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Economics Legislation Committee - 29/04/99 - Financial sector reform bills

CHAIR —Welcome. Before I ask for questions, are there any comments you wish to make now in relation to evidence that we have already heard?

Dr Roberts —APRA supports the legislation before the committee. APRA is looking forward to the transfer of the state based functions and supervisors. I think, from our point of view, the sooner it happens the better. It helps reduce the uncertainty for staff and helps people get on with the job.

In relation to staffing matters—and there was some discussion earlier with people from the FSU and the CPSU—that is not really my area. I can take matters on notice and undertake to get written replies back to the committee by COB tomorrow. APRA's position is that it has complied with all its obligations to staff under all the relevant acts and other requirements, and it will continue to comply with those. We certainly do not accept that there has been any violation of employment requirements by APRA.

Mr Lindwall —I want to point out the major difference between the status quo and what will happen: APRA regulates approximately 15 banks now, whereas under the new arrangements it will be taking on about 237 credit unions, 20 building societies and 85 friendly societies. One of the major reasons for the transfer of business bill—which we will obviously talk about in questions a little bit more—is, because of the great magnitude in terms of numbers of institutions, it is more likely to need that prudential tool which has not been present in the Commonwealth's sphere previously but has been in the states' and territories'.

I think there may also be a misconception in some of the previous testimony in respect of the word `Treasurer' in legislation as opposed to the word `minister'. In actual fact, because of the recent overturning of the Foster case and because of the Acts Interpretation Act, they in fact have no difference in actual practice. Another minister can act on behalf of the Treasurer, just as if it is written `Treasurer or minister', so in practice there is no difference at all. Therefore, hypothetically, under the Financial Sector (Shareholdings) Act, which is one of the tools to affect the four pillars policy, a minister other than the Treasurer could authorise such a transfer.

Mr Sellars —The only issue that was raised this morning that concerns me was the issue raised by Mr Pickersgill concerning the shares and guarantee issue. I am happy to answer that question generally, but I will seek leave to make some more detailed written submissions as well.

CHAIR —If you would like to comment on it now you can.

Mr Sellars —Mr Pickersgill only had one issue with the bill which was that friendly societies without shares on issue do not have the option of electing to become a company limited by shares alone. The position under the bill is that a friendly society with no shares on issue automatically becomes a company limited by guarantee.

Senator WATSON —The point is that that provision does not apply to building societies.


Mr Sellars —I will get to the distinction in a moment. They become a company limited by guarantee, and that means that all members are deemed to have provided a guarantee for the purposes of working out if they are a member. But there are provisions that ensure that that does not detrimentally affect their financial position in the event that the company is wound up at a later time, and so anyone who joins the friendly society prior to the placing of the guarantee into the company's constitution will not incur any liability.

The key thing that a friendly society would have to do would be to insert a paragraph into its constitution saying what the amount of the guarantee is. It is quite likely that they would choose a nominal amount, just as nearly all companies limited by guarantee do now. In that sense, they would become much like life insurance companies have been in the past. There are numerous examples of companies limited by guarantee that have operated quite successfully using that structure.

Senator WATSON —But why distinguish between a building society and friendly society?

Mr Sellars —Yes, I acknowledge that that does not answer the distinction made in the bill between a friendly society and a building society with no shares on issue. It is really based on a combination of factors involved here which I will just talk about generally. Because it does require references to clauses and so forth, I will give a detailed explanation to the committee in writing.

One of the factors is the membership share. Mr Pickersgill referred to the idea that the membership share is their vehicle of preference. The membership share, as set out in the bill, is not designed to be an ongoing way to structure a company. It is a transitional arrangement and it is a legislative device to enable members who do not hold shares to become members of a company limited by shares. The reason is that all members of companies limited by shares must hold a share for two reasons: one, because that is what their membership rights are attached to and, two, that is the device that limits their liability.

The guarantee will be put in place, as I mentioned, through an amendment to the constitution. The membership share vehicle is a statutory thing which has a limited life in that it must be replaced by something which is recognised in the constitution; it is a creature of statute. The friendly societies, as I understand it, would like to use a no[hyphen]value type share like that as their ongoing vehicle of membership. There would need to be other changes to the Corporations Law, or at least modifications made by regulation, to enable that sort of thing to occur.

