Clearing House Group Minutes - Department of Taoiseach

IFSC Clearing House Group 25 September 2012 

Department of the Taoiseach, Sycamore Room at 3.30pm 

Attendance 

Martin Fraser (Chair) 

Mary Clare O‟Sullivan 

Michael Sludds (Secretary) 

Ann Nolan 

Gary Tobin 

Peter Oakes 

Brendan Bruen 

Tim Hennessy 

Leo McAdams 

Peter Keegan 

David Guest 

Paul McGowan 

Pat Wall 

Pat Farrell 

Robert Richardson 

Eamon O‟Dea 

Jim Byrne 

Deirdre O‟Higgins 

Susan Dargan 

Brian Daly 

Kieran Donoghue 

1. Apologies 

John Murphy 

Matthew Elderfield 

Barry O‟Leary 

Padraig Rushe 

Fergus Murphy 

John Feely 

Tony Golden 

Pat Lardner 

Willie Slattery 

Tom Young 

Deirdre Somers 

David Fagan 

D/Taoiseach 


D/ Taoiseach 

D/Finance 

D/Finance 

Central Bank 

FSI 

Axis Capital/FSI 

Enterprise Ireland 

BOAML 

Green IFSC Steering Group 

Chair Funds Group 

PWC 

IBF/FIBI 

Pioneer Investments 

Revenue 

Revenue 

D/JEI 

State Street 

KPMG 

IDA 

D/JEI 

Central Bank 

IDA Ireland 

Bank of Ireland 

FSI 

Willis 

CITI 

IFIA 

State Street 

BNY Mellon/FIBI 

ISE 

Legal & General 

2. Minutes and Matters arising 

The Minutes of the meeting of 7 June 2012, as circulated, were agreed.

3. CHG Operation/IFSC Strategy 

The meeting discussed various dimensions in relation to implementation of the strategy 

taking particular account of the competitive international environment. The idea of 

establishing a Sub-Group was mooted. 

In relation to transparency, consideration will be given in advance of the next Group meeting, 

to the placing the Minutes of the Clearing House Group on D/Taoiseach‟s website, to 

publishing an annual report on the work of the CHG and to briefing the Oireachtas Joint 

Committee on Finance, Public Expenditure and Reform. 

In response to the discussion regarding the forthcoming budget, Tim Hennessy informed the 

meeting that the UK tax regime continued to improve and given London‟s prominence within 

the re/insurance market, it was increasingly challenging for Ireland to differentiate itself. 

4. Regulation (incl.Central Bank/Industry engagement) 

Peter Oakes reported that the Central Bank and Industry continue to engage on business as 

usual matters. He noted that Pat Farrell had informed, following previous engagements 

between the Central Bank and Industry that Industry will be reverting with its views on the 

approach to enforcement very shortly. Pat Farrell confirmed the point at the meeting. Pat 

Farrell informed the Chair that Industry think it important that further engagement take place 

on the Strategic Plan with the Central Bank before its publication. It was noted that the 

Strategic Plan is under draft with publication some months away. 

On the topic of anti-money laundering it was noted that the IFIA has, in past few days, raised 

the prospect of revisiting a specific area (reliance on third parties issue) of AML. The 

Central Bank is awaiting details from the IFIA. Paul McGowan informed that specifics of the 

issue will be sent to the Central Bank shortly. In response to a question from Ann Nolan 

about the timing of the new issue, IFIA confirmed that it will include D/Finance on the 

communication. 

5. D/Finance Update 

Ann Nolan, D/Finance, reported on a number of items including: 

AIFMD Level 2 

The College of Commissioners will not be disposing of the matter straight away. The process 

is continuing and the Department is contact with other Member States, and the Commission 

in relation to this matter. 

Anti Money Laundering Issues 

Discussions are ongoing between the Funds Industry, the Department of Finance and the 

Central Bank in relation to two related issues for some time namely Third party reliance and 

Secrecy Jurisdictions. It is hoped that progress can be achieved on both issues in the short 

term. 

IOSCO Multilateral Memorandum of Understanding (MMOU) 

Industry and the Central Bank recently informed D/Finance that failure to sign the IOSCO 

MMOU by the end of the year will have repercussions. 

The CBSE is currently between second and committee stages and has been for some time. 

Every effort is being made for the Bill to be completed in time for year-end.

CRD Update 

The Capital Requirements Directive and Regulation which are currently being discussed at 

trilogue stage are vitally important pieces of legislation. The need for stronger capital and 

liquidity standards for EU financial institutions is evident from the financial crisis. Ireland 

has played an active role in the negotiations during the Council Working Party group stage 

and will continue to monitor the progress of this proposal. 

General Tax Update 

Budget / Finance Bill 2013 

The annual consultation process with industry in respect of Budget and Finance Bill 2013 has 

commenced. Preliminary meetings have taken place with all of the CHG Tax Subgroups and 

we are awaiting formal pre-Budget submissions from some of the Groups (Insurance and 

Banking & Treasury). 

FATCA is one of the Department‟s (and Revenue‟s) big priorities in terms of Finance Bill 

2013 and negotiations with the US on an Intergovernmental Agreement are currently 

underway. 

Financial Transactions Tax (FTT) 

It became clear at the ECOFIN meeting in June that an EU-wide FTT would not be agreed, 

and those countries who favour the tax will now try to introduce it by way of “enhanced cooperation”, 

under which at least nine countries must participate. This requires those countries 

to write to the Commission asking it to produce a formal proposal for such a directive. No 

letter has issued to date and therefore there is no revised proposal. However, it is believed 

there will be a sufficient number of countries and that any new proposal will not substantially 

differ from the current proposal. 

Ireland will not be among the participating countries but the Minister for Finance has stated 

we will not stand in the way of those who want to introduce an FTT under the “enhanced cooperation” 

mechanism. 

The Minister had previously stated his view that an FTT would be best applied on a wide 

international basis to include the major financial centres; and that if it could not be introduced 

on a global basis, it would be better if it were introduced on an EU-wide basis to prevent any 

distortion of activity within the Union. 

EU Wide Bank Resolution Proposals 

Ireland has been supportive of the Commission‟s work to prepare a proposal for a Directive 

to establish a framework for the recovery and resolution of credit institutions and investment 

firms. Now that it has been published Officials from the D/Finance and the Central Bank are 

engaging with it at Council Working Group level. 

Banking Union 

Ireland supports the development of a banking union for Europe in principle but does not 

favour a fragmented approach. Further banking integration is supported and Ireland would 

favour its application to all banks in the 27.

Ireland supports the development of a banking union for Europe which immediately and 

permanently breaks the link between the sovereign and the banks and significantly eases the 

burden of support that Ireland has already provided to the banking sector. 

6. New Business/International Engagement and Marketing 

Green IFSC hosted a seminar at the Sustainability Conference in Galway in July. The 

seminar was well attended by international and domestic players and received excellent 

coverage in international journals. The keynote address by the Taoiseach served to underline 

Ireland's commitment to developing financial services activities which support the green 

economy. The Minister for Communications, Energy and Natural Resources also addressed 

the seminar. 

The 'Greening the IFSC' initiative was successfully launched by the Minister Rabbitte on 

September 27th. The project is supported initially by 10 major IFSC firms and SEAI. It is a 

key component in building credibility for Dublin as a leading centre for green funds and 

financing activity. It also demonstrates the commitment of the international financial services 

sector to the wider sustainability agenda. 

John Bruton of IFSC Ireland will headline a Green Funds event to be held in New York 28- 

30 November. The event is targeting influencers and decision makers in the global green 

asset management sector. 

In relation to Education and Skills there was a successful launch of DCU MSc in Sustainable 

Energy Finance in June 2012. 

The Green IFSC initiative continues to gather support from private sector participants and the 

public sector/state agencies. The focus through 2012 has been on building a credible 

legislative and skills framework to reinforce a strong branding and communications 

programme. The Steering Group will review work to date in the last quarter and agree an 

action plan for 2013. The mission is to build on the marketing and communications 

momentum and target the key players in the sector using both public and private sector 

resources. 

