Call for evidence outcome

Call for evidence: British credit unions at 50

Updated 31 December 2014

This was published under the 2010 to 2015 Conservative and Liberal Democrat coalition government

0.1 Ministerial foreword

Credit unions play a vital role in UK financial services, providing savings and loans to a wide variety of people across our society. Given the importance this government attaches to people being able to access financial products that are right for them, it is committed to doing all it can to help credit unions thrive and grow in a sustainable manner.

To further this aim, we have taken a number of important steps to help credit unions, including removing unnecessary restrictions in the legislation governing them, and allocating £38 milion to our Credit Union Expansion Project. We have also seen growing, tangible support for credit unions from wider society, most notably from the Church of England and several of our big banks. The time is now ripe to take stock and consider what are the appropriate next steps to help build the credit union sector we want to see for the future.

In launching this call for evidence I want to issue a dual challenge.

First, to credit unions themselves, to set out for us their vision of where they want to be as a sector in the coming years, and to point out where further government action is needed to support that. You know best what your members need and want from you, and government stands ready to do what it takes to allow you to deliver that.

And second, to wider society, to consider how best they can support credit unions, and how the government can encourage and facilitate such support. Credit union members, and those who are not yet members but could benefit from what credit unions have to offer, are among your customers, your congregations and your communities; support from wider society is invaluable in building a stronger, more sustainable credit union movement.

In its fiftieth anniversary year, the UK credit union movement can point to a proud record of supporting its members through thick and thin. Join us in helping to ensure that they can continue their progress through the next half century and beyond.

Andrea Leadsom MP, Economic Secretary to the Treasury

1. Introduction

1.1 About this call for evidence

In its Coalition Agreement, the government set out its commitment to “promote mutuals and foster diversity” in UK financial services. In terms of credit unions, this commitment has been realised via a number of measures to remove unnecessary legislative barriers to their sustainable growth, and the allocation of £38 million for the Credit Union Expansion Project. On the back of this work, the government is issuing this call for evidence to issue a dual challenge: first, to credit unions to set out their vision for the future, and second, for the private sector and wider society to consider how they can support credit unions. The government will then consider what actions are required to help deliver positive outcomes in this area. Any other views or suggestions that respondents wish to put forward on any of the discussion points raised or other relevant areas to credit unions not specifically covered here are also welcomed.

1.2 Who should respond to this call for evidence?

Reflecting its dual challenge, the government welcomes views from within the credit union movement, and also from the private sector and wider society, as well as members of the wider public who wish to contribute.

1.3 Purpose

The purpose of this call for evidence is to seek well-informed views about how the government can do more to support the development of the credit union movement in Great Britain^{[footnote 1]}. The responses will be used to aid government decision making and planning around the legislative and regulatory framework for credit unions. Enabling credit unions to strengthen and better serve their members will help with the delivery of the government’s aspiration for a diverse, healthy and successful sector which is able to offer a broad range of services to an increased number of members. At the same time it is important to enable credit unions to continue to fulfil their valuable social role and maintain their unique identity.

In their 50th anniversary year credit unions have become a key part of the British financial services landscape providing vital affordable credit and other services to their members. The government is keen to ensure that the legislative environment in which they operate is as supportive as possible in allowing credit unions to develop further, building on these strong foundations.

The government will carefully consider the responses to this call for evidence before considering potential policy options. An Impact Assessment will be produced, if necessary, at the appropriate juncture.

1.4 Scope

This call for evidence applies to credit unions in England, Wales and Scotland.

The legislation covering deposit-taking activities by Northern Ireland credit unions is devolved to the Northern Ireland Assembly. All matters relating to legislation for credit unions in Great Britain are within the jurisdiction of the United Kingdom Parliament.

Credit unions, as financial service providers, are subject to a range of legislation, rules and regulations which may not be credit union specific and are in place to protect financial services consumers in general. Therefore respondents are asked where possible to focus their responses on credit union specific legislation and issues.

1.5 Background

Credit unions are member-owned financial co-operatives, which are democratically controlled. They are operated for the purposes of promoting thrift, providing credit at competitive rates, using members’ savings for their mutual benefit, and training and educating members in the wise use of money and in the management of their affairs. They take deposits from, and lend predominantly to, their members.

