Governance and the credit union future - Patrick Casey, Registrar of Credit Unions

05 November 2018 Speech

Patrick Casey

Address to the National Supervisors Forum AGM

Chairman, members of the Executive, ILCU President Charles Murphy, ladies and gentlemen, I am delighted to speak today at the 2018 AGM of the National Supervisors Forum (NSF), and share my perspectives on the Irish credit union sector.

I want to begin by acknowledging the constructive engagement we have with the NSF under your Chair Liam Kelly. The NSF’s commitment to supporting the development of the skills and effectiveness of Board Oversight Committees is significant. We commend you as you continually seek to improve the contribution of your members in delivering their important oversight role.

The theme of your conference, “Effective Governance of Credit Unions”, is apt.  Strong governance standards are a fundamental requirement to support strong, viable credit unions and are a pre-requisite for credit unions seeking to expand their existing business models. Indeed, in line with our statutory mandate1, it speaks to our vision of “Strong Credit Unions in Safe Hands”:

  • We see ‘Strong Credit Unions’ as being financially strong and resilient, enabled by sustainable, member-focussed business models, underpinned by effective governance, risk management and operational frameworks.
  • We see that credit unions are ‘in Safe Hands’ when they are effectively governed, professionally managed and staffed, by competent, capable people who appreciate and prudently manage risks, while successfully meeting members’ product and service expectations.

Many credit unions are endeavouring to adapt their business models from a traditional savings and loans offering, to provide members with an expanded range of products and services. Effective governance is at the heart of successful business change. Through it clarity is brought to bear right across a credit union’s decision-making processes. This provides clearer visibility on the strategic, financial and operational challenges being faced, and what corrective actions need to be implemented, and by whom, in order to address them. In understanding this, Directors and CEOs/managers also acknowledge their individual and collective accountability and responsibility.

As you focus on effective governance, there are a number of questions to consider, in particular for those overseeing credit unions engaged in material business model transformation. These include:

  • Does your credit union have a risk mind-set in evidence across all of its activities to enable transition on a safe, sound and sustainable basis?
  • Is there a well-developed risk appetite statement, which is embedded in its governance and operational processes?
  • Does the board promote a culture where constructive challenge ensures enhanced strategies emerge from board and CEO/manager discussions?
  • Are the resulting strategic plans centred on credit union sustainability?

Within a sector of 264 credit unions2 of different sizes and capabilities, there will be varying levels of capacity regarding future business strategy.  Not all credit unions want to transition to an expanded business model, including some with emerging viability challenges. For those credit unions, we expect that all strategic options are being considered, including a transfer of engagements to a stronger credit union capable of meeting members’ needs. 

I am fully conscious of the unique position of Board Oversight Committees – you are appointed by your credit union members to perform an important oversight role, to assess whether the board is operating in accordance with the governance and operational requirements set out in Part IV and Part IVA of the Credit Union Act 1997. Ideally, it is a complementary relationship, one that adds value on behalf of members, ensuring that primary functions of the board are delivered upon.

Consistent with the nature of your role, the Board Oversight Committee is not expected to involve itself directly in the operations of the credit union. You are however in a position to evidence the quality of the board’s performance, including its deliberation on key strategic priorities on behalf of members. Constructive challenge and feedback from Board Oversight Committees supports a culture of collective challenge and improvement. Getting the balance right is critical. The ongoing training being provided by the NSF plays an important role in that respect.

In my address today, I intend to share my perspectives with you on four key areas:

As the sector seeks to undertake business model change, from the perspective of financial strength and meeting regulatory standards, what is the current position of credit unions today as a starting point;

  1. The importance of each credit union defining its strategic orientation for the future, grounded on a well-developed risk appetite;
  2. The importance of understanding both credit union strategic enablers and prudential supports; and
  3. Building upon its chosen orientation, what will the future hold for your credit union?

As the sector seeks to undertake business model change, from the perspective of financial strength and meeting regulatory standards, what is the current position of credit unions today as a starting point?

Sectoral and prudential profile

From a sectoral perspective, there are 264 active credit unions across the country3. The footprint of the sector is further augmented by a broader branch network serving members’ needs. The sector holds over €17 billion in assets4.  53 of the largest credit unions (with total assets in excess of €100 million) account for 55 per cent of sector assets and 50 per cent of sector members. 130 credit unions with total assets of ≤€40 million account for 16 per cent of sector assets and 19 per cent of sector members. These statistics highlight the diverse nature of the sector, and underline the fact that as business model development progresses, not all credit unions will be able to participate equally. 

