Minister’s Statement on Banking 30 September 2010
It is an urgent and immediate priority to reinforce international market confidence in our ability and commitment to restore our banking system to health and to secure the long-term sustainability of our fiscal position.
Greater certainty on the final costs of repairing the banking system in Ireland will provide reassurance to investors on the capacity of the Irish State to accommodate these costs within the Government’s overall framework for the restoration of Ireland’s public finances to long-term sustainability.
As has already been signalled, this statement confirms that additional capital support will be required by some of our banks and building societies. The overall level of State support to our banking system remains manageable and can be accommodated in the Government’s fiscal plans in the coming years.
It is imperative that we remain focused on our major challenge which is to ensure that our public finances are returned to a stable and sustainable path. We must continue the fiscal consolidation we have embarked upon. This is the only course to follow if we are to ensure the future economic wellbeing of our society.
There will be a very substantial spike in Ireland’s General Government Deficit in 2010 as a result of the capital support that we are providing to our banking system, totalling almost 20% of GDP. On a purely headline basis our General Government Deficit for 2010 will be around 32% of GDP. Were it not for this once off spike we would have broadly met our budget target for 2010. I want to stress today to all, including our European partners, that Ireland remains fully committed to reducing our deficit below 3% of GDP by 2014 as agreed. It is important that we have a credible path to show how we propose to meet this commitment. Accordingly, a four year budgetary plan, incorporating the annual measures will be published in early November.
No additional borrowing arises this year as a result of this capital support to our banks. Our ongoing cash funding requirements for these measures will be spread over more than ten years. Funding the banks in such a manner lessens the immediate impact on the Exchequer. It is important to note that the Exchequer is fully funded through to the middle of next year. However, in order to fully underline the strength of our resolve and to ensure the necessary fiscal adjustment we will make an additional significant consolidation effort in 2011 over and above the already announced target.
Projected final NAMA discounts
Following the completion of the transfer of the first two tranches of loans, a total of €27bn. of loans has transferred to NAMA. With the granular loan-by-loan data available to NAMA from these transfers and the comprehensive and detailed information now available to it on the remaining loans, the Agency has now refined its estimates of the discounts on the remaining loans to be transferred to a high level of accuracy.
This information has allowed the Financial Regulator to update his assessments of the capital position of all of the institutions participating in NAMA following his Prudential Capital Assessment Review (PCAR) earlier in the year and the EU-wide CEBS Stress Testing Exercise carried out in July.
In addition to the information on the capital position of Anglo Irish Bank, I will set out in this Statement the expected final position in respect of the other institutions participating in the NAMA Scheme.
A number of important steps have been agreed and will be taken by Government to provide certainty about the impact of NAMA transfers and to end the speculation on discounts which has surrounded the tranche by tranche release of data. The Board of NAMA and the participating institutions have therefore agreed that all remaining NAMA transfers should be completed in one single tranche for each of the participating institutions.
In order to support the accelerated implementation of the plan for restructuring Anglo into an Asset Recovery Bank and a Funding Bank, the Board have agreed that Anglo’s remaining eligible bank assets will be transferred to NAMA by the end of October and that bonds will issue to Anglo in return on the basis of NAMA’s current estimate of their value. These loans will then be subject to due diligence and valued by NAMA on a loan by loan basis. If any adjustment to their value is necessary, it will be made subsequently. The EU has been advised of this revision to the valuation process for the remaining Anglo loans and I will be making Regulations to provide for it.
In all cases this expedited transfer will be undertaken in accordance with the legislative framework for NAMA set out in the NAMA Act and the European Commission State aid approval for the NAMA Scheme. This expedited transfer will maintain the principle of a loan-by-loan valuation of all NAMA transfers and is consistent with the EU State aid approval for the Scheme.
The Government has decided, having consulted with the NAMA Board and the European Commission, that where the total exposure of a debtor is below a €20 million threshold in AIB and Bank of Ireland, that debtor’s loans will not now be transferred to NAMA. The threshold had previously been set at €5 million. This change will ensure that NAMA can operate to the highest level of efficiency and effectiveness in the management of its loan portfolio and allow for the completion of all NAMA transfers by end-year.
