Regulator issued“Fit and Proper Requirements ”which became effective from 1 January 2007, but only for new office-holders or those changing position (“the Requirements”).11 The “fit and proper test” in the Requirements provided for the completion of an “Individual Questionnaire (IQ)” by applicants.
On 1 December 2011, Matthew Elderfield introduced new statutory regulations and standards of fitness and probity, which set the requirements for entry into and removal from senior positions within entities regulated by the Central Bank (for existing and new office holders).12
Under the Central Bank Reform Act 2010 (the 2010 Act)13 , the Central Bank received enhanced new statutory powers to veto senior appointments (CEO, Directors, Company Secretary and other Controlled Functions). The 2010 Act also provided for the suspension or removal individuals from senior positions across the financial services sector. The 2010 Act further provided that, where appropriate, the Central Bank could also prohibit individuals from working in senior industry positions entirely.
Notably, the Central Bank also commissioned reviews of governance and risk management standards at the two largest banks, AIB and BOI.14
Cyril Roux, Deputy Governor of the Central Bank said: “The EBA conducted a review of our fitness and probity performance in 2014 and out of all the countries in the EU, only eight were fully compliant and were at the highest standard of fitness and probity surveillance, and Ireland was part of that. Now, I think we can get some comfort on this bit.”15
According to a paper prepared by the Central Bank,16 the 2010 Act was the first of a three stage legislative process to create a new fully-integrated structure for financial regulation consistent with best practice in the EU and internationally. The 2010 Act was also intended to enhance the powers and functions of the Central Bank and to consolidate existing banking-related legislation.
The key objective of the 2010 Act was the establishment of a new single fully-integrated institution to be known as the Central Bank of Ireland with a unitary board, known as the Central Bank Commission, to be chaired by the Central Bank Governor. The stated purpose of the new structure was to ensure that the domestic regulatory framework for financial services would meet government objectives for:
The 2010 Act also:
In the Paper entitled “Banking Supervision: Our New Approach” , the Central Bank proposed a transformation in its approach to banking supervision and sought to institutionalise the lessons learnt from the financial crisis.18 The Central Bank intended to implement a more “intrusive” approach to the prudential supervision of banks. In broad terms, the changes outlined by the Central Bank were:
Having reviewed the evidence furnished to the Inquiry in relation to this period, it appears that, following the enactment of the 2010 Act, changes did take place at the Central Bank Commission (the Central Bank board) level as well as at the most senior level of the Central Bank (Director level). Examples of the more significant organisational changes were as follows:
Patrick Honohan, the tenth Governor of the Central Bank of Ireland, was appointed in September 2009. In a departure from the profile of his predecessors who, for more than 60 years, had been senior civil servants drawn from the Department of Finance, Patrick Honohan was Professor of International Financial Economics and Development at Trinity College Dublin and spent almost a decade at the World Bank, where he was Senior Advisor on financial sector policy.
Matthew Elderfield, formerly the CEO of the Bermuda Monetary Authority, took up his position as Head of Financial Regulation in the new Central Bank of Ireland in January 2010 and became Deputy Governor in 2011.
The main organisational changes provided for under the Central Bank Paper were as follows:
The changes introduced under the 2010 Act sought to address the weaknesses identified in the Honohan Report21 through:
The five principal change categories provided for in the Central Bank Paper were:
From 2010, the Central Bank’s stated approach to regulating financial services providers was based on a model of intrusive risk-based supervision underpinned by a credible threat of enforcement.23 The Central Bank publicly stated that it intended to focus on the financial institutions which are most significant and on the risks that pose the greatest threat to financial stability and consumers.24
In November 2011, the Central Bank launched PRISM (Probability Risk and Impact SysteM), which was designed to enhance the Central Bank’s ability to deliver judgement-based, outcome-focused regulation. The Central Bank’s stated intent was to provide a unified and systematic risk-based framework, to allow banking supervisors to challenge the financial firms they regulate, judge risks and take action to mitigate those risks.25 PRISM has subsequently been replaced by the prescriptions of the SSM supervisory manual, which Cyril Roux said “are guided by a similar, if not more tough intrusive and sceptical ethos.”26
The Central Bank and Financial Services Authority of Ireland Act 2003 (CBFSAI Act 2003), implemented in 2005, gave the Financial Regulator the power to take action against financial institutions by way of administrative sanctions.27 However, in practical terms, these sanctions were not used against financial institutions for breaches of prudential regulations in the pre-crisis period (see Chapter 4).