Sound governance and effective systems of control are essential foundations required both to oversee and manage current activities and to underpin the development of new activities.  It is therefore important that credit unions ensure they have embedded systems and controls to acceptable levels, before engaging in significant business model development. Work continues across the sector in that regard. At a time of change for many in the sector, it is particularly important that those credit unions are mindful of identifying and addressing their own risk vulnerabilities, to protect members and their funds.

We published our 2017 PRISM Supervisory Commentary in March 20185, setting out the current status of governance and risk management standards in credit unions we inspected.

Whilst governance standards have improved across the sector, governance remains one of the key risk areas for credit unions. It is concerning that almost 60 per cent of individual risks identified during on-site engagements relate to governance and operational risks. We are still seeing high levels of weakness relating to risk management and compliance reporting. In terms of operational risks, issues cover IT governance-related vulnerabilities, inadequate segregation of duties and deficiencies in terms of key reconciliations.

Credit risks represent 19 per cent of individual risks overall. Clearly as a priority credit unions must address any weaknesses being evidenced in relation to the core activity of underwriting loans and related processes.

Strategy and business model risk issues are also evident. For instance we are seeing inconsistencies between credit unions’ documented risk appetite statements and policies linked to risk appetite. This is concerning, given commercial challenges facing many individual credit unions today, and highlights an important area for increased focus for boards and management teams.

We will be publishing a 2018 PRISM Supervisory Commentary in H1 2019, which will provide further clarity on standards within the sector. All credit unions need to meet minimum regulatory standards – not reactively in the context of supervisory engagement – but proactively in order to address their own risk vulnerabilities so as to protect members and their funds. I therefore encourage all credit unions to review our PRISM supervisory commentary findings, as they seek to strengthen their core prudential foundations on an ongoing basis.

Financial performance and position

Moving to broader sectoral and credit market trends, I would refer you to two recent Central Bank publications relevant to today’s circumstances:

  1. The Registry of Credit Unions bi-annual report entitled the “Financial Conditions of Credit Unions”, issued in August 20186.
  2. Central Bank Household Credit Market Report, issued in October 20187.

Financial Conditions of Credit Unions 2013 to 2018

In August this year, we published the “Financial Conditions of Credit Unions 2013-2018”, based upon data reported in prudential returns up to 31 March 2018. The report analyses financial performance over the previous five years. It is an important statistical information release with a primary focus of assisting credit unions in analysing performance relative to peers, and to provide insights to the sector on key trends from prudential data.

The report highlights positive trends within credit unions with continued improvement in areas such as lending growth, reported arrears and overall reserves. Significant financial and commercial challenges remain for many credit unions however, including a low loan to assets ratio, low investment yields and high cost income metrics, translating into declining return on assets across the sector. Despite positive loan growth overall, the average loan to assets ratio at 27 per cent remains static and reflects the continued rate of savings inflows, which are outpacing new lending.

While an increase in lending growth is positive, it is not at a quantum to meaningfully impact overall credit union performance. Indeed, there are examples across the sector of new lending diluting income generation given an increased level of longer term lending which typically commands a lower return. Credit unions therefore must consider the adequacy of product pricing and related financial impacts, as they make important strategic business decisions for the long term.

Underlying data highlights the variance in financial position and performance between credit unions across the sector:

  • The loan to assets ratio ranges from 11 to 75 per cent.
  • Annualised return on asset ranges from -1.1 to 3.5 per cent.
  • Total realised reserves range from 10 to 26 per cent.

The variance of these key performance indicators – and the loan to assets position in particular – underlines the diversity in income generation capacity amongst credit unions. It is also a clear indicator that the credit union regulatory framework is not the inhibiting factor in terms of lending growth.

The Household Credit Market Report 2018

The Central Bank’s Household Credit Market Report 2018 - and underpinning statistical tables providing multi-year comparative statistics8 - highlights that the size of the non-mortgage consumer credit market has declined 4 per cent from €13.4 billion to €12.8 billion since 20139. There has been significant growth in the one to five year segment of that market, which has grown from c.€6 billion to c.€8 billion. It now represents 61 per cent of overall non-mortgage consumer credit.

The one to five year segment is core to credit unions who collectively retain a 46 per cent market share within the segment down from 60 per cent10 in 2013. The monetary amount of one to five year lending provided by credit unions today is largely the same as in 2013 at €3.6 billion. However, the credit union share of this segment has declined as a consequence of stronger growth by other lenders.

