Central Bank publishes three Behind the Data papers examining the international activities of the Irish financial sector
Executive Summary
The Central Bank of Ireland (CBI) published three "Behind the Data" papers on 20 January 2022 analyzing the international activities of Ireland's banking, insurance, investment funds, and non-bank financial intermediation (NBFI) sectors, highlighting post-Brexit asset migrations, insurer exposures via funds, and Ireland's fifth-largest global NBFI sector per FSB metrics. This matters for compliance professionals as it signals heightened CBI scrutiny on cross-border exposures, interconnectedness, and data granularity needs, potentially informing future supervisory expectations, macro-prudential policies, and reporting enhancements without imposing immediate rules. #
What Changed
No direct regulatory changes, requirements, or new rules are introduced; these are analytical papers using existing locational banking, insurance, and fund data. Key insights include: (i) €180bn surge in cross-border bank assets (2018-Q3 2021) driven by UK-to-Ireland subsidiary migrations post-Brexit, concentrated in loans/deposits, derivatives, and three foreign-parent banks; (ii) Irish insurers' fund holdings primarily in equity (US-issued), bond (euro-area government/corporate), and mixed funds, with ~50% domiciled in Luxembourg but minimal local issuance; (iii) Recommendation for refined banking statistics distinguishing Irish-parent vs. foreign-parent banks to aid supervision. The NBFI paper applies FSB framework to classify activities posing bank-like stability risks, noting Ireland'
What You Need To Do
- Review and enhance internal reporting on cross-border assets, distinguishing Irish-parent vs
- Map insurer fund exposures to underlying assets (e
- Assess NBFI activities against FSB economic functions for stability risks; prepare for possible granular data requests
- Monitor CBI's "Behind the Data" series for evolving trends, as it uses firm-submitted data and fulfills IMF recommendations (e
Key Dates
Compliance Impact
Urgency: Low – This is informational analysis from 2022 with no binding rules, deadlines, or enforcement; it matters indirectly by flagging data gaps (e.g., parent distinction) that could shape future CBI supervision, macro-prudential tools, or reporting burdens, especially amid ongoing Brexit/NBFI focus. Firms with foreign parents or fund-heavy portfolios should note for risk monitoring, but no i
Who is Affected
Summary
Recent increase in cross-border financial assets is largely due to migration of assets from UK banks to subsidiaries in Ireland, to continue to serve EU clients after Brexit. Paper examining the strength of the connectedness of Irish insurance sector and investment funds finds insurers primarily hold shares in equity, bond, and mixed funds. The Irish non-bank financial intermediation sector – as measured using a Financial Stability Board framework - is the fifth largest in the world. The Cent...