There are approximately 370 credit unions in Great Britain with a combined membership of over 1 million, over £1 billion in assets and more than £600 million in outstanding loans to members. While these figures constitute only a fraction of the volumes seen in mainstream banking, credit unions nevertheless provide an important service to their members, attested by the fact that membership levels continue to grow.

Credit unions in Great Britain are governed by the Credit Unions Act 1979 (“the 1979 Act”) and the Industrial and Provident Societies Act 1965 (“the 1965 Act”). Credit unions are regulated under the Financial Services and Market Act 2000 (FSMA); they are authorised by the Prudential Regulatory Authority (PRA), and are regulated by the PRA and by the Financial Conduct Authority (FCA). They have various features which make them unique among UK financial service providers, including that members must meet the bespoke membership criteria of individual credit unions known as ‘common bonds’. They are also limited by legislation, their Rules and the PRA and FCA’s Credit Union New Sourcebook (CREDS) in terms of the range and terms of some of the products and services they may offer; for example, the maximum amount a credit union can charge its members for loans is capped by law.

While provisions of the 1979 Act apply only to credit unions, some of the provisions of the 1965 Act applies to credit unions and industrial and provident societies (co-operatives and community benefit societies). The 1965 Act is in the process of being consolidated by the Co-operatives and Community Benefit Societies Bill 2014 which brings together and modernises existing legislation. This consolidation bill is due to come into force in August 2014; the Credit Unions Act 1979 is not part of the consolidation.

1.6 Existing support for credit unions

The government’s approach to mutuals (including credit unions) is set out in its founding document, the Coalition Agreement, which includes a commitment to “foster diversity and promote mutuals”. Following this commitment, the government has taken forward a number of modernisations of existing credit union legislation. *[LRO]: Legislative Reform Order

In January 2012, the government brought into force a Legislative Reform Order (LRO) for the credit union sector. The LRO removed a number of unnecessary restrictions on credit unions, allowing them, among other things to to:

• reach out to new groups by serving more than one group of people
• provide services to community groups, businesses and social enterprises
• offer interest on savings, instead of a dividend

The rate of interest that credit unions can charge their members for loans is capped by law. As of 1 April 2014, the maximum interest rate credit unions in Great Britain can charge for loans is 3% per month (previously having been set at 2% per month). This change followed a feasibility study carried out for the Department for Work and Pensions (DWP) in 2012 which found that many credit unions were making a loss on some of the smaller loans made to their members (typically those of less than £1000).

The increased interest rate cap in Great Britain is intended to allow credit unions to break even on more of the loans they make, and give them more flexibility to appropriately reflect risk within the pricing of their loans. The interest rate cap change is permissive and individual credit unions continue to decide what interest rate they charge their members for loans, up to this new cap. However, even if individual credit unions decide to increase loan rates to 3% a month, this will still keep the costs of lending at a level significantly lower than many of the high cost lenders operating in the same market. At the same time, if credit unions are able to make more loans available sustainably this will give additional affordable finance options to many more people who may be unable to access mainstream credit.

DWP have also committed to deliver the Credit Union Expansion Project (CUEP) which will make an investment of up to £38 million into the sector. The contract was awarded to ABCUL (the Association of British Credit Unions Ltd - the largest credit union trade body in Britain). Payments are staged against delivery of various ambitious new member and loan milestones. CUEP is a major programme focusing on cultural and behavioural change, and contains specific technology, distribution and infrastructure goals. The project aims to achieve the modernisation and expansion required for the credit union sector to be close to achieving sustainability in the next seven to ten years.

A package of measures for industrial and provident societies including credit unions also came into force in April 2014. This package made the following changes:

• introduced insolvency rescue procedures, including administration and voluntary agreements; this gives more rescue options to societies and credit unions experiencing financial difficulties, that previously would have had no choice but to be wound up
• reproduced Companies Act provisions with regard to the investigative powers of the registrar (Financial Conduct Authority) in addition to the regulatory powers that already existed in the Financial Services and Markets Act; enhancing the FCA’s powers will give confidence to the movement that if a credit union is suspected of unlawful or improper behaviour there is the power to investigate this
• simplified the registration process for new societies when submitting registration documents electronically by only needing to supply one copy of rules (previously two copies were required); this measure also makes provision to allow electronic registration as another option to conventional paper submissions of documents

On top of these modernisations, the government has ensured that credit unions also continue to benefit from a number of European Directive exemptions and in some cases from a lighter-touch regulatory regime, in recognition of their special status as a credit union or linked to their size.