Enterprise Ireland hosted International Markets Week in Dublin in September. Over 100 

marketing executives from 30 overseas offices representing 60 markets met with EI clients to 

assist them in their international growth strategies. There were over 2,300 meetings 

organised for 700 EI clients. All of EI‟s key Financial Services clients attended the event, 

with significant focus on emerging markets. 

EI will be holding 3 overseas Financial Services events in quarter 4 of this year, a trade 

mission to Canada and to South Africa and an Embassy dinner event in London. 

Kieran Donoghue briefed the Group on recent developments in relation to IDA marketing of 

the sector and international engagement: 

IDA continues to engage with a diverse range of companies within the international financial 

services sector. This includes both existing investors as well as new targets. IDA has recently 

completed a five day promotional programme in Singapore and Kuala Lumpur. The 

programme team included a Senior Official from the Department of Finance. Meetings were

held with a range of institutions including Sovereign Wealth Funds, Banks, Asset / Fund 

Managers and Institutional investors. 

The programme included a specific focus on Islamic Finance and several meetings with 

relevant companies at the Global Islamic Finance Forum (GIFF). Islamic finance is a specific 

area of opportunity identified in the Government‟s Strategy for the sector. The trip confirmed 

several investment prospects from the region– both portfolio and direct. 

Forthcoming overseas marketing missions by IDA include the following: 

West Coast of the United States (US) in October with a focus on Payments and Financial 

Technology (Minister Bruton will also be in the US at this time and meetings are being put in 

place with FS clients) 

Hedge Funds - East Coast US in late October 

The UK (London) early November with John Bruton, President of IFSC Ireland 

SIBOS Japan also November. 

Pat Farrell gave an update on IFSC Ireland. A review of IFSC Ireland‟s mandate was 

recently completed by an independent consultant. Having considered the outputs and 

recommendations, the Council of IFSC Ireland decided to renew the mandate and that of the 

President for a further 2 years. Upcoming promotional events between now and year end are 

focused on London and New York with the latter focused on the marketing of “Green IFSC”. 

7. AOB 

Brendan Bruen reported good engagement on discussions with the Central Bank on Cross 

Border Guidelines. 

Pat Wall led a discussion on the recently published GFSI ratings which placed Ireland at 49. 

There was general agreement that the rating was disappointing but probably not an accurate 

reflection of where Ireland should be, notwithstanding the challenges we face. Pat Wall 

undertook to come back to the Group with suggestions. 

8. Date of next meeting 

The next meeting takes place on Thursday 22 November at 8.30am.

IFSC Clearing House Group 7 June 2012 

Department of the Taoiseach, Room 308 at 8.30am 

Attendance 



John Murphy 

Ann Nolan 

Gary Tobin 

Tom Young 

Michael Brennan 

Patrick Brady 

Brendan Bruen 

Tim Hennessy 

Leo McAdams 

Peter Keegan 


David Guest 

David Fagan 

Tony Golden 

Pat Lardner 

Denis Curran 


Paul McGowan 

Pat Wall 

John Feely 

1. Apologies 


Mary-Clare O‟Sullivan 


Padraig Rushe 

Brian Daly 

Pat Farrell 


Eamon Deasy 

Jim Byrne 

Fergus Murphy 



D/JEI 

D/Finance 

D/Finance 


Revenue 

Central Bank 

FSI 



BOAML 

State Street 



CITI 

IFIA 

IDA 

ISE 


PWC 

Willis 

Central Bank 


IDA Ireland 


KPMG 

IBF/FIBI 


Revenue 

Revenue 

FSI 


The Minutes of the meeting of 3 April 2012, as circulated, were agreed.

3. Regulation (incl.Central Bank/Industry engagement) 

Pat Brady reported that the Central Bank and Industry are continuing to engage, reporting 

progress with a number of substantive issues addressed. There was recognition of the many 

challenges for the international financial services industry in the difficult global environment 

and the ability to fulfil the objectives in the Strategy. 

4. Presentation by Matthew Elderfield to CHG in July 

The meeting was informed that Matthew Elderfield will make a presentation to the CHG on 

the Central Banks Strategy 2013-2015 on Tuesday 10 July at 3.30pm. 

5. D/Finance Update 

Ann Nolan reported that the Department had established an internal IFSC Working Group to 

enhance the Department‟s engagement with the Clearing House Group and Industry. 

AIFMD 

The Department has been in contact with the EU Commission. The Commission indicated 

that it was open to amendments to Article 85(d) to allow the continued delegation of 

significant numbers of functions by fund managers where the manager retains an appropriate 

level of oversight and control. 

They had also discussed the depositary liability issues and submitted proposals jointly with 

the UK and Luxembourg. The Commission is examining the proposals and it is expected they 

will make their views known in the next few weeks. 

Open Ended Investment Company/SICAV Bill 

Industry is currently working on preparing a submission regarding the Draft Heads for 

consideration by the Department. 

The timetable is considered ambitious. Even if Heads are quickly agreed the Office of the 

Attorney General and the Oireachtas will have competing demands. The Department of 

Finance will also be under pressure before during and after the presidency next year. 

Industry have offered any assistance which is appropriate in preparing the Heads of a Bill 

which will require close consultation between the Central Bank, D/JEI and D/Finance before 

Government approval is sought for the Heads of Bill. 

CRD IV Update 

Following the unanimous support for the Danish Presidency compromise text at the ECOFIN 

meeting on 15 May, CRD IV is currently at Trialogue stage, the process where the European 

Parliament, the European Commission and the Danish Presidency engage in negotiations to 

achieve a first reading agreement. The European Parliament‟s ECON committee voted in 

favour of rappateur Othmar Kara‟s‟ report on 14 May. 

Discussions are continuing at Trialogue stage with a vote in the European Parliament on the 

proposal scheduled for early July. This is one of the priorities of the Danish Presidency. 

Aim of the Proposal 

The legislative package published by the European Commission on 20 July 2011 proposes to 

implement Basel III in EU law by a recast of the existing Capital Requirements Directive into 

a new Directive and a Regulation.

The aim of the proposal is to reflect the Basel III capital proposals, to introduce new 

sanctions for non-compliance with prudential rules, corporate governance and remuneration. 

These changes are due to be implemented from 1 January 2013 (there will be transitional 

arrangements for some elements). 

The proposal changes the balance of home-host supervisor responsibilities concerning 

liquidity supervision of branches. Under the current CRD, host supervisors are responsible 

for liquidity supervision, pending further coordination. CRD IV will assign this responsibility 

to home supervisors, but with safeguards to ensure that host supervisors have full access to 

information gathered by home supervisors. 

General Tax Update 

D/Finance has started a consultation process in respect of Budget and Finance Bill 2013. 

Meetings have taken place with the Banking and Treasury Tax Subgroup and meetings are 

scheduled with the Insurance and Funds Groups over the coming weeks. 

Presidency of the EU will be a significant priority for D/Finance over the course of the next 

year – there are a number of high-profile tax dossiers – CCCTB, FTT, and VAT. The 

Department met with the European Commission in March of this year to kick off the 

planning process and further meetings at Heads of Unit Level are planned for July. 

FTT 

The Government position is clear. Any tax on financial transactions would be best applied on 

a wide international basis to include the major financial centres. If such a tax cannot be 

introduced on a global basis, it would be better if it were introduced on an EU-wide basis, as 

this would prevent any distortion of activity within the Union. There is concern if a FTT was 

introduced, it could affect the financial services industry, especially in the IFSC, and lead to 

some activities moving abroad. 

D/Finance has consulted widely with the financial services industry on the implications of the 

FTT proposal, including a round-table meeting on 5 March. The Department is fully aware 

of industry concerns that the proposal may lead to loss of business and employment, 

particularly if it is not introduced on a global or EU-wide basis. 

FATCA – Foreign Account Tax Compliance Act 

Five Countries - Germany, Italy, U.K., Spain and France, together with the US issued a joint 

statement, in February, to the effect that they would explore a common approach to FATCA 

implementation through domestic reporting and reciprocal automatic exchange and based on 

existing bilateral tax treaties. In essence, country-to-country agreements would replace the 

agreements between the U.S. and the foreign financial institutions. 