The Enforcement Directorate was established within the Central Bank in June 201028 to address a gap in the regulatory regime, namely to provide the capability to take action against financial institutions where they failed to manage their risks adequately29 . The Directorate is organised into two divisions:
In 2013, the Central Bank contributed technical assistance in the formative processes that ultimately established the framework for the ECB’s Single Supervisory Mechanism (SSM). The principal objectives of the SSM are to ensure the safety and soundness of the European banking system and to increase financial stability in Europe. The SSM introduced a new system of financial supervision in Europe, comprising the ECB and the national supervisory authorities of participating EU countries. The ECB assumed its new role as supervisor of the larger Irish banks31 and Euro area banks in November 2014.32
According to the evidence of a number of witnesses from the Central Bank, banking supervision was significantly under-resourced in the run-up to the banking crisis. This was independently verified in a Mazars Report published in February 2009.33
In the period following the banking crisis, it was planned to increase staffing numbers involved in banking regulation within the Central Bank from 349 in 2009 to 725 by 2012. The objective behind this increase was to enable the Central Bank to execute its powers and responsibilities effectively.34 However, at the date of this report, the staffing issue remains a challenge for the Central Bank.
In his evidence, Cyril Roux said:
“So I would say for prudential supervision, we have some vacancies. We have 124 people when we have our approved complement ... or we have estimated we need 140. But I think, here, where we are an outlier is mostly in terms of supervisory experience.”35 …“So I think it’s a continuous challenge to staff adequately ... not even to lose people, just to replace people who are leaving is the challenge.”36
The Central Bank (Supervision and Enforcement) Act, 2013 came into effect on 1 August 2013 (the 2013 Act).37 The 2013 Act significantly enhanced the capacity of the Central Bank to supervise regulated entities, including banks, and to enforce financial services legislation.
The 2013 Act strengthened regulation in a number of ways, provided better tools for risk assessment, increased enforcement sanctions against firms and individuals, set clearer regulatory and policy making powers, provided a new best practice whistle blowing standard and increased the level of sanctions it may impose.
The 2013 Act also provided the Central Bank with the ability to pass new types of regulations, the power to issue wider-ranging directions, wider powers for authorised officers and the ability to require skilled persons reports from regulated entities. Skilled Persons reports require a regulated entity to produce a report, at the entity’s own expense, on matters specified by the Central Bank. The decision to commission such a report is usually prompted by a specific requirement on the part of the Central Bank for information, analysis of information, assessment of a situation, expert advice or recommendations.
The 2013 Act doubled the administrative sanctions, increasing the maximum fine for individuals and bodies corporate to €1 million and €10 million (or 10% of annual turnover) respectively. In his evidence to the Inquiry, Cyril Roux provided an overview of the principal fines levied by the Central Bank on banks for offences committed prior to 2014:
“Banks entered into a settlement with us for failing to ensure the accuracy of its liquidity reporting and to have internal controls in place ... Allied Irish Banks admitted to the contraventions, they accepted a reprimand and penalty of €490,000. Citibank Europe entered into a settlement with us on contraventions of liquidity requirements and also paid a monetary penalty of half a million.”38
Amid efforts to improve the supervision and prudential regulation of banks, the Central Bank had to remain cognisant of the severe impact of the financial crisis on the customers of the financial institutions. While all categories of consumer borrowing deteriorated, the area of principal concern related to home loan arrears.
In response, the Financial Regulator introduced the Code of Conduct on Mortgage Arrears in February 2009 (updated most recently in 2013)39 in order to ensure fair and consistent treatment for borrowers who fall into arrears on their home loans. The Central Bank also introduced an updated version of its Consumer Protection Code40 in January 2012.