The government has also taken steps to support savers, including those who save with credit unions. Measures announced at Budget 2014 include:

• increasing the annual ISA subscription limit to £15,000 and reforming the ISA into a simpler product such that this full amount can be held in a cash ISA, a stocks and shares ISA, or split in any combination between the two
• raising the annual subscription limits for Child Trust Funds and Junior ISAs to £4,000
• from April 2015, lowering the starting rate of savings income tax from 10% to 0% and extending the band to which it applies from £2,880 to £5,000

Finally, the government has taken action to tackle unscrupulous lenders, in order to prevent them competing with credit unions and other finance providers on unfair terms. The government has fundamentally reformed consumer credit regulation, transferring this responsibility from the Office of Fair Trading to the FCA on 1 April 2014. To protect consumers from unfair costs the government has also legislated to require the FCA to impose a cap on the cost of payday loans, which will be in place by 2 January 2015. These measures will help level the playing field for credit unions.

The actions outlined above demonstrate the government’s continuing support for the credit union movement and the mutuals sector as a whole. This call for evidence aims to build on this support and establish which next steps will bring the most significant benefits for credit unions in Great Britain, and which the government should therefore prioritise to further support the sector and safeguard its future.

2. Call for evidence discussion topics

The document is broken down into sections designed to consider various aspects of credit unions and the issues they may face throughout their life cycle. It will cover the basic structure of a credit union, the experience of setting up a new credit union, considerations around how to meet the needs of a growing and diverse membership, the practicalities of running a successful, self-sufficient credit union, and what happens in the event of a credit union getting into financial difficulties or wishing to merge with another credit union.

2.1 Credit unions: The basic structure

Credit unions differ from banks and other financial institutions in a number of ways, in particular, as mutuals, those who have accounts with a credit union are its members and owners. They elect the credit union’s Board of Directors, who are often volunteers, on a ‘one member one vote’ basis, regardless of their amount ‘invested’. A credit union’s policies governing interest rates and other matters are set by this Board of Directors.

The size and sophistication of credit unions varies widely in Great Britain. The largest credit unions are now quite complex financial institutions with tens of thousands of members and permanent, trained, paid staff, operating from well equipped premises and offering a range of financial products and services. Others are much smaller ventures with perhaps only a few hundred members, staffed by volunteers often in less well-equipped environments, providing a limited service and meeting the needs of a relatively narrow group of members. These sometimes polarised operating models, coupled with historic differences in stakeholders’ vision for the future of the credit union movement and fundamentally different views of a credit union’s mission, create alternative conceptions of the needs of the movement as a whole, including the appropriate framework of legislation and regulation.

Historically, many credit unions in Great Britain were initially set up in response to a growing demand in some local communities for basic savings and loans products. The first pioneers and members may have been unable to access traditional bank facilities and had observed how credit unions had worked in other countries. In the fifty years since these early credit unions were established the nature of British society and consumer habits and expectations have evolved. The services offered and the role that credit unions play in society for some has stayed quite true to the original model while others have adapted their strategy and business models to try and meet changing consumer demands.

Whatever the nature or aspirations of individual credit unions, they are all bound by the same guiding principles, the ‘objects’. These are set out in the Credit Union Act 1979. The 1979 Act states that:

The objects of a credit union are -

(a) the promotion of thrift among the members of the society by the accumulation of their savings;

(b) the creation of sources of credit for the benefit of the members of the society at a fair and reasonable rate of interest;

(c) the use and control of the members’ savings for their mutual benefit; and

(d) the training and education of the members in the wise use of money and in the management of their financial affairs.

2.6 The objects do not specifically spell out exactly what credit unions can and cannot do. Also current legislation does not distinguish between small community based credit unions and larger more professionalised credit unions in terms of prescribing the role and powers of credit unions.

Question 1

Do you agree that the basic structure and objects of a credit union remain appropriate? What changes, if any, are required?

2.2 Setting up a credit union

When setting up new credit unions applicants must satisfy both the Prudential Regulation Authority and the Financial Conduct Authority rules and regulations (“the Threshold Conditions”), demonstrating that they have developed a strong and sustainable organisation. Once the formal application process begins, full authorisation of a new credit union can take between six and twelve months. Application fees currently start at £300 for basic credit union permissions but can be higher dependent on a number of factors which are reviewed each year^{[footnote 2]}.