The current position

When taken together, it is reasonable to consider what these three reports are telling us about the financial strength and regulatory standards in credit unions.

Positively, we continue to see loan growth returning. However, while the core one to five year segment has grown by c.€2 billion over the last five years, credit unions do not seem to have captured much of this increased credit demand. Credit unions need to consider why their lending performance was not stronger in this core segment. As part of the strategic planning process, credit unions should be considering how best to retain and grow their market share and by extension, protect income generation. A loss of market share in this core area as a consequence of pursuing new activities such as longer term lending, may ultimately dilute return on assets.

As many credit unions seek to manage their existing business while advancing into new areas, continuous strengthening of core prudential foundations must also remain a priority. As you would expect, the Central Bank will continue to require minimum regulatory standards are met by all credit unions, and we retain higher expectations for those with more complex business models.

Having clarified the current position in terms of financial strength and meeting regulatory standards, attention can turn to the future.

The importance of each credit union defining its strategic orientation for the future, grounded on a well-developed risk appetite

Defining the strategic orientation

As credit unions seek to evolve from a traditional savings and loans offering to provide members with an expanded range of products and services, success requires clarity in terms of strategy and risk orientation. 

In taking ownership of business model development, boards are seeking to define the future strategic direction. This requires a developed understanding of member demand and clarity regarding risk appetite. In defining its strategic orientation, a credit union must consider:

- Is its strategy aligned to its risk appetite statement?

- What are the products and services members need and is there sustainable demand for them within the common bond?

  • Are they within the risk appetite of the credit union?
  • Can they be fully accommodated within the credit union’s governance, risk management and operational frameworks?
  • Can the credit union deliver them on an economic basis that is sustainable, bearing in mind competitive dynamics?            

Each credit union business model is unique to its environment. Common bond circumstances vary depending upon membership profile, economic conditions locally, competitive dynamics and financial profile. Each business model presents its own challenges in terms of transitioning to a target model. As no single model represents the ideal, the challenge for each credit union is to define a model that is appropriate to its environment, circumstances, resources and capabilities, not to mention its risk orientation.

We emphasise credit union ownership of their business model, which means boards taking ownership of critical strategic decisions and being accountable to members for making appropriate choices. For those credit unions who do not wish to undertake significant business change, that is their strategic choice. Accordingly, they should be able to demonstrate through analysis how they arrived at this decision. In such circumstances we expect to see a thorough assessment of long term sustainability and contingency planning to ensure continuity of member services, including where appropriate, the identification of possible transfer partners.

Risk orientation

We see higher performing credit unions have typically moved beyond a mere ‘tick box’ compliance attitude to exhibit a more rounded governance culture, with the board and management teams demonstrating strong risk awareness and understanding. Credit unions are required to manage risks in a systematic and structured fashion. This will be assessed as part of our PRISM engagements. Where issues of concern are identified by our supervisors, we will be clear in setting out the issues concerned in risk mitigation programmes (RMPs) which set out the mitigating actions to be taken by the credit union to address them. The responsiveness to and quality of the remediation of these RMPs distinguishes progressive and risk-focussed credit unions from their peers.

Business model strategy and risk appetite must be aligned. Defining risk appetite is a task for the board and management, as it sets the scope and parameters of the credit union’s strategic approach. New strategic initiatives may present opportunities, but the expected rewards must be weighed against related risks. The board and management must consider the risk capacity of the credit union, including the amount and type of risk the credit union is able to support, based on its operational capacity and financial strength.

Therefore, in determining the strategic orientation of the credit union, boards must take ownership of their business model change agenda and have a developed sense of risk appetite.

Lack of clarity regarding risk appetite can result in excessive ambition in strategic planning in some instances, and excessive conservatism in others. Both present risks to achieving desired business model sustainability. At an extreme, where there is lack of clarity, board and management may have a conflicting understanding of risk appetite, which has the potential to create operational and strategic dysfunctionality.

The importance of understanding both credit union strategic enablers and prudential supports.

Strategic enablers

Having clarified the risk appetite and strategic orientation of the credit union, attention turns to the capacity to deliver it supported by key enablers. Each credit union has varying attributes and capabilities to draw from in that regard across:

  • Financial and balance sheet profile;
  • Common bond dynamics;
  • Core foundations – in terms of governance structures, risk management frameworks and operational capability;
  • Staff competence and capability;
  • Systems and technology;
  • Marketing and distribution platforms; and
  • Third party and shared service supports.    