The Central Bank Consumer Code applies to all financial services products and providers. It includes both general principles and specific requirements for regulated product providers and covers topics such as arrears handling, errors and complaints resolution procedures, amongst others.41
Although not within the remit of the Central Bank, a further important reform for customers suffering from the financial fallout of the crisis was the introduction of the Personal Insolvency Act 2012 (the 2012 Act).42 The 2012 Act introduced a number of new measures for dealing with borrowers in financial distress, with the aim of making the majority of cases quicker and easier to deal with, rather than resorting to bankruptcy, which previously was the only fall back option. The 2012 Act also introduced measures to update the bankruptcy legislation, the most significant being a reduction to the bankruptcy term from twelve years to three in the majority of cases.
In his evidence, Cyril Roux drew attention to two reviews.43 The first review was a balance sheet assessment carried out by the Central Bank of the three remaining Covered Institutions, conducted as part of the 2013 Financial Measures Programme.44 This review concluded that the Covered Institutions were mostly in financial working order and required only moderate strengthening of their provisions, which were addressed by actions taken in their year-end accounts.
The second review which Cyril Roux mentioned was one conducted by the IMF.45 That IMF review found that, since the crisis had begun, the Central Bank had taken substantive steps to rebuild its functions in financial regulation and supervision. These steps included changes in the institutional setting, changes of senior staff, and increases in the quantity (albeit from a very low base) and calibre of supervisory staff.
The IMF acknowledged the design and implementation of a proactive and intensive approach to supervision, the expansion of prudential requirements and improvements in enforcement powers. Overall, the IMF ascribed to the Central Bank and to Ireland, as of 2013, a satisfactory level of compliance with the Basel Core Principles for Effective Banking Supervision.
The Central Bank Reform Act 2010 also requires that the Central Bank make appropriate arrangements for an international peer review of its regulatory performance to be carried out at least every four years. The first such review was scheduled to be undertaken in 2014 but, as at the time of writing of this report, the output of that review had not been made public.
Michael Noonan summarised the suite of regulatory changes adopted since the financial crisis occurred as follows:
“…The effectiveness of the current governance regime has been enhanced by a suite of reforms to the Irish banking and regulatory system, initiated at both an Irish and EU level. Such reforms include the European banking union, which will provide for centralised supervision and will help to rebuild trust and confidence in the European banking sector. Importantly, the link between the banks and the sovereigns has been broken and the bailout of banks has been replaced with bail-ins”.
“At the domestic level, a significant amount of reform was undertaken in the financial regulation … These reforms will form the foundation of a strong and effective governance structure, which will go a long way to making sure a boom and bust-type of cycle will not reoccur…”46
The Department of Finance plays a lead and central role in the formulation and management of Ireland’s economic affairs, especially with regard to macro-economic matters and fiscal stewardship. Thus, along with the regulatory authorities and the banks, the Department is entrusted with a special responsibility.
While oversight of the financial system is not the Department’s responsibility, it nonetheless has a role to play. This is particularly so in the context of bank debt becoming entwined with sovereign debt.
In the wake of the financial crisis, Brian Lenihan commissioned a review of the Department of Finance’s policy, advice and performance over the previous ten years and on how best the Department might adapt to meet challenges in the future (commonly known as the Wright Report).47 A number of reforms were recommended on foot of the Wright Report and this section seeks to provide an overview of the proposed reforms that were implemented.
The Wright Report was published in December 2010 and provided an assessment of performance of the Department before and during the financial crisis. At the time of writing the Wright Report, the financial crisis had entered its second substantive phase, with the Troika Bailout agreed almost simultaneously with completion of the Report.
The Wright Report contains 50 recommendations across a wide range of topics, including risk analysis, economic and fiscal forecasting, the budgetary process, policy advice, internal structures, and human resources and skills requirements. The findings of the Wright Report related to the Department of Finance as it was structured and resourced at the time of the writing of the Report. Thus, it covered a number of functions which were reassigned months later to the new Department of Public Expenditure and Reform, established after the 2011 General Election.
The newly established Department of Public Expenditure and Reform was assigned the dual goals of reducing public spending to sustainable levels and reforming public services.48 Although key to improving the efficiency and effectiveness of the public service, thereby acting as a driver of stability and growth, the Department of Public Expenditure and Reform’s policies and actions do not impact directly on the financial system and accordingly are outside of terms of this Inquiry.