The PRA and the FCA offer a variety of resources and early support to people considering setting up a new credit union. Pre application meetings can be held as a preliminary engagement with both regulators ahead of the submission of the application. In addition, contact points and access to online tools and information are available at all stages of the application process.

The PRA and the FCA have distinct roles during the Authorisation process. The FCA is the registering authority for societies under the Industrial and Provident Act 1965 and the Credit Union Act 1979. The FCA needs to give the PRA consent to the approval of Part 4A Permission (permission to carry out regulated activities). The FCA’s Mutual Team will not register a Credit Union until it has received confirmation from the PRA that Part 4A Permission has been granted. Approval of Part 4A Permission and Registration of the credit union occur on the same day.

On average four credit unions are newly-authorised each year. Some common problems encountered when credit unions are setting up are often related to the terms of the Common Bond, being unable to demonstrate the viability of the business model, difficulties acquiring sufficient funding, varying application quality in terms of the documentation and policies included and IT costs.

Question 2

Is the procedure for setting up new credit unions appropriate? What changes, if any, are required?

2.3 Meeting the needs of a growing, diverse membership

Credit union membership numbers in Great Britain continue to increase. The total number of members rose from 563,000 in 2004 to 1,040,000 in 2012^{[footnote 3]}.

The sophistication and demands of financial services consumers has also increased in recent years. Credit unions, in common with other institutions, need to be able to respond to these changing needs and expectations to remain relevant, retain customers and attract new members.

Under the 1979 Act membership of a credit union is based on the concept of a ‘common bond’ between its members. There are various qualifications for membership appropriate to credit unions, including occupation, residence and workplace.

Some credit union representatives have argued that the concept of the common bond is out-dated and redundant, stemming from a time when it was believed that people would not be prepared to volunteer for a credit union, or become a member, unless there was a close connection between members. The common bond also historically reduced the need for the institution to engage in expensive information-gathering processes to assess risks, as members knew each other or had a better understanding of their members’ lifestyles. Members may also have been more inclined to repay debts due to the social pressures of this closer relationship.

In response to requests from the sector over time, the common bond has been relaxed on a number of occasions. For example, employee credit unions were allowed to also take in members who lived in the local area who were not employed by the relevant employer. The rules were further relaxed in 2012 by the Legislative Reform (Industrial and Provident Societies) Order 2011 which allowed credit unions to provide for more combinations of membership and to have multiple common bonds.

Changes were made in the 2011 Legislative Reform Order to give credit unions the ability to set their own limits for non-qualifying members, such as people who moved away from an area or left an employer, which was previously capped at 10%. Young people were also allowed to become members. Some stakeholders have suggested that these changes could go further to cover wider scenarios such as divorced partners of ‘qualifying’ members and grandchildren.

The potential number of members a credit union with a locality based common bond is limited by legislation. This cap was increased in 2012 to make the maximum number of potential members of a society of two million. A potential field of membership test was put in place to enforce this. The requirements of that test are:

• that the number of potential members of the society do not exceed 2 million
• that it is reasonably practicable for every potential member to participate in votes of the society, serve on the society’s committee and have access to all the services offered by the society

In reality no credit union in Great Britain is currently close to having two million members with the largest ones having around 30,000. However, for some credit unions with a locality element to their common bond, although membership levels are around 30,000 or less they may well be pushing up against the limit of two million potential members. This could be acting as a barrier to the ability of a credit union to attract new members, either by being unable to extend existing common bonds or add new ones, hampering expansion plans into neighbouring areas or halting plans to merge with another credit union, all of which may take potential members above the permitted level.

The membership limit was originally put in place to stop a credit union from getting so big that it was unable to serve its members effectively. With advances in technology, communication methods, transport links and a generally more mobile population, the basis of this original reasoning has weakened.

The way that the ‘common bond’ has evolved and the rules around the different types of members could allow credit unions to potentially extend the membership of a credit union to unconnected groups of members, thereby changing the scope of the original society. An unrestricted scope for credit unions could, however, have the impact of making it more difficult to justify exemption from European Directives in the future. In particular, the basis of credit unions’ exemption from the Consumer Credit Act could come under threat.

Question 3

Are the concept of the common bond and the wider rules around membership still relevant and valued by the credit union movement? What changes if any need to be made and what would be the benefits and risks?