The second issue is that there are some interactions with other laws at the state and Commonwealth level because of the status of friendly societies. I would just like to point out to the committee that, although it looks like a simple amendment to just include `limited by shares' as an option in clause 12, there are flow[hyphen]on effects which need to be taken into consideration. It is more complex than just that simple amendment. They are the only comments I have to make at this stage.

Senator WATSON —Some of the people who are members of friendly societies are people of very low income. Can you give us an idea of what that level of guarantee is going to require?

Mr Sellars —Most companies limited by guarantee have a nominal amount. It is usually a $10 amount now; it could be $5, it could be $2, it could be $1. It is payable when a company goes into liquidation if there is a shortfall in the assets. In practice, it is unlikely that a liquidator of such a company would go to a great deal of trouble to recover the $1, or even the $10. So we are not talking about a large financial imposition on anyone, just as for a


member of most companies limited by guarantee now it is not something that enters into the equation.

Senator WATSON —So what you are telling us now does not require a legislative action. Can you give us an assurance that a letter will be sent to every friendly society nominating the upper amount of the guarantee?

Mr Sellars —It is envisaged that the way that the upper amount of the guarantee would be regulated is that it would be a streamline mechanism for insertion of that paragraph into the constitution. But that streamline mechanism will not be available for a fixed amount which is yet to be determined but will probably be in the region of $50.

Senator WATSON —You were telling us $10, $5 or $1; now it is $50.

Mr Sellars —Whatever the amount is does not affect existing members or anyone who joins prior to the time the guarantee is inserted into the constitution. That is what the bill provides for.

Senator WATSON —For new members?

Mr Sellars —Yes.

Senator WATSON —Are you going to give a specific letter to every friendly society outlining that, and outlining the maximum amount that any friendly society member might be up for in the event of liquidation? That is what we have to satisfy ourselves on, if you are not going down the limited share route.

Mr Sellars —Just like a company limited by a guarantee now. They are in almost the same position as a company first starting up in limited by guarantee form.

Senator WATSON —Yes, but I think everybody is entitled to know what the new rules are going to be and also the rules that are going to apply to their existing members so that there are no questions asked, because some of these friendly societies are not all that sophisticated in terms of their structures.

Mr Sellars —Indeed.

Senator WATSON —I do not want to frighten people out of friendly societies. Because there is this big question about a guarantee and the amount is quite a bit uncertain, I want to put some certainty into it. How can we get that certainty? Give us your undertakings of what you are going to do to give us greater certainty.

Mr Sellars —If you wanted to put a statutory limit on it, that is a matter of policy.

Senator WATSON —We might have to. We have to protect these people in some way so that they are not in a worse position compared with the building society, where their liability is limited to the extent of unpaid amounts on the share. People have a guarantee, and there is no statutory base or no formal exchange of letters to say that they will have an upper limit of $5, $10 or even $50, or whatever the figure is. But I would certainly baulk at a figure much above $20, given that the people who are members of friendly societies are predominantly low income people.

Mr Sellars —The proposal was that any level of guarantee would need to be put to the existing members, but they will not be affected anyway unless it was done by this streamline mechanism, which would be limited to a low amount.

Senator WATSON —How do you intend to give legislative backing or some sort of legal backing to this limit that will apply to friendly society members? I have to declare an interest. My wife works for a friendly society. That is why I am rather interested in getting it right.


Mr Sellars —There could be a statutory limit—

Senator WATSON —I am not happy about `there could be'. There has to be a `will be', as far as I am concerned.

Mr Sellars —I cannot say what will be. Could I put the reply through the minister?

CHAIR —I do not think the officer is entitled to say what the government should be doing or what the government must do. That is a policy decision for the government, Senator Watson.

Senator WATSON —The whole purpose is to have a degree of harmony between all these organisations that are going to join APRA. In the interest of ensuring this harmony, I just want to make sure that the members of one group who are joining are not going to be disadvantaged in the future compared with other groups simply because the arrangements are different. I am saying that, if they are different, they have to minimise those differences. I would like to know in advance what the extent of that guarantee is going to be for new members.

CHAIR —Senator Watson, he indicated that he would reply through the minister because it is a government decision, not a decision for the officer.

Senator WATSON —Yes. Also, I want to know the nature of the communication that you are going to make, because I think the existing members need to have that letter that they are not subject to the guarantee, it is only new members.