Each credit union needs to be clear regarding the qualitative drivers of the credit union’s strategy in terms of: (i) success drivers; (ii) validity of assumptions in planning and financial projections; and (iii) how realistic and executable the strategy is. There should be clarity regarding the gap between the envisaged business model and the current business model, and, in terms of execution, the required strategies and enablers needed to deliver it.

From a regulatory perspective, all of these enablers depend upon the effective functioning of the credit union’s core foundations and related systems and controls.  In this context, I will focus today on key prudential supports.

Prudential supports

As you know, we engage proactively and transparently with the sector, and value our direct bilateral interaction with those who oversee and govern it. Our multi-channel interaction with the sector includes:

  • our on-site and off-site engagement underlining our risk-based supervisory approach designed to enhance safety and soundness, by supporting credit unions in building core foundations through supervisory proportionality;
  • our important sector communications on cross cutting issues, including guidance, PRISM supervisory commentary and thematic reviews, which support boards and CEOs/managers, in addressing key risk vulnerabilities;
  • our statistical publications such as the Financial Conditions of Credit Unions report;
  • our regular meetings with trade bodies and other stakeholders;
  • our engagement with the sector on evolving an already tailored and proportionate regulatory framework for credit unions, where prudentially justified, through regulatory responsiveness;
  • our annual information seminars and other engagement channels; and
  • through earned flexibility, our facilitation of strong credit unions in safe hands on business model development proposals, by using our additional service powers where necessary.

Our sectoral reports and statistical publications are provided to all credit unions, in order to support boards and CEO/managers when reviewing the adequacy of their governance, risk management and operational frameworks, and to make any necessary improvements. In doing so, credit unions are better equipped to protect members’ funds.   

We continue to support voluntary restructuring within the sector, involving ongoing transfers of engagements, which as regulator we manage post the Credit Union Restructuring Board (ReBo)11. Year to date, we have supported to completion and confirmed 16 transfers of engagements. A further 13 transfers are at varying stages of progression to completion.

We view the continuation of further restructuring as an important strategic consideration for potential transferor and transferee credit unions. We plan going forward to publish a thematic review on sector restructuring activity over the past five years. This will analyse the impact that completed transfers of engagements have had in changing the nature and profile of the sector.

Other Developments

In the course of 2018, we have introduced a further range of new initiatives to the sector as it seeks to undertake business model development:

Behaviour and Culture Report

The Central Bank published a report assessing the culture and behaviour of the main retail banks operating in the Republic of Ireland that is important reading for all financial institutions. The report entitled: Behaviour and Culture of the Irish Retail Banks[,12 highlights the importance of an embedded consumer focus in structures, processes and systems. This focus speaks strongly to the member-centric ethos of credit unions, which is an identified strength13.

Culture is important from a prudential and conduct perspective, given that behaviours can affect any or all areas of a firm. While elements of the proposed framework contained in the report such as individual accountability are not intended to apply to credit unions, nonetheless it presents important insights on the topic of organisational culture that places the interests of consumers at its heart. The Central Bank is increasingly insisting that firms comply not only with our regulations and codes, but also that the people who lead the firms we regulate and supervise set the right tone-from-the-top, and create and embed a culture that minimises the risk of misconduct. Therefore the report should be read by those involved in all financial institutions including credit unions, and represents a useful reference regarding sound practice in this area.

Long Term Lending – public consultation

I wish to draw particular attention to our recent review of the credit union lending framework. The Central Bank has recently published “CP125 - Consultation on Potential Amendments to the Lending Framework for Credit Unions14. The proposals support diversification in credit union loan portfolios, while effectively managing duration and concentration risk. Changes include a removal of maturity limits based on a percentage of outstanding loans, and the introduction of tiered concentration limits for both house and commercial loans based on a percentage of total assets.

These proposed changes would provide increased flexibility for all credit unions to undertake additional personal lending – in particular between five and ten years. For larger credit unions, who can demonstrate that they have the required financial strength and resilience, expertise, capability and risk management mind-set, the proposals would provide significant additional capacity to undertake house and commercial lending, via a new application process. The Central Bank is of the view that proposals to increase long term lending should be considered by credit union boards in the context of the issues set out in our December 2017 paper entitled ‘Longer Term Lending Guidance for Credit Unions’15. We emphasise the need for the boards of credit unions to ensure that they fully understand the risks involved in longer term lending, including financial, regulatory and consumer impacts.