NAMA will continue to focus on realising maximum value for the taxpayer from the higher-value loans transferred into it. I have been advised by NAMA that there are 650 debtors with property-related debts of between €5m and €20m in these two banks. They account for just €6.6bn of the aggregate €80bn volume of NAMA eligible loans.
Loans of this size can be efficiently managed by the banks themselves through their network of local representation and relationships. The Financial Regulator will ensure that the banks put in place prudent provisioning for these loans.
Anglo Irish Bank
Anglo Irish Bank
On the 8th of September last I announced the Government’s decision on the restructuring and resolution of Anglo Irish Bank, which remains subject to European Commission approval.
This envisages the splitting of the bank into two licensed and regulated credit institutions: an Asset Recovery Bank focussed on recovering maximum value for the State from the loan assets and business of Anglo not being transferred to NAMA and a Funding Bank to fully safeguard Anglo’s deposit base.
I said then that the guaranteed position of depositors in Anglo Irish Bank would be unaffected by the new structural arrangements for the bank. Both existing and future depositors are a critical source of funds for the restructured Anglo and protecting these depositors is a priority.
Capital Assessment – Anglo Irish Bank
Mr Matthew Elderfield and his staff in the Central Bank have worked intensively liaising very closely with the CEO and senior management team in Anglo, NAMA and the other relevant authorities to establish as definitively as possible the level of capital required by the new structure.
This assessment has now been completed. The result has been communicated to the bank and a statement has been issued by the Central Bank. The statement provides an explanation of the approach and methodology adopted to determine the bank’s capital requirements.
The Central Bank has, therefore, determined and advised the Bank that in the central - or expected loss case - an additional €6.4bn in total capital will be needed for the Recovery Bank and Funding Bank structure to continue to meet the minimum capital requirements in the coming years consistent with Basel rules.
A total of €22.9bn has already been provided by the State since the bank was nationalised early in 2009. This additional capital requirement brings the projected total gross cost of the restructuring of Anglo Irish Bank to €29.3bn.
This additional capital will be provided by increasing the Promissory Note issued by the State and by appropriate burden-sharing exclusively by holders of Anglo subordinated debt instruments as outlined below.
The Central Bank has carried out a detailed analysis of potential losses in the bank in the coming years. The examination has drawn on comprehensive information and analysis of Anglo’s non-NAMA loan book carried out both by the Bank and its advisers and independent consultants in preparing the Bank’s Restructuring Plan for the European Commission. Information has also been made available by NAMA from a review of assets securing the loans in Anglo’s remaining NAMA tranches. This review has enabled NAMA to determine and advise the Central Bank of the expected discount of 67% on the remaining €19bn. of the bank’s loans that are due to be transferred.
Stress scenario - Anglo Irish Bank
The Central Bank has also undertaken a stress test on Anglo building on the PCAR analysis carried out for the other banks earlier in the year. The Central Bank has determined that on the basis of severe stress assumptions - including a 70% discount on the remainder of Anglo’s NAMA loans– the stress case level of losses in Anglo Irish Bank could potentially be €5bn. higher than in the expected case of €29.3bn.
The stress case indicates the upper boundary of the level of losses. It does not represent the Central Bank’s expectation of the likely outcome.
The Government will therefore capitalise the new structure to the expected case requirement of €29.3 billion.
It will also be a priority for authorities to press ahead with the restructuring of the bank with a view to achieving the split of the bank early in 2011. I will continue close consultation with the European Commission and in particular with Commissioner Almunia with the aim of providing in the next month all elements necessary to bring the Commission’s assessment of the restructuring plan to a positive conclusion. This should allow the matter to be settled through a formal Commission decision on a timely basis.
Burden sharing by holders of subordinated debt in Anglo Irish Bank
Much has been said about senior debt obligations in Anglo Irish Bank. The position is that senior debt obligations rank equally with deposits and other creditors under Irish law. I have no plans to change this position. There is, therefore, no question of seeking to impose losses on holders of such senior debt in Anglo or indeed in any other credit institution in the State through any legislative measures. Any alternative strategy as advocated by some creates a significant risk of jeopardising the banking system’s and indeed the State’s access to international debt markets and cannot be countenanced on that basis.
The principle of appropriate burden sharing by holders of subordinated debt, however, is one with which I agree. As can be seen from the figures outlined above, the losses in the bank are substantial and it is right that the holders of Anglo’s subordinated debt should share the costs which have arisen.