Following the release of that statement, Revenue has made contact with the U.S. Treasury 

and is now in discussions with the U.S. with a view to implementing a country-to-country 

agreement with the U.S. in relation to FATCA. 

EU Wide Bank Resolution Proposals 

D/Finance mentioned the European Commission proposal for a Directive to establish a 

framework for the recovery and resolution of credit institutions and investment firms

The Commission characterises the overriding objective of the framework as ensuring that 

institutions in difficulties can be allowed to fail without risk to financial stability while 

avoiding costs to taxpayers. 

6. Strategy Progress and Monitoring 

Brendan Bruen and the Chairs of the IFSC Working Groups gave brief updates in respect of 

Strategy implementation. The Chair indicated that a review of progress on the Strategy would 

be undertaken by the Public Sector representatives and a meeting organised in the coming 

weeks. 

7. New Business -Green IFSC 

Communications & Marketing 

Following the recent launch of the Green IFSC Global Green Asset Management network, 

initiative on-going marketing and communications activity has led to significant, positive 

media attention domestically and internationally among mainstream, green enterprise and 

financial services publications. 

Private Sector response 

As a direct result of increased marketing/communications activity, Green IFSC is receiving 

an increased number of queries from international green finance players seeking to learn 

more about Ireland‟s offering in this space. Green IFSC Steering Group private sector 

members are assisting with query response. 

Education/Skills 

Supported by the Summit Finuas Network, education/skills pillar will launch the new DCU 

MsC in Sustainable Energy Finance on 25 June in the Convention Centre. Green finance 

educational suite of products now stands at three – DCU MsC in Sustainable Energy Finance, 

DCU Grad Cert in Sustainable Energy Finance and UCD Smurfit MsC in Energy & 

Environmental Finance. 

Tax/Finance 

Hosted by PwC, Green IFSC‟s inaugural Green Tax Breakfast briefing was held on 2 May. 

With a capacity audience of 127 finance and enterprise leaders, this event offered an 

opportunity to brief attendees on recent green finance supportive tax measures. 

“Greening the IFSC” 

Supported by SEAI, the measurement of the IFSC‟s carbon footprint, under the “Greening 

the IFSC” continues. To date, 12 companies have signed up to this specific project 

representing 8,000 plus of IFSC employees. 

State agencies continue to play an important role in supporting Green IFSC efforts. Recent 

meetings have been held with IDA focussed on collaboration across 

marketing/communications activity, with follow up scheduled mid-June. Enterprise Ireland 

meeting is currently being scheduled. 

Initiative momentum is being maintained and accelerated as a result of mandate certainty.

8. International Engagement and Marketing 

Michael Stapleton said that John Bruton, in conjunction with IDA and IFSC Ireland, had a 

series of bilateral meetings with senior executives up to CEO level, of both existing clients 

and major target companies in the US in March. 

IFIA had staged two major platform events and other networking events in New York and 

Boston. 

The Taoiseach‟s visit to China had also given the IDA and Industry the opportunity to meet 

with a number of Chinese banks and interested parties in the aviation finance sector. 

9. Date of next meeting 

The next meeting takes place on 25 September at 3.30pm.

IFSC Clearing House Group 3 April 2012 

Department of the Taoiseach, Italian Room at 5pm 

Attendance 


Mary Clare O‟Sullivan 


Michael Stapleton 

John Murphy 

Ann Nolan 

Tom Young 

Eamonn O‟Dea 

Jim Byrne 

Patrick Brady 

Brendan Bruen 

Padraig Rushe 

Brian Daly 

Tim Hennessy 

Julie Sinnamon 

Pat Farrell 

Peter Keegan 


David Guest 


John Travers 

David Fagan 

Tony Golden 

Gary Palmer 

Denis Curran 


Breda Power 

1. Apologies 

Fergus Murphy 

John Feely 



Paul McGowan 

Pat Wall 




IDA Ireland 

D/JEI 

D/Finance 


Revenue 

Revenue 

Central Bank 

FSI 


KPMG 



IBF/FIBI 

BOAML 

State Street 



Chair, Green Evaluation Team 


CITI 

IFIA 

IDA 

ISE 

D/JEI 

FSI 

Attain 

Central Bank 

IDA Ireland 


PWC 


The Minutes of the meeting of 18 January 2012, as circulated, were agreed. 

The Chair introduced Mary Clare O‟Sullivan, D/Taoiseach, to her first meeting of the Group.

The Chair thanked Gary Palmer of the Irish Funds Industry Association for the excellent 

contribution he had given over the years to both the Funds Working Group and the Clearing 

House Group. On behalf of the Group he wished Gary every success in the future. 

3. Department of Finance update 

Ann Nolan updated the Group on a number of issues: 

The Finance Act passed through all stages of the Oireachtas and was signed into law by the 

President. The Act contains 13 sections which introduce 21 individual measures to support 

the ambitious jobs targets contained in the IFSC Strategy. 

In summary, the measures enhance the competitive position of the sector through: 

o Reducing double taxation in the corporate treasury and aircraft leasing sectors, 

o Providing clarity around the tax treatment of complex financial transactions in 

terms of stamp duty in particular, 

o Addressing tax issues arising for investment funds due to the UCITS IV Directive 

which was implemented on 1 July 2011, and 

o Further easing the administrative burden in relation to non-resident investors in 

Irish investment funds. 

Taken together with the Special Assignee Relief Programme and Foreign Earnings 

Deduction, the measures represent a significant package which will support the 

competitiveness of the industry and hopefully assist in creating new jobs. 

Financial Transactions Tax 

Opinion on the FTT is polarised, and there could be considerable discussion on the subject at 

the upcoming Informal ECOFIN. A clearer picture may emerge after that meeting. 

D/Finance position on the proposals for an FTT is clear. Any tax on financial transactions 

would be best applied on a wide international basis to include the major financial centres. If 

such a tax cannot be introduced on a global basis, it would be better if it were introduced on 

an EU-wide basis, as this would prevent any distortion of activity within the Union. The 

major concern is that, if an FTT is introduced, it could affect the financial services industry, 

especially in the IFSC, and lead to some activities moving abroad. 

D/Finance has consulted widely with the financial services industry on the implications of the 

FTT proposal, including most recently a round-table meeting on 5 March. The Department is 

fully aware of industry concerns that the proposal may lead to loss of business and 

employment, particularly if it is not introduced on a global or EU-wide basis. 

FATCA - Foreign Account Tax Compliance Act 

The European Commission had been negotiating with the US on behalf of all member states 

until a group of five countries (France, Germany, Italy, Spain and UK) broke away and issued 

a joint statement with the US announcing their intention to explore a common approach to 

FATCA implementation through domestic reporting and reciprocal automatic exchange and 

based on existing bilateral tax treaties.

What is envisaged is that the relevant financial institutions in those member states would 

report to their national Revenue authorities in respect of US investors. The national Revenue 

authorities would then deal direct with the IRS in the automatic exchange of information. 

The issue has been discussed with the relevant representatives of the IFS industry and the 

industry favours an approach whereby Ireland would also seek to enter into a bilateral 

agreement with the US whereby reporting from Irish financial institutions would be to the 

Irish Revenue who would then exchange information directly with the IRS. 

Jim Byrne, Revenue, reported that following the issue of the Joint Statement by the U.S., 

Germany, Italy, U.K., Spain and France, Ireland decided to initiate contact with the U.S., 

with a view to exploring a common approach to FATCA implementation through domestic 

reporting and automatic exchange and based on existing bilateral tax treaties. 

Revenue has made contact with the U.S. Treasury and is now in discussions with U.S. 

The U.S. have outlined that they are not engaging in negotiations with individual States but 

are developing a model global agreement. Ireland is one of a number of countries with which 

discussions in relation to a model agreement are ongoing. 

The model agreement will not alter or amend the obligation to identify or report certain 

information under FATCA but will outline an alternative pathway for reporting FATCA. 

The model agreement is expected by the end of June. 