As noted earlier, the Central Bank is supportive of credit unions prudently engaging in long term lending as part of a balanced loan portfolio, and the new proposals facilitate this across a suite of loan categories to meet members’ needs. We encourage all credit union engagement in the consultation process currently underway, to ensure your voice is heard in relation to changes to the lending framework.

New Credit Union Workshops

As regulator, we continue to support credit unions in strengthening core foundations. We introduced new Credit Union Workshops to assist Directors to better understand and meaningfully address key governance, risk and operational vulnerabilities. These new workshops, underpinned by a clear articulation of our supervisory expectations, have been developed to support improved risk understanding by boards, and by extension, drive improved compliance standards across the sector.

The theme for the first wave of the new workshops was governance, with the Registry presenting on three key areas: strategic leadership, oversight and culture. The workshops facilitated two-way discussion on these areas between credit union Directors and our supervisors, and also provided Directors with an opportunity to learn from their peers.

To date we have held six Credit Union Workshops in Dublin, Limerick and Sligo, which were attended by 205 credit union representatives. As we roll out further workshop sessions over the next twelve months, it is important that board representatives from all credit unions avail of the support being provided.

New CEO Forum on Business Model Development

In July 2018 we initiated a new CEO Forum on Business Model Development. The Forum is designed to help CEOs address the need for business model change by facilitating increased collaboration on new initiatives in service of sector sustainability. Consistent with credit union business model ownership, it is CEO-led, under the independent Chair of Professor Donal McKillop. We see this independence as being important, as discussion and decision-making needs to be led by CEOs. 

The CEO Forum represents all credit unions. It is managed by a CEO steering group comprising 15 credit unions of different sizes. It is designed to foster real collaboration around issues-based work streams with the objective of delivering practical outcomes for all. To identify priority work streams, the CEO Forum recently issued a survey to all credit unions, the results of which, I understand, will be shared with the sector. The role of the Central Bank in the CEO Forum is to provide secretariat support to the Steering Group, and as regulator – to engage constructively on regulatory aspects.

We view this as an important initiative to support credit unions as they focus on addressing their sustainability. The support of all credit unions will be key to its success, and we hope that every credit union can benefit from it. I therefore encourage the participation and support of all credit union CEOs in the new Forum.

Internal audit workshop

In July 2018, the Registry also hosted a workshop to engage directly with credit union internal auditors. The overall purpose of this was to highlight good and weak practices identified in internal audit functions during our on-site engagements, and to receive feedback from internal auditors on their work.  Following the workshop, a communication was issued to all credit unions and internal auditors covering our supervisory expectations, with a specific emphasis on the role of internal audit in the “three lines of defence”. This is another important support function for boards, as they focus on strengthening their core foundations.

Building up your chosen orientation, what will the future hold for your credit union?

The capacity of individual credit unions to deliver a sustainable future will depend upon how they deploy their key strategic enablers. Credit unions face challenges that are commercial in nature, and responses need to be commercially targeted, and grounded in the credit union’s core foundations of governance, risk management and operational capability.

As indicated earlier, the sector comprises credit unions of varying sizes and financial strengths, and at different stages of development in terms of business profile. All face key challenges.  Low loan to asset ratios are evident across credit unions of all asset sizes and reflect longer-term challenges. The ability of credit unions individually and collectively to address these challenges, will determine how each credit union positions itself for future sustainability.

Our review of the lending framework, which is currently out for consultation, represents a significant change package. It is informed by prudential requirements, our engagement with the sector and a desire by many credit unions to evolve their business model. The proposals represent an appropriate lending framework for credit unions that effectively manages duration and concentration risk within loan portfolios, while facilitating credit risk diversification.

The challenge for credit unions in the future is to deliver a product and service proposition on a sustainable basis to members, without undue risk to their funds.  While the focus will understandably be on loan book growth, the relative contribution to income of each loan product must be critically analysed in deciding on a preferred offering. Certain business lines are high volume, low margin, and may take time to generate a positive contribution. Given current challenges and a median sectoral cost / income ratio of 76 per cent, careful prioritisation of offering is key.

It is clear that few credit unions, due to size and scale constraints, have the ability to safely transition their business model absent broader sectoral collaboration. Properly structured and efficiently run, such shared service initiatives can result in improved scale efficiencies and access to technical competence that may not be affordable for many credit unions on a stand-alone basis.  We are supportive of these developments, where the real costs and legal obligations are understood, and where they provide realisable benefits for participating credit unions and their members. 