The Department of Finance submitted its own assessment of the changes implemented since the publication of the Wright Report to the Inquiry.49 The Department’s assessment provides a detailed response on, inter alia, actions taken in respect of the 50 Wright Report recommendations. Amongst the principal actions outlined in the Department assessment document are:
More structured interaction: Internal and external interaction are now on a more structured footing, internally between divisions and externally between the Department and other Departments, as well as the Central Bank, NTMA, ESRI and external experts.
Expanded ‘Principals Group’: The ‘Principals Group’ (which replaced the Domestic Standing Group) involves key officials from the Central Bank, the NTMA and the Department. This group was used on bank restructuring and the Bailout negotiations, meeting weekly or more frequently, where required.50
Memorandum of Understanding: The Department now has in place a Memorandum of Understanding (MOU) with the NTMA setting out the roles and responsibilities of each party in relation to the compilation of debt data and servicing forecasts.51
Shareholding Management Unit: The Department’s oversight of NAMA is now managed by the Shareholding Management Unit (the Unit), which is staffed with banking specialists on secondment from the NTMA’s banking division. The Unit is responsible for ensuring that Ministerial responsibilities under the NAMA legislation are fulfilled and that the NAMA’s objectives are met. There is now regular interaction with senior executives of NAMA, both on a formal and informal basis, involving frequent meetings.52
Codified governance: The Department has formally codified its governance structures and processes in a single document.53
Improved external consultation: There is an increase in the Department’s engagement with other Departments and bodies on the identification and management of risk, including fiscal and economic risks. This engagement is not supported by a legislative mandate.
Improved internal risk analysis: The Department has engaged with the development of the National Risk Assessment process (including identification of economic and financial risks in the 2014 NRA document). It is working with the Department of the Taoiseach in progressing a methodology for managing and mitigating the identified risks.54
In his evidence, Derek Moran, Department of Finance, said: “I went through all 50 recommendations of the Wright report, Regling-Watson and the Governor’[s] [Report] and so on … I’m fairly well satisfied that, you know, we’ve pretty much implemented them all”.55 Derek Moran added“… this is never a finished project. You need to keep doing more and more and more and to the extent possible, benchmark what you’re doing against best practice elsewhere”.56
Evidence was provided to the Joint Committee by a number of witnesses on behalf of the Department of Finance in relation to the changes that have occurred in respect of taxation and fiscal matters in the aftermath of the financial crisis.
The Tax Policy Division within the Department now has some 35 staff. As part of the budgetary process, the Division chairs and supports the high-level Tax Strategy Group which considers between 10 and 20 separate tax policy papers prepared internally each year.57
The Irish Fiscal Advisory Council (IFAC), which was placed on a statutory footing in December 2012, provides independent assessments of Department of Finance budgetary forecasts and proposed fiscal policy objectives.58 In his evidence, John McHale, chairman of IFAC, said: “under the leadership of the [Department’s] Chief Economist, the quality of the Department’s macroeconomic forecasting work is of a high level.”59
However, he pointed to a deficiency in the Fiscal Responsibility Act 2012 in that it does not provide IFAC with a statutory right to information, a principle identified by the OECD for best practice for independent fiscal institutions:
“…not have the resources to produce a full set of our own benchmark budgetary forecasts…”60 and he said“the Fiscal Responsibility Act does not provide the Council with a statutory right to information. Such a right is also one of the principles identified by the OECD for best practice for independent fiscal institutions.”61
Michael Noonan said that the Fiscal Council must endorse the budget forecast and added: “… otherwise I can’t build the budget on the forecast that Finance produces. Now, that’s an extremely strong power... an extremely strong power and it’s mandatory….. [on] which we base the budget, they have to be endorsed by the Irish Fiscal Advisory Council.”62
John McHale said that “the Council receives very good cooperation from the Department in its review work.”63 He concluded that the framework now in place, which combines complementary domestic and European elements “..….. should help ensure that the budgetary policy mistakes that contributed to the vulnerabilities of the Irish economy in the past are not repeated”.64
The Department has identified the need for greater inclusiveness in Departmental management as one of its guiding principles specifically in respect of engaging at all levels within the Department, including more junior roles and across disciplines. A number of new standing subcommittees of the MAC65 , such as risk, policy, EU strategy and capital markets allow for greater in-depth analysis than could occur during MAC meetings.66
On the accommodation of dissenting opinions on economic matters, Secretary General, Derek Moran said that the process of developing a position on the economic policy “would include discussions across the range of people” and that the ultimate position“would’ve taken on board very, very different views…..”67 . He added that contrarian views are now incorporated “dissent ... or contrarian views … are accommodated within that sort of dialogue that goes through the process.”68 He concluded that the Department“had in place procedures and processes that allowed an appropriate discussion, particularly of ... visions around housing and construction and so on.”69