4. Regulation 

Regarding Central Bank/Industry engagement, the industry side is finalising its submission to 

the Central Bank and expects to meet with the Bank soon. A more substantive report will be 

made to the next CHG meeting. 

AML continues to be an area where further engagement with the Central Bank and D/ 

Finance would be of benefit. Industry is currently working towards an AML workshop with 

the Central Bank, where industry's proposals regarding areas where concerns arising from 

AML inspections will be considered. Additionally, the AML workshop will also look to 

agree a framework/procedure for a risk based assessment of third parties/jurisdictions 

pending a legislative amendment to the CJA 2010 to provide for this. 

Following this workshop it is proposed that the Investment Funds Sectoral Guidelines will be 

revised and updated to reflect the proposals agreed during the workshop, following which the 

revised guidelines will be shared with the Central Bank for review/agreement. 

With regard to reliance on third parties in jurisdictions where banking secrecy exists, it was 

noted that while other jurisdictions appear to have similar requirements when relying on third 

parties in jurisdictions with banking secrecy, the challenges of accepting undertakings from 

such third parties, which reference local secrecy laws, were not so acute in other jurisdictions. 

It was noted that the D/Finance have written to the Commission to understand how this issue 

was being addressed in other Member States. 

5. New Business 

Green IFSC

John Travers presented the findings of the independent Review Group which was established 

to undertake an evaluation of the Global Green Interchange (GGI) Report and the 

implementation plan contained therein and report back to Government. 

Ultimately the Review Document has recommended against one of the key recommendations 

of the original GGI report which was the establishment of an International Carbon Registry in 

Dublin. However, the Review does highlight a number of other positive elements of the 

Green IFSC Initiative. 

With regard to the Green Finance proposals (Pillar 2), the Evaluation Group agreed that there 

are significant investment location opportunities for Ireland in this space and that these are 

best pursued on the basis of agreed partnership arrangements between the private sector and 

the development agencies. Both sectors are active in this space at present but, even taking 

account of the inherent differences in their roles, their respective activities are somewhat 

more fragmented than they should be if Ireland Inc's promotional activities are to be 

optimised. There is a need for an agreed, joint promotional approach. Some of this work will 

be industry-driven, some will be agency/Government-driven and some will involve shared 

activities. 

In relation to the Education, Skills and Innovation aspects of the report (Pillar 3) the 

Evaluation Group considered that these are well articulated and agreed that ongoing work 

needs to be further enhanced and developed to create a pool of professional expertise which 

will meet the requirements of investors in green finance and associated projects in 

consultation with training bodies, with the third- level education providers and with the 

Department of Education and the HEA. 

Regarding the proposals in respect of carbon markets (Pillar 1: the establishment of a 

sovereign-backed International Carbon Standard (ICS) and a Dublin International Voluntary 

Offset Registry/DIVOR by the Government) the Evaluation Group do not consider that the 

case for such initiatives, radical and innovative as they are, as set out in the report, are 

sufficiently robust to allow their endorsement by the Group. The reasons for that conclusion 

are set out in detail in the report of the Evaluation Group. 

Following Mr Travers presentation there was a general discussion on the next steps. It was 

agreed that the development agencies, IDA and Enterprise Ireland, should meet as a matter of 

urgency with representatives of the Group to progress the required partnership arrangements 

on the promotion and development of the green finance initiatives as advocated by both the 

Evaluation Group and the Group. It was agreed that any further consideration of the 

ICS/DIVOR proposals be "parked" pending progress on these initiatives. 

Tony Golden, Citi, said that Investment funds which invest in 'Green or Environmental 

Companies' and which are traded and listed on a regulated stock exchange are no different to 

administering any other UCITS or regulated fund. Investment funds which invest in 'Carbon 

Credits' or indeed start up early stage finance green companies may be a little more complex 

and may fit more into a non-UCITS or QIF type fund. However, provided there are no issues 

in obtaining prices for these type securities, they can be easily administered. 

He felt that from a pure 'custody and clearing perspective', there is a possible opportunity. 

The clearing and settlement aspects of carbon credit trading, as well as the issuance and 

paying agency aspects which relate to a carbon credit type security is perhaps an activity

where IFSC could carve out an opportunity as a centre of excellence. In other words, while 

there may/may not be a Carbon credit trading opportunity, there could be opportunities for 

custody, clearing, issuance and paying agency activities for the IFSC. Citi has an offering 

currently available. 

David Guest reported that progress on the Green IFSC initiative had continued during the 

evaluation period in respect of the marketing of green financial services and green finance 

education. He noted that Michael Sludds from Department of an Taoiseach would be joining 

the Green IFSC Steering Group and also noted the support given by an Taoiseach to the 

Green Asset Management Global network initiative at recent events in the US and China. 

6. International Engagement and Marketing 

Michael Stapleton said that John Bruton, in conjunction with IDA and IFSC Ireland, had a 

series of bilateral meetings with senior executives up to CEO level, of both existing clients 

and major target companies in the US in March. 

IFIA had staged two major platform events and other networking events in New York and 

Boston. 

The Taoiseach‟s visit to China had also given the IDA and Industry the opportunity to meet 

with a number of Chinese banks and interested parties in the aviation finance sector. 

7. Strategy Update from Working Group Chairs 

Asset Management Working Group 

Robert Richardson reported that the Group had completed a first draft of its strategy 

document for input into the overall IFSC Strategy. 

Insurance Working Group 

Tim Hennessy informed the meeting that the industry members of the Insurance Working 

Group had met on two occasions to develop their views on possibilities to further develop 

employment opportunities within existing markets along with opportunities for new entrants. 

A matrix across the various re/insurance industry sectors was developed encompassing 

product, jurisdiction, regulatory, tax etc. The broad themes are consistent with Insurance 

opportunities for growth included in the 2011-16 IFSC Strategy document. Meetings had 

also been held with FSI and the Insurance Working Group output will be incorporated into 

the overall document being coordinated by FSI. 

Banking and Treasury Working Group 

David Guest reported that a Working Group was progressing with an initiative with 

participants in the Private Equity/Venture capital sector. The objective of the initiative is to 

determine whether marketing and development of the IFSC can be expanded to promote 

growth in this sector together with the established IFSC sectors. The Banking and Treasury 

Group was also monitoring developments in payment services, intellectual property 

commercialisation and Islamic finance to identify links and synergies with existing CHG 

initiatives.

Funds Working Group 

Gary Palmer said that a matrix of action points for the Funds industry had been drawn up and 

a number of sub-group meetings had taken place to discuss implementation. 

Pension Funds Working Group 

A Pension Funds Focus Group is scheduled for 22 May to discuss the future potential for 

cross-border pensions and asset pooling. 

8. Date of next meeting: 

The next meeting of the Group takes place on Thursday 7 June at 8.30am.

IFSC Clearing House Group 18 January 2012 

Department of the Taoiseach, Room 308 at 10am 

Attendance 




John Murphy 

Ann Nolan 

Gary Tobin 

Pat Casey 

Geoffrey Keating 

Tom Young 


Jim Byrne 

Patrick Brady 

Brendan Bruen 

Padraig Rushe 

Brian Daly 

Paul McGowan 

Tim Hennessy 

Joe Breslin 

Pat Farrell 

Peter Keegan 

Pat Wall 


David Guest 


John Travers 

David Fagan 

Tony Golden 

Gary Palmer 

1. Apologies 

Fergus Murphy 

John Feely 




Breda Power 



IDA Ireland 

D/JEI 

D/Finance 

D/Finance 

D/Finance 



Revenue 

Revenue 

Central Bank 

FSI 


KPMG 




IBF/FIBI 

BOAML 

PWC 

State Street 





CITI 

IFIA 

FSI 

Attain 

Central Bank 

IDA Ireland 

ISE 

D/JEI 

The Chair welcomed the newly appointed Secretary General of D/JEI, John Murphy, to the 

Group.


The Minutes of the meeting of 24 November 2011, as circulated, were agreed. 

3. IFSC Strategy Implementation 

Brendan Bruen updated the Group on progress on the IFSC Strategy. The Working Groups 

were preparing implementation plans for the end of February, and work was also progressing 

on cross-sector elements. 