Mr Sellars —It is a matter for the rules of each entity concerned.

Senator WATSON —As far as we are concerned, we have got to make sure that there is a degree of uniformity, that friendly society A does not have $10 and another one has $1,000.

Mr Sellars —I would like to point out, though, Senator, that it is possible under the existing Corporations Law to move from a company limited by a guarantee structure to guarantee and shares or shares alone. That option is still open.

Senator WATSON —That is not the way it reads at the moment, according to this bill. Which has preference: that option, or the new legislation which says that friendly societies cannot have an option with shares?

Mr Sellars —On transfer, that is quite true, but after transfer there are facilities to change classifications of company. This will be set out in detail in a written response.

Senator WATSON —To the committee?

Mr Sellars —Yes.

Senator GEORGE CAMPBELL —Dr Roberts, I think you said earlier that you heard the evidence given by the unions today with respect to the approach taken by APRA in dealing with staff. I understand the point you made, and you may not be able to answer these questions but I will ask them anyway. If you cannot answer them, I would ask you to get a response from APRA. The unions have raised concerns about the way in which state and territory employees have been asked to apply for employment with APRA and the fact that they are only being offered AWAs. Why is there that particular decision not to offer them choice?

Dr Roberts —I will have to take that one on notice.

Senator GEORGE CAMPBELL —I also refer you to the letter that was sent to Graeme Thompson on 23 April by Mr Waters, the national organiser for the CPSU, in which he refers to a letter sent by Mr Thompson to the national secretary of that union, Ms Wendy Caird. It in part states:


Clearly the negotiation of that certified agreement will be a priority matter for both management and staff.

It is referring to the use of a certified agreement to harmonise workplace terms and conditions across APRA. Mr Douglas, who represented APRA in the hearings in the commission, indicated that APRA had given no commitment to negotiate a certified agreement. Can you comment?

Dr Roberts —Again, I will have to take that on notice. I should say that the human resource policy and the industrial relations handling is not in my area. My understanding is also that we do not have the benefit of having seen the CPSU's and FSU's submission to the committee. We are happy to undertake to get replies to all your questions back to the committee by tomorrow.

Senator GEORGE CAMPBELL —I am keen to get a clear statement from Mr Thompson on what he believes he did offer in that letter to the national secretary of the union, Ms Caird. The third question that I ask you to take on notice is that in this letter it refers to a number of determinations that were signed by Mr Carmichael on 1 July 1998 with respect to the terms and conditions of ISC staff transferring over, the agreements applying to the RBA transferees and the terms and conditions that would apply until a certified agreement is made with APRA employees.

Mr Douglas again in those hearings indicated that APRA no longer feels bound by these undertakings. Can we ask you for a response about why they feel they are no longer bound by the undertakings that were given by the chairman of APRA? What circumstances have changed and what reasons are there as to why they feel no longer bound? Given that roughly 65 per cent of the staff have signed the petition seeking the certified agreement, why is APRA resisting negotiating a certified agreement with that staff? Can I also ask you to take that on notice?

Can I also ask you to take on notice a couple of other questions that were raised in relation to the operation of section 45 of the APRA Act. For what reason does APRA believe that it is not covered by the provisions of the Workplace Relations Act 1996?

Can I also ask you to give us a response in respect to what the attitude of APRA will be to those persons who apply for appointments with APRA—either new employees or existing state and territory employees—who refuse to sign an AWA? What attitude will APRA take to their employment?

Dr Roberts —I think the CEO addressed that in the information material that this issue referred to. The CEO said in this question and answer material provided to staff under the heading, `Why should I sign an AWA; what if I don't?' He said that it is not compulsory to sign an AWA. If a person decided against working under an AWA in the new structure, APRA would offer the new terms of employment through a letter of engagement or common law contract. The person was then entitled to appoint a third party such as a union, a solicitor or any other person to represent him or her during negotiations over entering into an AWA. APRA recognised that some staff may wish to be represented and welcomed the opportunity to engage in negotiations with a nominated bargaining agent. A person could not be dismissed for refusing to sign an AWA.

Senator GEORGE CAMPBELL —I am pleased that he put that in writing. That does not go to the issue of choice of the employee as to the method under which his terms and conditions of employment will be regulated.