Another change in credit union legislation made by the Legislative Reform Order was to allow credit unions to admit corporate members within certain limits. Such members can make up a maximum of 10% of a credit union’s total membership, hold a maximum of 25% of shares in the credit union and be granted a maximum of 10% of loans. Some credit unions appear to be taking this opportunity to engage in opening accounts and making loans for business customers; however, many are choosing not to.

Obtaining a small loan from a high street bank to start up a small business can be difficult for many individuals. Thanks to their first-hand knowledge of local communities and economies, credit unions could in some circumstances be well-placed to offer such loans at an affordable rate, supporting small businesses within the community to the benefit of their members.

Limits also apply to the amount of loans and savings that can be made to members, as well as in the case of lending, the maximum interest rate that can be charged.

The range of products offered by individual credit unions varies widely. Some credit unions choose to simply offer basic savings and loan accounts, others have branched out into providing debt counselling services, current accounts, prepaid cards, payday style loan products and a few also offer mortgages. There is a wide diversity of product offering within the credit union sector.

Question 4

Are the various limits imposed by legislation at the right levels to allow credit unions flexibility to serve and attract all kinds of members? What changes, if any, should be made?

Question 5

What other help can government give to assist credit unions to attract and retain a wide range of customers and have confidence to serve all customers effectively? What changes can be made to improve this?

Question 6

What reasons have prevented some credit unions from offering loans to small businesses, including sole traders, in their communities? What could be done to encourage more activity in this area and allow credit unions a greater role in supporting local small and micro enterprises?

The subject of credit union rulebook arrangements has been raised previously as a possible area of over-complication that can act as a barrier to meeting the changing needs of members. For example, currently if a credit union wants to extend services to a new group (i.e. enact a new common bond) a full rule change is required that members must agree to.

After members have voted on changes to their rules, for example at their AGM, the credit union is still required to register the rule amended with the FCA before it is effective. The FCA cannot give conditional approval ahead of changes put to a member vote. If the proposed rule change is contrary to the legislation the FCA cannot register it. This can cause delays and extra costs for credit unions to communicate again with members if they want to resubmit an amended rule change.

Credit union boards already have powers to act in accordance with their own rulebooks, to achieve its objects. However, there may be a lack of clarity about what they are allowed to do without seeking agreement from members which may be stifling ideas and innovation.

Question 7

Is there anything that government can do to improve, simplify or clarify the legislation to make rules changes and the Boards power to act easier to navigate and meet the needs of their members?

The credit union movement has historically found it difficult to clearly communicate to the public the nature and role of credit unions, and the potential benefits of membership.

Most credit unions agree that being able to attract a wide range of members can help the credit union to meet its social obligations and at the same time become a sustainable business. Recent attention focusing on credit unions as an ethical alternative to payday lending has been welcomed by some but has concerned others with its portrayal of credit unions as only of interest to the less well-off.

Question 8

What else can the government do to encourage wider knowledge and understanding of credit unions?

In some countries where credit unions are more widespread they have grown through collaboration and pooling certain functions to achieve economies of scale. The Credit Union Expansion Project aims to bring about aspects of this. For example, the first product produced through the project is the Automated Loans Decision Making Tool which is being used across the majority of the credit unions involved with the project.

One interesting example in Canada, where credit unions have a three tiered structure and each credit union participates in a liquidity pool by depositing a certain percentage of its assets with a central institution. These central institutions open up additional opportunities by operating on a larger scale than individual credit unions could do alone; for example, they can access payment systems and thus give access to local credit unions. This removes the need for individual credit unions to have an arrangement with a sponsor bank, as is currently the case in the UK.

Question 9

What can the government do to bring about further efficiencies and stability to the credit union movement?

2.4 Enabling sound financial management and responsible lending

Without philanthropic funding, it is as important for credit unions, just as for other financial institutions, to operate as sustainable entities. This status enables them to give members confidence that they are well managed and secure, looking after members funds responsibly whether their members are borrowers, savers or both.

The government has historically supported credit unions through various funding initiatives. This approach has evolved with the DWP Credit Union Expansion Project (CUEP) which aims to target funding to help credit unions to become sustainable in the next seven to 10 years. CUEP requires the contractor and its sub-contracted credit unions to comply with all regulatory requirements of the PRA and the FCA. The project will also place an emphasis on supporting credit unions to demonstrate good financial management, sound decision making, robust credit control and debt recovery. These improvements combined with a continued emphasis on responsible lending should allow credit unions to earn sufficient income to pay for the running of the credit union.