The Chairs of the Working Groups updated the Group on specific issues under consideration. 

The intention is to present work on a consolidated list of action areas at the next Group 

meeting. 

4. Green IFSC Evaluation process 

Kieran Donoghue reported that the Evaluation Group had met on a number of occasions 

since being established at the end of September 2011. The Group were reviewing the draft 

findings of the Steering Group implementation plan and expected to report back to 

D/Taoiseach shortly. 

The Chair of the Evaluation Group, John Travers, would meet with Martin Fraser to inform 

him of the Group‟s findings. 

5. EU 

(a) Recent Developments 

D/ Finance reported that: 

The European Commission published a proposal on 30 September for a Directive on a 

common system of financial transaction tax. 

The Minister has indicated that Ireland does not agree to such a tax being introduced 

except at a global level or at least by all 27 Member States of the European Union, 

including the United Kingdom. 

The Taoiseach reiterated this view during the British-Irish Council meeting in Dublin in 

January 2012. 

The Department of Finance hosted a roundtable discussion on the FTT in October 2011 

and has sought input from each of the CHG subgroups in terms of the potential impact of 

the FTT on their sector. 

The proposals are being discussed at EU Council Working Group level and the first 

meeting dealing with the text of the proposal took place on the 3 January. 

The next meeting is scheduled for March 2012 and D/Finance intends to host another 

roundtable discussion with the IFS industry in advance of that meeting. 

(b) Presidency Preparations 

D/Finance gave a comprehensive overview indicating anything they anticipate will arise in 

the international financial services area during the Irish Presidency:

2012 sees the Danish and Cypriot Presidencies. This will form the backdrop to the Irish 

Presidency. 

Danish Presidency 

The Danes have identified a number of priorities in Financial Services and have plans to 

make progress on the 10 Financial Services dossiers currently under ECOFIN and the 2 

Financial Services files which will fall under the Competiveness Council. 

They hope to secure either a first or second reading agreement with the European Parliament 

on the following dossiers: 

i. Mortgage Credit Directive 

ii. CRD IV 

iii. Deposit Guarantee Schemes 

iv. Omnibus II 

v. Investor Compensation Schemes 

vi. EMIR 

vii. Venture Capital Funds (Competitiveness Council) 

viii. Social Entrepreneurship Funds (Competitiveness Council) 

Denmark hopes to get an agreed general approach at Council on the Credit Ratings Agencies 

dossier and on the Transparency dossier. This would then leave the Trilogue negotiations to 

the Cypriot Presidency and possibly the Irish Presidency. 

It is the Danish intention on the Central Securities Depositories and MIFID and Market 

Abuse to produce a Progress Report at the end of their 6 months. These two files will then 

fall into the Irish Presidency at Trilogue stage, if not finalising negotiations on a common 

approach. 

EU Commission proposals 

Denmark will also deal with a number of forthcoming proposals from the Commission if and 

when they are adopted: 

Crisis Management (Bank recovery and resolution) – end January/early February. 

Discussions within the Commission are being finalised but there remains a problem regarding 

choosing a date to release this. A worsening of the banking situation may lead to further 

delay. 

Central Securities Depositories – end January/early February 

Protection of Investors (PRIPS) – end February/early March 

Insurance Mediation Directive – end February/early March 

UCITS V – April 

AIFMD LII – Quarter 2 

Other matters 

Work is also ongoing on the non-legislative file on Shadow Banking. The Commission will 

put forward a communication on this by end March and will be holding a conference around 

27 April

Cypriot Presidency 

Negotiations on the following files will be initiated by the Cypriot Presidency and will form 

part of the Irish Presidency agenda: 

Directive on legal certainty of securities holding and transactions (SLD) 

Institutions for Occupational Retirement Provisions (IORP) – The Department of Social 

Protection take the lead on this file. 

Close-out Netting 

Irish Presidency planning 

The agenda is evolving and will become clearer as the Danish and Cypriot presidencies 

progress. 

Discussions with the Commission and Trio partners [Lithuania and Greece] will be important 

part of the decision making process on priorities. 

The Minister for Finance and the Government will decide on our priorities. 

Trilogue discussions with European Parliament will be a key part of the Irish Presidency. 

D/Taoiseach updated the Group on Presidency preparations and priorities for the Irish 

Presidency. At the last two IDCCP meetings in November and December 2011, Departments 

highlighted emerging issues and draft legislation that is likely to figure on Ireland‟s 

Presidency agenda in 2013.These discussions will feed into the Trio and national Presidency 

programming process. Regular meetings are taking place with Attachés focussing on 

emerging sectoral priorities and this work will also contribute to the clearer definition of Irish 

Presidency themes. The IDCCP will continue to evaluate and refine the Presidency priorities 

and to assess emerging overall themes. 

It was also reported that the Presidency would largely be based in Dublin and that it provided 

a unique promotional opportunity for Ireland to assist in rebuilding Ireland‟s reputation in 

Europe and internationally. 

6. Budget and Finance Bill process 

In December‟s Budget, the Minister announced the introduction of a new Special Assignee 

Relief Programme and a new Foreign Earnings Deduction for temporary assignments to 

BRICS countries in order to help address this issue. 

The Minister also reiterated the Government‟s commitment to the 12.5% corporate tax rate 

and announced that Finance Bill 2012 would contain a further package of measures to 

support the IFS industry. 

The Finance Bill will be published on 9 February. 

As mentioned at the November 2011 CHG meeting, the Tax Policy Unit in the Department of 

Finance has been working closely with the different industry subgroups in the run-up to the 

Finance Bill and three further meetings took place in December and January.

D/Finance pointed out that when considering industry proposals, they must also be mindful of 

Ireland‟s tax reputation. 

In this regard, in relation to the Funds Industry proposal for the introduction of a bespoke tax 

regime for a new type of investment vehicle – an „Alternative Investment Company‟ 

D/Finance said they had to consider the broader implications of individual proposals in terms 

of their potential impact on Ireland‟s reputation. 

It was the Department‟s view that the introduction of such a vehicle could be viewed 

negatively by our Treaty partners as overly aggressive and as a result, the proposal was not 

being considered for the Finance Bill. 

The Department understood the industry‟s disappointment but highlighted that virtually all of 

the other issues contained in the Funds Industry pre-Budget submission were being 

progressed and that the Department is working with the Funds industry to develop a new 

corporate funds structure in Ireland. 

There are between 15 and 20 individual measures under consideration. The aim of a number 

of these measures is to simplify the tax treatment applying to complex financial transactions 

in order to make it easier to do business. 

7. Report on Central Bank / industry engagement 

Discussions are ongoing between the Central Bank and industry, and meetings will take place 

over the coming weeks. 

8. Marketing IDA/IFSC Ireland 

IDA reported that the 2012 marketing programme was underway. A number of forthcoming 

international events involving the Taoiseach, the IDA and IFSC Ireland were outlined. IDA 

was cautiously optimistic on the prospects for 2012. 

Martin Fraser informed the meeting that a high profile inward visit from China was 

earmarked for February and that the Taoiseach would visit Davos in February and a number 

of cities in the US as part of the St Patricks Day celebrations. 

9. AOB 

John Murphy said that a Jobs Action Plan was being finalised within D/JEI and would be 

announced shortly. He also mentioned that consideration was being given restructuring 

within the Department and its Agencies. 


The next meeting takes place at 5pm on Tuesday 3 April 2012 in the Italian Room, Ground 

Floor.

IFSC Clearing House Group 24 November 2011 


Attendance 





Ann Nolan 

Gary Tobin 


Jim Byrne 


Patrick Brady 

Breda Power 

Brendan Bruen 

Tom Young 

Padraig Rushe 

Brian Daly 

Paul McGowan 

Tim Hennessy 

David Fagan 

Joe Breslin 

Pat Farrell 

Peter Keegan 

Pat Wall 



David Guest 


John Travers 

1. Apologies 

Fergus Murphy 

Tony Golden 

John Feely 

Gary Palmer 



IDA Ireland 

IDA Ireland 

D/Finance 

D/Finance 

Revenue 

Revenue 

Central Bank 

Central Bank 

D/JEI 

FSI 

FIBI 


KPMG 





IBF/FIBI 

BOAML 

PWC 

ISE 

State Street 

Ulster Bank 



FSI 

CITI 

Attain 

IFIA 


The Minutes of the meeting of 14 July 2011, as circulated, were agreed. 