Appendix 11 Footnotes
1. Regling and Watson, A Preliminary Report on The Sources of Ireland’s Banking Crisis, PUB00168-029.
2. Honohan Report, The Irish Banking Crisis Regulatory and Financial Stability Policy 2003-2008, May 2010, PUB00075-054/057.
3. Alan Gray, Economist, former Non Executive Director, Central Bank, and Managing Director of Indecon Economic Consultants, statement, AGR00001-011.
4. European Commission Green Paper Corporate governance in financial institutions and remuneration policies, KPMG00938.
5. Central Bank & Financial Services Authority Paper dated 21 June 2010 “Banking Supervision: Our New Approach”; Annual Performance Statement (Financial Regulation) 2010-2011, Annex 2, PUB00057-053.
6. The Central Bank’s policy efforts during the period 2003-2010, CB00069-005.
7. The Central Bank’s policy efforts during the period 2003-2010, CB00069-006.
8. The Central Bank’s policy efforts during the period 2003-2010, CB00069-006.
9. Central Bank, Fit and Proper Requirements May 2006, CB07235.
10. The “Fitness” standard requires that a person appointed as a director or manager must have the necessary qualifications, skills and experience to perform the duties of that position. “Probity” requires that a person is honest, fair and ethical.
11. Central Bank, Fit and Proper Requirements May 2006, CB07235.
12. Central Bank, Fitness and Probity Standards 2011, RBO00001-002.
13. The 2010 Act was commenced on 1 October 2010.
14. Address to the Chairpersons’ Forum Institute of Public Administration by Matthew Elderfield, PUB00410.
15. Cyril Roux, Deputy Governor (Financial Regulation), Central Bank, transcript, INQ00099-012.
16. Central Bank of Ireland & Financial Services Authority Paper “Banking Supervision: Our New Approach”, PUB00411.
17. Memorandum for Government, Draft text of the Central Bank Reform Bill, DOF06657.
18. Central Bank of Ireland & Financial Services Authority Paper “Banking Supervision: Our New Approach”, PUB00411-035.
19. Central Bank & Financial Services Authority Paper dated 21 June 2010 “Banking Supervision: Our New Approach”; Annual Performance Statement (Financial Regulation) 2010-2011, Annex 2, PUB00057-053.
20. Central Bank of Ireland & Financial Services Authority Paper “Banking Supervision: Our New Approach”, PUB00411-002.
21. Honohan Report, The Irish Banking Crisis Regulatory and Financial Stability Policy 2003-2008, May 2010, PUB00075-044/081.