In keeping with this approach, my Department in conjunction with the Attorney General is working on resolution and reorganisation legislation, which will enable the implementation of reorganisation measures specific to Anglo Irish Bank and INBS which will address the issue of burden-sharing by subordinated bondholders. The legislation will be consistent with the requirements for the measures to be recognised as a re-organisation under the relevant EU Directive in other EU Member States.
I expect the subordinated debt holders to make a significant contribution towards meeting the costs of Anglo.
Irish Nationwide Building Society
On the 30th March I announced that INBS did not have a future as an independent stand-alone entity. The institution is now under public control and arrangements for its sale or integration into another institution are being advanced in discussions between the State, the European Commission and the Society.
To date I have provided €2.7 billion in capital to cover the losses on lending by the Society. The NTMA has recommended that I provide a further €2.7bn representing a prudential estimate of the capital required to cover expected losses on INBS’s residual loan book and bringing the total capital support to €5.4bn. I have accepted the NTMA’s recommendation in order to establish a ceiling on the level of support provided to the Society consistent with the objective of providing final clarity on the public support required by the Irish banking system. I propose to inject this capital, subject to European Commission approval, through an increase of the Promissory Note so as to spread the cash requirements over the coming years.
I have asked the NTMA and my other advisors to explore options for the society and to bring finality to the position. Management in INBS was replaced in 2009.This further capital investment by the State will reassure depositors in the institution that all deposits remain secure.
The same approach will be adopted for subordinated bondholders in INBS as in Anglo.
Estimate of final NAMA discount for Bank of Ireland and AIB Bank
Detailed and extensive work has been carried out by NAMA in close consultation with Bank of Ireland and AIB on the remaining loans to be transferred from both banks. This draws on the detailed analysis of the valuations and transfer values from the approximately €10bn. of loans already transferred from these two banks in the previous tranches. It is now possible for NAMA to forecast with confidence the final overall discount to be applied to the remaining tranches of loans from these banks. Both banks have had discussions with NAMA on this matter. This information on the projected final discounts has been conveyed by NAMA to the Central Bank to inform its assessment of the capital position of both banks.
Bank of Ireland
Bank of Ireland has already met the Financial Regulator’s 2010 capital requirement.
To date the Bank has transferred €3.75bn of loan assets to NAMA at an aggregate discount of 36%. While the final tranche of NAMA loans may have a higher discount of up to 42%, the Central Bank has confirmed that the bank has sufficient capital to meet the PCAR standard to accommodate this increase.
The Financial Regulator determined last March that AIB must raise €7.4bn by the end of 2010 to meet its capital requirements. AIB has already announced the sale of its Polish subsidiary BZWBK, expected to generate capital of €2.5bn.
To date AIB has transferred just over €6bn. of loan assets to NAMA at an aggregate discount of 45 per cent. NAMA has reviewed the quality of loans still to transfer from AIB and has estimated discount to be applied to the remaining €13.5bn. of loans at 60 per cent.
A major factor in this increased discount for AIB has been the predominance of land bank loans, many of which were speculative investments that now have little value.
In view of the increased NAMA discount the Central Bank has concluded that an additional amount of €3bn will be required. This brings the new total capital requirement for AIB, after deducting the capital generated on the sale of its Polish subsidiary, to €7.9bn.
The Central Bank Governor, the Financial Regulator and the NTMA have now advised me, and AIB has acknowledged, that in the current stressed market conditions, the bank is unlikely to be able to conduct a traditional privately underwritten transaction.
In order to afford every opportunity to AIB to raise as much as possible of the required capital from the markets and to minimise further Government support, it has been decided that this capital requirement will be met through a placing and open offer to shareholders of AIB shares to the value of €5.4bn. This transaction will be fully underwritten by the National Pension Reserve Fund Commission (NPRFC) at a fixed price of €0.50 per share and is expected to be completed in 2010 subject to shareholder and regulatory approval. If necessary, the NPRFC’s underwriting commitment will be satisfied by the conversion of up to €1.7bn. of its existing preference shares in the bank into ordinary shares along with a new cash investment for the balance of €3.7bn in ordinary shares. This transaction structure assumes the sale of AIB’s stake in M&T Bank and disposal of other assets in due course.