3. IFSC Strategy Implementation 

Brendan Bruen updated the group on implementation of the IFSC strategy. A proposed roadmap 

for Q1 2012 was circulated outlining a number of actions. The goal was to tie down the 

high-level objectives that had been agreed to specific initiatives, timelines and ownership. In

areas where clear responsibility lies with an existing body or working group, this would be 

formally delegated. 

The Working Groups were being asked to complete work plans by the 28 February on aspects 

of the strategy that were sector specific. Cross-sectoral strands were also on-going, and a 

consolidated plan would be prepared for the March meeting of the group. In implementing 

the strategy, consideration will be given to the establishment of standing cross-sector groups 

where appropriate, if necessary adjusting the meeting frequency of the sector working groups 

to keep workload constant. 

Timelines were agreed as: 

By Jan 31 – Industry submission to Central Bank 

By Jan 31 – Go-live of IT resource 

By Feb 28 – Each Working Group to document implementation and ownership plans 

and provide to the Department of the Taoiseach. 

By Feb 28 – Work plans (supported by workshops if necessary) on 

o Education and skills 

o Tax priorities 

o Shared services, ICT/FS convergence 

o Targeting of Asian market 

o Coordination of international engagement and marketing 

March - Broad industry workshop involving CHG and Working Groups to review 

progress and identify outstanding items. 

4. Green IFSC Evaluation process 

David Guest confirmed that he and other members of the Green IFSC Steering Group were 

scheduled to meet the Chairman of the review panel, John Travers, on 28 November. 

The Review panel is to meet twice in December including a meeting with the full Steering 

Group on 20 December. He also emphasised the importance of completing the review process 

within a reasonable timeframe, ideally by end January 2012. 

5. Budget and Finance Bill process 

Ann Nolan reported to the meeting that: 

The Tax Policy Unit in the Department of Finance has met with the tax subgroups of the 

various IFSC sectors: funds, banking and treasury, insurance, Green IFSC and international 

asset financing in the run up to the Budget and Finance Bill. 

In total more than 10 separate meetings have so far taken place. 

A specific paper on tax issues impacting on the IFSC prepared by the Department of Finance 

was discussed recently by the Government's Tax Strategy Group. 

Many of the issues raised by the various tax subgroups were sector specific and these are 

being pursued bilaterally in the context of the forthcoming Finance Bill which will be 

published early February 2012. 

Some issues raised cut across different IFSC sectors. The most prominent issue has been in 

relation to SARP - the Special Assignee Relief Programme.

It is hoped that a significant package of IFSC supportive measures will be included in the 

Finance Bill. 

Obviously, given the current state of the public finances, the focus has been on progressing 

issues with little or no cost for the Exchequer. 

The Budget speech is currently in preparation. The speech will once again outline the 

Government's absolute commitment to the 12.5% Corporation tax regime. 

6. Report on Central Bank / industry engagement 

Matthew Elderfield reported that a very useful meeting had taken place between the senior 

regulatory management team of the Central Bank and senior industry representatives in 

September at which the Central Bank set out its strategy for 2012, including setting out the 

banking and supervisory challenges, rolling out the new supervisory approach (PRISM) and 

reforming supervision and regulation. 

Pat Farrell said that industry would send in a formal response before January 31 2012. 

Matthew Elderfield indicated that bilaterals with industry would continue in the future. The 

Chairman concluded that this was a useful exchange and the bilaterals were a good forum for 

discussing regulation specific issues. 

7. Marketing IDA/IFSC Ireland 

IDA Ireland provided an update on the pulse of their international financial services business; 

- Activity within the Sector is strong, based on site visits, investor queries and investments 

won; 

- Overseas marketing activity continues apace and has been enhanced by the effective 

collaboration with IFSC Ireland; 

- Client feedback on the various platform events put in place with IFSC Ireland has been very 

positive and further events are planned for 2012 in Frankfurt, New York, Brussels and 

London; 

- IDA plans to allocate additional resources to its financial services Division during 2012 

through internal redeployment; 

- The recent joint venture with the funds industry whereby IDA's overseas office network will 

act as representative offices for the Sector is a further positive development. 

Pat Farrell updated on the activities of IFSC Ireland. There were two important dimensions 

to John Bruton‟s programme in 2011; overseas promotional visits to target markets in 

collaboration with IDA Ireland and industry representative bodies, bilateral meetings both 

here and overseas with firms interested in making new or additional investment into Ireland. 

An important complimentary aspect to John‟s work was his strong articulation of the Ireland 

Inc story as an integral part of the overall messaging. 


The next meeting takes place at 10am on Wednesday 18 January 2012.

IFSC Clearing House Group 14 July 2011 


Attendance 

Dermot McCarthy (Chair) 



Gary Tobin 

Jim Byrne 

Bob Keane 

Fergus Murphy 

Brendan Bruen 

Tony Golden 

Padraig Rushe 

Brian Daly 

Paul McGowan 

Tim Hennessy 

David Fagan 

Joe Breslin 

Pat Farrell 

Patrick Brady 

Peter Keegan 

Pat Wall 

Aileen O‟Donoghue 

Breda Power 


David Guest 


Gary Palmer 

1. Apologies 

Kevin Cardiff 


William Beausang 

Neil Ward 


John Feely 




IDA Ireland 

D/Finance 

Revenue 

D/ETI 

FSI 

FSI 

CITI 


KPMG 





IBF/FIBI 

Central Bank 

BOAML 

PWC 

ISE 

D/JEI 

State Street 

Ulster Bank 


IFIA 

D/Finance 

Central Bank 

D/Finance 

BMO 

IDA Ireland 

Attain 

ISE 


The Minutes of the meeting of 23 June 2011, as circulated, were agreed. 

3. Adoption of Strategy Document 

In relation to the IFSC Strategy, the Chair noted that the document agreed by the Group at its 

previous meeting had been finalised and approved by Cabinet. Printed versions of the

document were circulated at the meeting and would be made available online later in the day. 

The Taoiseach would be formally launching the Strategy and holding a press conference 

immediately after the conclusion of the meeting. 

4. AOB 

Tim Hennessy noted that further discussions had taken place between industry and the 

Department of Finance in relation to a possible call on the Insurance Compensation Fund 

arising from the failure of Quinn Insurance. The compatibility of the levy provisions with the 

Non-Life Directive was in question and concerns had been raised at an EU level by both DG 

Internal Market and DG Competition. 

The Chair indicated that this would be his last meeting in the role, and thanked the Group for 

their work. Brendan Bruen expressed thanks on behalf of the industry to the Chair and a 

presentation was made to the Chair in appreciation of his work and dedication over many 

years. 

5. Next Meeting 

The next meeting takes place at 8.30am on Thursday 8 September, 2011.

IFSC Clearing House Group 23 June 2011 


Attendance 




Gary Tobin 

Jim Byrne 

Bob Keane 

Fergus Murphy 

Brendan Bruen 

Tony Golden 

Padraig Rushe 

Brian Daly 

Paul McGowan 

Tim Hennessy 

David Fagan 


Pat Farrell 

Patrick Brady 

Peter Keegan 

Pat Wall 

Aileen O‟Donoghue 

Breda Power 


1. Apologies 


Gary Palmer 

Kevin Cardiff 



Neil Ward 


John Feely 


David Guest 



IDA Ireland 

D/Finance 

Revenue 

D/ETI 

FSI 

FSI 

CITI 


KPMG 





IBF/FIBI 

Central Bank 

BOAML 

PWC 

ISE 

D/JEI 

State Street 


IFIA 

D/Finance 

Central Bank 

D/Finance 

BMO 

IDA Ireland 

Attain 

ISE 

Ulster Bank 

The Group observed a minutes silence in respect of the late Mr Brian Lenihan T.D., Mrs 

Betty Tobin, Mrs Molly O‟Dea and Mr Liam Donlon 


The Minutes of the meeting of 12 May 2011, as circulated, were agreed.