Inevitably, for some credit unions, their strategic assessment will highlight that they are not in a position to deliver the product and service needs of their members into the future. In such cases, restructuring may provide a solution whereby a stronger credit union can deliver for members on a sustainable basis. 

For credit unions with emerging viability issues, we seek to engage with boards regarding the strategic options available. Our preference is to support a transfer of engagements to a stronger credit union to ensure continuity of services for members. The earlier the decision is made by the board to pursue a strategic transfer in those circumstances, the higher the prospects of success for all parties, and most importantly, for members.


It is now six years since the Commission on Credit Unions report and ensuing legislation was published. The report made a range of recommendations to strengthen credit union governance and highlighted, “At its fundamental, governance is about aligning the actions and choices of credit union boards and managers with the interests of members.”

The Credit Union and Co-operation with Overseas Regulators Act 2012 introduced a range of valued added supports for boards including those of internal audit, compliance and risk management. It required boards to adopt a more formal strategic leadership and oversight function, and provided Board Oversight Committees to support the strengthening of governance. It also required that boards approve strategic plans to support achievement of sustainable business models through prioritisation. Overall it placed a strengthened regulatory and governance framework on the statute book, so that the sector in Ireland was positioned to evolve in line with mature international peers. 

So the framework is in place, but what progress has been made in terms of business model change and related collaboration? The sector has yet to materially transform the credit union business model from its traditional savings and loans offering. Business model change initiatives are emerging, such as MPCAS scheduled for a H1 2019 launch. While a range of other product proposals are under consideration within the sector, significant solutions have yet to be operationalised. Collaboration between credit unions remains at an early stage of development. The CEO Forum should be a positive platform to help support collaborative efforts by CEOs in this regard.

While there has been some improvement in governance standards across the sector, the position is not uniform. There is a need for continuous focus in this key area. As you will fully appreciate, the absence of a strong governance culture inhibits the credit union. This is the case not only in addressing regulatory requirements, but also inhibits the credit union from effectively responding to emerging business challenges, and by extension ultimately protecting members as consumers.

Going forward, the degree to which you can leverage your strategic enablers and prudential supports will be influential in terms of your credit union’s future. Business model growth is about seeking to ensure that the credit union has a sustainable and vibrant model, with growth potential across a broader set of income streams. For some credit unions, this may posit a strong future. For others, the picture will be more challenging. In either case, analysis must support strategic decision making on the part of the credit union board, and articulate next steps. As Board Oversight Committee members, you are in a position to evidence the quality of such strategic considerations by boards

Ultimately, it is for the sector and its leaders to navigate its vision for the sector’s future. In line with our statutory mandate1, the Central Bank continues to provide the sector with key prudential supports through our supervisory proportionality, earned flexibility, regulatory responsiveness, and through regular constructive engagement on key challenges.

To conclude, I would like to thank all of you for your attention. I trust you will have interesting conference. For our part at the Registry of Credit Unions, we look forward to continuing constructive engagement with the NSF as your representative body, on a broad range of regulatory and supervisory topics.

1 Section 84(1) of the Credit Union Act 1997 (as amended)  - The Bank shall administer the system of regulation and supervision of credit unions provided for by or under this Act with a view to—

(a) the protection by each credit union of the funds of its members, and (b) the maintenance of the financial stability and well-being of credit unions generally.

2 Number of credit unions trading as at 31 March 2018

3 Number of credit unions trading as at 31 March 2018.

4 Figures in this section based on credit unions reporting their Prudential Return as at 31 March 2018.

5 Supervisory Commentary - March 2018

6 Financial Conditions of Credit Unions 2013-2018

7 Household Credit Market Report 2018 

8 Private Credit Household Deposit statistics   See Table A.5.1 Loans to Irish Households  - Purpose and Maturity

9 In terms of market maturity profile the level of credit granted in the less than one year and over 5 years segments have seen significant decreases of €1.2bn (down 32%) and €1.3bn (down 30%) respectively. Credit union market share of these segments is 12% and 26% respectively.

10 As per data reported on prudential returns submitted by individual credit unions.

11 ReBo ceased operation on 31 March 2017.

12 Behaviour and Culture of the Irish Retail Banks - July 2018

13 Credit unions top the CXi Ireland customer experience poll (October 2018) for the fourth consecutive year.

14 Consultation Paper 125 

15 Long term lending guidance for credit unions