Question 10

Should the government do more to ensure that credit unions have the flexibility to run their business but protect members by ensuring sound financial management?

Lending money to members is a key staple of a credit unions activity. Lending responsibly to people who can afford to repay enables more money to be lent in the future, by minimising levels of bad debts and generating healthy surpluses. As technology and society changes it is becoming increasingly difficult for lenders as a whole to see a full picture of the income and outgoings of borrowers in order to make informed lending decisions.

A lack of access to real time credit reference information has been mentioned as an increasing issue for some credit unions as they are unable to detect instances when some loan applicants may have taken out or applied for multiple loans in the same period, which ultimately impacts on their ability to repay the loan from the credit union.

Some credit unions have raised concerns that increasing numbers of people are turning to them as a last resort, expecting the credit union to be able to ‘bail out’ members who have got into difficulties with high cost credit providers. Often these situations may have gone too far for credit unions to be able to help, as the customer no longer represents a reasonable risk for lending.

Sound management (including financial management) is as important for credit unions as other financial institutions and businesses in general. In recent years most instances of credit unions going out of business can be traced back to poor governance whether as a result of fraud, poor lending decisions and various other examples of mismanagement.

Question 11

What can the government do to help credit unions grow while continuing to uphold strong governance and lend responsibly?

2.5 Learning and Support from Business and the Wider Community

In recent months, the government has been pleased to see strong support for credit unions from the private sector and civil society, in particular from:

• the Church of England, via the Archbishop of Canterbury’s task group on credit unions
• parts of the banking sector, where Lloyds, Barclays and Citibank have each provided a mixture of financial and operational support

This type of support represents the coming together of different parts of society to aid credit unions in growing sustainably, in order to serve more people in their communities. The government is keen to hear what more can be done along these lines, and what we can do to support such action.

Question 12

What experience and support can wider society most usefully share with credit unions? What can government do to support and facilitate this?

2.6 Assisting credit unions to strengthen by amalgamation or transfers of engagements

The actual number of individual credit unions in Great Britain has been on a gradual downward trend for a number of years. This decline is not due to a decline in members, as overall membership levels continue to grow, but as a result of credit unions merging with others either to achieve greater efficiencies and economies of scale or out of necessity as a result of some credit unions finding themselves in financial difficulties.

One option in this area would be to enhance the power of the PRA to actively intervene when credit unions start to show signs of struggling. This would be analogous to Sections 42B and 42C of the 1986 Building Societies Act which provide that, if the appropriate authority considers it expedient to do so in order to protect the investments of shareholders or depositors of a building society, it may either direct the society to transfer all its engagements to one or more other building societies, or to transfer its business to an existing company, or to a mutual society under the Butterfill Act (this latter point being inserted by the 2012 Act). The PRA may also direct that a transfer may proceed by board resolution only, rather than by seeking the approval of the members of the society.

Another idea suggested by industry is that a ‘stabilisation fund’ would be beneficial when seeking a merger partner for individual credit unions who find themselves in financial difficulty. If potential shortfalls in the institution’s finances could be filled this may increase the likelihood of being taken over by a willing successful credit union, which would not then be risking weakening its own financial stability by taking on an unsustainable business. A similar fund exists in Ireland, having been built up from credit union contributions over a number of years. Considerations of how this could work (including measures to defend against moral hazard) or be funded would need to be thought through.

Question 13

What can the government do to help credit unions achieve more positive outcomes if they get into financial difficulty?

Question 14

Should the government be doing more to assist healthy credit unions to come together to benefit from the potential economies of scale which may come from the larger resulting credit union?

2.7 Other areas

If there are other ideas and views that have not been covered in the above discussion areas respondents are invited to provide details along with any supporting evidence that helps to explain why their ideas should be considered for future policy making.

Question 15

In which other areas is government action required to deliver its aspirations for the credit union movement?

1. Northern Ireland credit unions have their own distinct legislation and fall under the jurisdiction of the Northern Ireland Assembly. ↩

2. The current fee structure can be found at http://fshandbook.info/FS/html/handbook/FEES/3/Annex1 ↩

3. Introduction to Credit Union Statistics, Bank of England, July 2013 ↩