3. Marketing and Messaging of the industry 

Pat Farrell and IDA reported that an update on the IFSC Ireland programme of events is to be 

provided and circulated to the Group. 

A set of proposed events with John Bruton (IFSC Ireland) are being considered for 2012. 

4. Adoption of Strategy Document 

The Chair proposed the final draft of the strategy document as circulated for adoption on 

behalf of the Group and for submission to Government. Two amendments of an 

uncontroversial nature were noted as pending in respect of educational links and payments. 

Brendan Bruen thanked industry and public sector members of the group for their assistance. 

He noted that further work was now being undertaken to plan implementation and ownership 

of the various elements of the strategy. The Chair thanked the Group for their contribution in 

bringing the Strategy to completion. 

The proposal to adopt the strategy was agreed unanimously and the Chair indicated that it 

would be submitted to Government in the coming weeks. 

5. Green IFSC 

Padraig Rushe reported that the implementation plan in draft form was now with the IDA and 

EI for validation. He said it was a comprehensive document covering all aspects of the 

transition to a global low-carbon economy. 

Kieran Donoghue acknowledged that the IDA received the document on 10 June and that the 

intention was to establish an Expert Group with international expertise to evaluate the 

proposal and funding by September 2011. 

6. AOB 

Tim Hennessy updated the meeting on the Insurance Compensation Fund, the concern of the 

industry that the statutory basis of the Fund no longer reflects the reality of the non-life 

insurance industry established here, and the severe competitive damage that the imposition of 

the proposed levy would have on the international industry. It was noted that since the last 

CHG meeting, the Taoiseach had written to Minister Noonan highlighting the concerns of the 

international non-life insurance industry. 


The next meeting takes place at 9.30am on Thursday 14 July, 2011.

IFSC Clearing House Group 12 May 2011 


Attendance 




Gary Tobin 

Jim Byrne 

Bob Keane 

Fergus Murphy 

Brendan Bruen 

Tony Golden 

Padraig Rushe 


Brian Daly 

Paul McGowan 

Tim Hennessy 

David Fagan 

Gary Palmer 


Pat Casey 

Pat Farrell 

David Guest 

Patrick Brady 

1. Apologies 

Kevin Cardiff 



Pat Wall 

Neil Ward 



John Feely 


Peter Keegan 

Breda Power 



IDA Ireland 

D/Finance 

Revenue 

D/ETI 

FSI 

FSI 

CITI 



KPMG 




IFIA 


D/Finance 

IBF/FIBI 

Ulster Bank 

Central Bank 

D/Finance 

Central Bank 

D/Finance 

PWC 

BMO 

State Street 

IDA Ireland 

Attain 

ISE 

BOAML 

D/JEI 


The Minutes of the meeting of 23 March 2011, as circulated, were agreed.


Following a full calendar of activity year to date, there are now confirmed IFSC Ireland 

events in London and Paris in June and September respectively. Additional opportunities are 

being assessed, with a view to trips to Asia and South America in Q3 / Q4 2011. The goal is 

to have engagements planned 6-9 months in advance, ensuring opportunities are maximised 

and relevant meetings can be secured. 

A successful event was also held in the ISE on 13 April, receiving positive media and 

industry recognition. 

IFSC Ireland is a privately funded body, and is not a representative or lobby group. It will be 

engaging with international financial services companies to seek patron support over the 

coming weeks. 

4. Strategy Document – Update 

A draft Industry Strategy paper discussed with the Working Group Chairs was circulated to 

the other industry CHG members and feedback is now being received. The approach is 

around key issues for the business environment, and the document should be relatively 

uncontroversial. The next step is for the public sector to consider the material prepared, and a 

meeting of the previously constituted Steering Group should take place to finalise the draft. 

In parallel, the document will be circulated to a wider industry group to further develop 

specific points. It is hoped to be able to present an agreed document at the next CHG 

meeting. 

5. Green IFSC 

1) Green IFSC business plan development is nearing completion with a due date of 20 May 

2011. The plan sets out the global context for a green IFSC Initiative and resources required 

to achieve the vision over a 36-month period. In closing out the plan, the Green IFSC 

Steering Group is being assisted by Accenture, KPMG and PwC. 

2) Green IFSC brand development is scheduled for completion by 13 May 2011. 

3) Green IFSC educational and skills strategy development is underway. Action Plan report 

will be formulated within the next three-months. Forfas is assisting this process. 

4) Green IFSC activity, to date, has been kept low-key as building out and developing real, 

tangible support initiatives/strategies for the vision continues. Communicating to the wider 

business community, domestic and internationally, is scheduled to begin in June. 

6. AOB 

Pension Funds Levy 

Dave Fagan said he had been in contact with the Chair of the Pension Funds Group who 

highlighted the potential impact this could have on cross-border pension funds. 

Firstly, the impact would depend on how any levy is implemented: 

· If it is levied on all pension arrangements established in Ireland, then it will put 

an end to any prospects of establishing cross-border pension schemes in Ireland.

· If it is levied on Irish pension funds excluding assets in respect of overseas 

members then there is still a risk that Irish pension funds will move to somewhere like 

Belgium where no levy would apply. 

· If it is levied on pension assets for Irish members, irrespective of the location of 

the pension fund then, in theory it should have no effect. 

Secondly, the Chair was of the opinion that the introduction of a pensions levy would give a 

generally negative view to the market of Ireland‟s support for pension‟s schemes and the risk 

of further changes will make it difficult to encourage multinationals to choose Ireland as a 

base. 

Insurance Compensation Fund 

The Group agreed, following concerns expressed by the international non-life insurance 

sector representatives, that the Taoiseach should be briefed regarding recent press/media 

reports stating „that the Administrator of Quinn Insurance Limited would request a call from 

the Fund totalling €600 million of which approximately €180 million would occur in late 

2011‟. 

The Group was informed that insurance guarantee schemes throughout the EU are under 

review at present with a view to harmonisation. The international non-life insurance industry 

has requested serious engagement with the Department of Finance to consider how the Quinn 

deficit should be appropriately funded and to review the Act given the composition of 

Ireland's current non-life market. 


The next meeting takes place at 8.30am on Thursday 23 June, 2011.

IFSC Clearing House Group 23 March 2011 


Attendance 




Gary Tobin 

Jim Byrne 

Bob Keane 

Fergus Murphy 

Brendan Bruen 

Tony Golden 

Padraig Rushe 


Brian Daly 

Paul McGowan 

Tim Hennessy 

David Fagan 

Gary Palmer 

Pat Farrell 

Breda Power 

Paul O‟Connor 



John Feely 

Joe Breslin 


Peter Keegan 

1. Apologies 


Pat Wall 

Pat Casey 

David Guest 

Kevin Cardiff 



Neil Ward 



IDA Ireland 

D/Finance 

Revenue 

D/ETI 

FSI 

FSI 

CITI 



KPMG 




IFIA 

IBF/FIBI 

D/JEI 

IBF 

State Street 

IDA Ireland 

Attain 


ISE 

BOAML 


PWC 

D/Finance 

Ulster Bank 

D/Finance 

Central Bank 

D/Finance 

BMO


The Minutes of the meeting of 27 January 2011, as circulated, were agreed. 

Tim Hennessy updated the meeting on the Statutory Audit Directive (SI 220 of 2010). 

Arranged by D/EJI, DIMA attended a meeting along with D/Finance and Central Bank of 

Ireland representatives. DIMA's strong preference is for re/insurance companies to be 

exempted from the public interest entity ('PIE') definition - the UK and Luxembourg which 

are competing international insurance centres opted for this exemption in their 

implementation of the Directive. Mr Hennessy suggested that the D/EJI had gold plated the 

implementation by requiring two independent directors per the SI as opposed to one within 

the Directive. The D/EJI appeared unwilling to amend the SI to exempt re/insurance 

companies from the PIE definition but seemed willing to address the confusion caused by the 

definition of 'independent director' and to look at the appropriateness of the SI for captive 

re/insurers. 