22. Central Bank Annual Performance Statement (Financial Regulation) 2010-2011, PUB00057-006.
23. Cyril Roux, Deputy Governor (Financial Regulation), Central Bank, transcript, INQ00099-018/021.
24. Central Bank Annual Performance Statement Financial Regulation 2011-2012, PUB00059-005.
25. Central Bank Annual Performance Statement Financial Regulation 2011 – 2012, PUB00059-038.
26. Cyril Roux, Deputy Governor (Financial Regulation), Central Bank, transcript, INQ00099-005.
27.http://www.irishstatutebook.ie/eli/2003/act/12/enacted/en/html
28. Part IIIC of the Central Bank Act, 1942, as amended.
29. Central Bank, Annual Performance Statement (Financial Regulation) 2010-2011, PUB00057-042.
30. Central Bank, Annual Performance Statement (Financial Regulation) 2010-2011, PUB00057-042.
31. AIB, BOI, PTSB and Ulster Bank Ireland.
32. Central Bank, Annual Performance Statement Financial Regulation 2013 – 2014, PUB00063-005.
33. Towards a “Best Practice Organisation” Mazars, February 2009, PUB00271.
34. Annual Performance Statement (Financial Regulation) 2010-2011, PUB00057-042.
35. Cyril Roux, Deputy Governor (Financial Regulation), Central Bank, transcript, INQ00099-007.
36. Cyril Roux, Deputy Governor (Financial Regulation), Central Bank, transcript, INQ00099-008.
37. Central Bank (Supervision and Enforcement) Act 2013 (Commencement) Order 2013; See Department of Finance, Narrative on Reports into Financial Crisis and actions taken, DOF02474-002.
38. Cyril Roux, Deputy Governor (Financial Regulation), Central Bank, transcript, INQ00099-013.
39. Financial Regulator Code of Conduct on Mortgage Arrears, February 2009; Annual Performance Statement (Financial Regulation) 2011-2012, PUB00059-068/069.
40. Central Bank of Ireland, Consumer Protection Code 2012 Annual Performance Statement (Financial Regulation) 2011-2012, PUB00059-068/069.
41. Central Bank of Ireland Consumer Protection Code, 2012, PUB00059-068/069.
42. Draft Press Release Minister Shatter publishes Scheme of Personal Insolvency Bill, DOF06841-001.
43. Cyril Roux, Deputy Governor (Financial Regulation), Central Bank, transcript, INQ00099-003.
44. Central Bank Annual Performance Statement Financial Regulation 2013 – 2014, PUB00063-005.
45. IMF Detailed Assessment of Observance of Basel Core Principles for effective Banking Supervision April 2014, PUB00283.
46. Michael Noonan, Minister for Finance, transcript, INQ00102-007.
47. Report of the Independent Review Panel, Chaired by Rob Wright (former Deputy Minister for Canada), ‘Strengthening the Capacity of the Department of Finance’, (commonly known as the Wright Report), published in December 2010, PUB00175.
48.www.per.gov.ie/en/what-we-do-2/
49. Department of Finance, Report of the changes made in response to the Wright Review, created for the Banking Inquiry, DOF02844.
50. John Moran, Secretary General & former Second Secretary General, Department of Finance, statement, JMO00002-013.
51. Department of Finance, Report of the changes made in response to the Wright Review, created for the Banking Inquiry, DOF02844-006.
52. Department of Finance, Report of the changes made in response to the Wright Review, created for the Banking Inquiry, DOF02844-007.
53. Derek Moran, Secretary General and former Assistant Secretary, Department of Finance, statement, DMO00001-013.
54. Wright Report, Strengthening the Capacity of the Department of Finance, DOF02844-007.
55. Derek Moran, Secretary General and former Assistant Secretary, Department of Finance, transcript, INQ00114-025.
56. Derek Moran, Secretary General and former Assistant Secretary, Department of Finance, transcript, INQ00114-026.
57. These papers are published on the Department’s website after each budget- Department of Finance, DOF02844-008/009.
58. John McHale, Chairman, Irish Fiscal Advisory Council, statement, JMH00001-003.
59. John McHale, Chairman, Irish Fiscal Advisory Council, statement, JMH00001-005.
60. John McHale, Chairman, Irish Fiscal Advisory Council, statement, JMH00001-006.
61. John McHale, Chairman, Irish Fiscal Advisory Council, statement, JMH00001-007.
62. Michael Noonan, Minister for Finance, transcript, INQ00102-023.
63. John McHale, Chairman, Irish Fiscal Advisory Council, statement, JMH00001-005.
64. John McHale, Chairman, Irish Fiscal Advisory Council, statement, JMH00001-003.
65. Management Advisory Committee, Department of Finance.
66. Department of Finance, Report of the changes made in response to the Wright Review, created for the Banking Inquiry, DOF02844-014.
67. Derek Moran, Secretary General and former Assistant Secretary, Department of Finance, transcript, INQ00114-005.
68. Derek Moran, Secretary General and former Assistant Secretary, Department of Finance, transcript, INQ00114-005.
69. Derek Moran, Secretary General and former Assistant Secretary, Department of Finance, transcript, INQ00114-006.
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