In the event that the bank’s residual capital requirement is not met through asset sales by 31 March 2011, any shortfall will be met by the conversion of a proportion of the remaining €1.8bn. of preference shares. The company will issue a prospectus in relation to the open offer in due course giving details of the transaction, underwriting structure and timing. In the first instance, existing shareholders will be given the option of subscribing for the whole or part of their entitlement to new shares under the offer pro rata to their existing holdings. New institutional shareholders may also be permitted to subscribe for new shares.
Any additional capital required will be provided by the NPRFC.
Ireland is committed to ensuring that all additional aid to AIB will be granted in line with State aid rules. To this end, it will notify the new measures to seek State aid approval before they are implemented.
As a consequence of these actions it is likely that the State will hold a majority shareholding in AIB.
The high level of State support being provided to AIB, as an institution, is absolutely necessary given the central role that AIB plays in the Irish economy and in the Irish financial system. In the coming weeks I will be working closely with the Board of the Bank on behalf of the Government to ensure that AIB successfully overcomes its current challenges and develops a renewed strategic focus on the Irish market following the divestiture of its overseas operations. In conjunction with the recapitalisation, I expect there will be progressive management and board change in AIB. The bank’s board has agreed with Mr Dan O’Connor that he will step down as executive chairman within the coming weeks. The bank’s board has also agreed with the Group Managing Director, Mr Colm Doherty, the termination of his contract on existing terms. Mr Doherty will depart AIB before the end of 2010. I appreciate the commitment of Mr O’Connor and Mr Doherty in this most challenging environment as well as the support they have shown to me.
Educational Building Society
The projected final NAMA discount for EBS is in the region of 60%. The Central Bank has advised that this final discount will have no material implications for the overall capital requirements of the banking system.. The Society is in discussion with a number of parties about its future and any adjustment in its capital need that arises will be accommodated in the outcome of those discussions in due course. The EBS sales process is ongoing.
Repair of the Irish banking system
The overriding benefit of the NAMA process is the recognition of losses upfront by the participating institutions and the cleansing of the balance sheets of our banks of their most toxic loans. Otherwise this lending would remain on the banks’ books representing a major source of risk and instability in the years ahead which would prevent the banking system from playing its essential role in providing the finance required to underpin our economic recovery and fiscal sustainability.
The transparency and clarity achieved through the operation of NAMA has been recognised internationally as a significant strength of the government’s strategy for the repair and the restoration of the banking system.
Fiscal impact of bank restructuring costs in Ireland
As I indicated at the outset of this statement, this Government is committed to restoring sustainability to our public finances. In so doing, we will achieve a General Government Deficit of below 3% by 2014. The inclusion in this year’s deficit of the banking support measures does not alter this commitment in any way.
This target can be achieved in a manner which is consistent with maintaining a sustainable trajectory for Ireland’s General Government Debt and the capacity of the National Treasury Management Agency to fund the Exchequer’s borrowing requirement.
Work is underway on a revised four year plan that will set out the annual measures required to restore order to the public finances and bring our deficit below 3% of GDP by 2014. The four year budgetary plan will be published in early November taking account of the latest economic and fiscal data.
The full amount of the costs for Anglo and INBS is added to Ireland’s General Government Debt which raises the ratio to 98.6 per cent this year. The objective is to stabilise the debt to GDP ratio in 2012/13 period. As has been stressed by the NTMA over recent months, this figure is a gross debt figure and does not reflect the very substantial assets held in the National Pension Reserve Fund, or the substantial cash balances held by the NTMA. On a net debt basis our Debt ratio would be 70.4 per cent of GDP this year.
Today’s announcement brings full clarity to the costs and methods of recapitalising the banks. These costs are fully manageable in the context of the programme of fiscal restraint to which the Government is committed. In addition the cliff in the banks’ refinancing requirements during the month of September, which had been a source of concern to the markets, has passed and the amount of term bank debt maturing over the remainder of this year and next year is quite limited.
I am advised by the NTMA as the Exchequer is fully funded until late June 2011 the Agency has decided not to proceed with the bond auctions scheduled for October and November. The NTMA will return to the bond markets in the normal way in early 2011. In the meantime investors will have had the benefit of the affirmation in the budget that Ireland continues on its planned path of multiannual fiscal consolidation up until 2014