Mr Hennessy expressed concern at the compounding impact of regulation / legislation. In the 

case of SI 220 there is duplication and inconsistency with the CBI Corporate Governance 

Code of 2010 (the 'Code'). The CBI Code is effective from 1 January 2011 with transitional 

provisions to 30 June 2011. Despite this industry still awaits the FAQ's from CBI - the delay 

in clarification is making it difficult from a practical perspective for companies to progress 

their implementation until issues which required clarification are addressed by CBI. 

Referencing the discussions at previous meetings on the proposed regulatory guidelines for 

the implementation of the 3rd AML Directive, Gary Palmer noted that a number of 

significant issues still remained. Noting that the funds industry was an internationally disintermediated 

industry the issues around the reliance on third parties and what 

activity/information must be undertaken by Irish industry companies was of particular 

concern. It was reported that a meeting to include the Department of Finance, the Central 

Bank and industry representatives had been scheduled where it would be important to ensure 

the conclusion of a framework that provided for an internationally focussed industry, 

especially in the light of the challenges posed by the prevailing negative sentiment towards 

Ireland. 

David Fagan told the meeting that there has recently been a range of new regulatory measures 

affecting the industry such as CP41, new Fitness and Probity proposals, SI220 etc. While 

these may all make sense individually he felt that it is important that some forum is created to 

look at the cumulative impact of these, consistency between them and the communication 

around them. 

Willie Slattery expressed concern and disappointment that there had been no consultation on 

the Audit Directive. He saw no obvious rationale as to why there had been no such 

consultation. He stressed that the international financial services industry were fighting to 

protect employment and that promulgating legislation in this way was unreasonable 

behaviour. He was also concerned with Ireland‟s rating downgrades and specifically the 

impact of another downgrade, the possibility of junk status and a potential default rating. He 

believed that the regulatory terms now being applied in the domestic banking sector were 

over reaching unreasonably into the international financial services sector. 

Breda Power told the meeting that the Department of Jobs, Enterprise and Innovation had 

specifically consulted with the Funds Industry on the Audit Directive. It had also had a

productive meeting with DIMA and the Central Bank and had sought further information 

from the Central Bank which they were still awaiting. The matter is still being considered. 

Michael Deasy said that the Central Bank would be issuing a FAQ document in the coming 

weeks. In reply to certain observations that some requirements were excessive, particularly 

vis-à-vis other jurisdictions, Mr Deasy said that the Bank made no apologies about insisting 

on high corporate governance standards, particularly in the current climate. He said that he 

was disappointed in many of the queries received to date - their intention was to whittle away 

the effectiveness of the Code. 

Brendan Bruen noted that non-compliance with the corporate governance code was 

potentially very serious, and that it was reasonable for firms to expect clarity and consistency 

of interpretation and application. 

Tim Hennessy reiterated that industry required a robust regulatory regime but when 

requirements exceed international best practice then Ireland‟s ability to retain and attract 

international financial services is hampered. 

The Chair emphasised the need to strike a balance by demonstrating commitment to robust 

yet sustainable regulatory standards, and recognising that regulation will have to take account 

of the cumulative impact. A meeting is to be convened with appropriate industry and public 

sector representatives to consider the impact existing and proposed regulation / legislation 

was having on industry particularly where industry consider that Ireland's requirements go 

beyond international best practice. The Chair said that these concerns could also be 

considered in the drawing up of the strategy document. 


Gary Palmer reported to the meeting on the activities of IFSC Ireland and specifically on the 

events of the previous week in the US. During the week a significant number of meetings 

and events were held, led and attended by the President of IFSC Ireland (John Bruton) and 

included both the various industry sectors and State agencies. From a funds industry 

perspective and particularly in the current environment Mr Palmer noted the value and 

importance of having a leading representative that can address the current concerns and 

highlight the separation between domestic issues and an international industry. 

Barry O‟Leary updated the group on the IDA‟s efforts to counter negative publicity about 

Ireland, and noted that the IDA is in the process of having high-level meetings with major 

multi-nationals. The largest 65 IDA clients were responsible for 80% OF FDI jobs, and IFSC 

firms comprised 12 of these. 

The Chair said that the Government recognised that a systematic and strategic approach was 

needed with appropriate resources. Developments in the domestic economy had clearly had a 

serious impact on Ireland‟s image, but there was still support internationally. However, 

clarity around the operating environment and a holistic approach were needed. He noted that 

the Government had been very explicit around its commitment to the 12.5% tax rate, and the 

Department of Finance and the IDA were articulating that message. 

Willie Slattery said that the industry strongly supported the efforts of the public sector, but 

noted that very serious damage had already been done, by the sovereign downgrades in 

particular.

Gary Tobin noted that aggressive tax structures posed a real risk to the reputation of Ireland, 

and that they would be dealt with appropriately by the Department of Finance. 

Deirdre Somers commented on the very positive support which the ISE has received from 

IFSC Ireland in its marketing efforts in the US and the Middle East. In particular she said 

that John Bruton's Presidency of IFSC Ireland was hugely important in dealing head on with 

the very real concerns which the market has about Ireland, given the amount of negative 

publicity at present and the uncertainty relating to the tax rate. 

4. Strategy Document – Update 

Brendan Bruen updated the Group on the development of a strategy for the IFSC. An industry 

workshop had been held with excellent representation from the different firms and 

associations involved. Everyone was committed to moving the process to a completion as 

soon as possible, and agreed that the focus of the strategy should be to improve the general 

environment, with targeted support for specific initiatives where necessary. A key theme to 

emerge was the increasing role of technology in provision of services. 

A draft SWOT analysis had been prepared and was being worked on by industry participants. 

Key positives included the critical mass of existing players, the global franchise, reduced cost 

base and traditional strengths of an English-speaking workforce, geography, euro and EU 

membership. On balance, there is still a positive perception of the legal, tax and regulatory 

environments. Negatives included the sovereign weakness, reputational damage and the 

marketing challenges associated with it, personal tax regime, and the uncertainty around 

regulatory and legislative changes. Further threats include intense competition from both 

established and emerging centres, and the dangers arising from a "knee-jerk" reaction to the 

domestic banking issues. 

The headline goal should be around job creation, and the workshop considered that 25,000 

new jobs over a 5 year period should be adopted as the target, with an associated generation 

of tax revenue and the reclaiming of a place as a top 10 financial centre. Opportunities to 

achieve this were identified across areas that include: emerging markets and non-traditional 

areas of business, green financial services, specialised services and RD&I, alignment with 

Ireland's position as an ICT leader, payment services, insurance hubs, new products and 

markets in life insurance and the broadening of activities and moves up the value chain in 

funds and asset management. The approach of the Central Bank to regulation of IFSC firms 

had been highlighted as crucial. Industry was not seeking a reduction in standards, but sought 

a system which was predictable, consistent and efficient. The volume of change both in terms 

of new requirements and the structure of the organisation was creating real challenges. 

He suggested that work continue on the industry side around (a) a high-level strategy 

statement, (b) a more detailed supporting document and (c) bi-lateral meetings with 

appropriate public sector stakeholders, including the Central Bank as a priority. 

The Chair thanked him for the update, and suggested that the steps outlined be progressed as 

a matter of urgency. 

5. Green IFSC 

Padraig Rushe advised that the Green IFSC was being rebranded as 'Global Green 

Interchange' following a review of the image and branding of the initiative. Since the last

Clearing House Group, where the Taoiseach launched the initiative, the Steering Committee 

has met and the final draft proposal on the carbon element will be available next week for 

submission to IDA/EI for their review. It is anticipated that a final document will be 

submitted to Government by Mid April. 

Separately the green finance aspects are being progressed and McKinsey will be involved in 

updating and validating the original projections and assumptions that formed part of the 

feasibility study. A further Steering Group session will take place in April to continue this 

process. At this stage it is hoped to have the implementation plan fully operative in early 

May. 


The next meeting takes place at 9.30am on Thursday 12 May, 2011.

Clearing House Group Minutes - Department of Taoiseach

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