Dr Roberts —I will take it on notice.


Senator GEORGE CAMPBELL —The difference between an AWA and a common law contract is arguable. I will ask you to take that on notice and give us a specific response.

Dr Roberts —Yes, Senator. I am assuming that Mr Hallahan can fax us the written version of the questions.

Senator GEORGE CAMPBELL —It has been anticipated by the financial sector that the scheme set up by the bills subject to this inquiry would come into effect on 1 July this year. Furthermore, the date may be pushed back to 1 October 1999, at least for the transfer of staff from state bodies to APRA. Does APRA anticipate the scheme commencing on 1 July?

Dr Roberts —That is what we are working towards at present.

Senator GEORGE CAMPBELL —Has legislation been introduced in the state and territory parliaments as yet?

Mr Lindwall —My understanding is that at least Victoria has legislation entered into its Lower House.

Senator GEORGE CAMPBELL —Only Victoria?

Mr Lindwall —That is my understanding at this point in time, yes.

Senator GEORGE CAMPBELL —Given that is the case, what is the likelihood of it starting on 1 July?

Mr Lindwall —I do not have an assessment on the likelihood, but I do point out that obviously it requires all states and territories to pass the necessary legislation across the Commonwealth before 1 July in order to have it start on 1 July. At this point in time, 1 July is still the target date.

Senator GEORGE CAMPBELL —Does that seem likely to you given that we are almost in the bay?

Mr Lindwall —I cannot comment on that.

Senator GEORGE CAMPBELL —I suggest to you that it seems very unlikely. Does APRA consider that the Treasurer should consent to all transfers under the transfers bill?

Dr Roberts —APRA's view is that it should always comply with government policy and that the Treasurer would certainly be consulted on any major proposals, sensitive proposals or contentious proposals.

Senator GEORGE CAMPBELL —Why does schedule 8, item 7, propose that new ADIs `may' rather than `must' be dealt with as if their authorisation and conditions had been imposed under the Banking Act? Why should it not be `must'?

Dr Roberts —May determine conditions to which the authority is subject?

Senator GEORGE CAMPBELL —Yes.

Dr Roberts —That is the existing arrangement for licensing banks, and I would suspect that under the FI scheme as well that—

Senator GEORGE CAMPBELL —I would suggest you have a discretion. Is that the intent of the legislation: to put a discretion in there?

Dr Roberts —I believe it is.

Mr Lindwall —Yes.

Senator GEORGE CAMPBELL —Can you explain the voluntary transfer mechanism proposed under the transfers bill?


Mr Lindwall —Could I first make a couple of points of a similar nature. Firstly, the heart of this concern is, as I think you mentioned, about the minister's consent being waived. It is worth pointing out that, for example, the other four pillars legislation, such as the Financial Sector (Shareholdings) Act, the Banking Act and the Insurance Acquisitions and Takeovers Act, all provide the ability for the Treasurer or the minister to delegate responsibilities.

For example, section 44 of the Financial Sector (Shareholdings) Act provides an explicit delegation power to APRA in relation to acts under that particular act. It is a similar situation with section 69 of the Insurance Acquisitions and Takeovers Act. Section 63 of the Banking Act is delegated to APRA in certain cases. All of those delegations are made by written instruments by the Treasurer or the minister, as the case may be, and they are not subject to be tabled in parliament or anything like that. So the consent requirement in the transfers of business bill—in clause 15, for example—that consent is not required is not dissimilar in effect, therefore, to the sections that are in these other acts.

The voluntary transfer mechanism, which is basically part III of the transfers of business bill, requires a number of conditions to be met before APRA can approve a voluntary transfer. Before I go on, let us not forget that the purpose of this is as a prudential regulation tool, and therefore it is protecting the depositors' interests in the case of DTIs. APRA cannot approve a voluntary transfer unless the interests of the depositors or policy owners of the transferring body, when viewed as a group, have been met.

There are also the interests of the receiving body, the interests of the financial sector as a whole and other matters that it can consider. Also, it has to be satisfied that it is adequately adopted. What that means is that APRA will be required to put an instrument into parliament—which is disallowable—which will set out the conditions that constitute adoption by the transferring body and the receiving body. For example, it might be how much notice is needed to be given to the members of a building society or it might be how many votes are needed by the members to constitute approval of that type of process. All of those conditions have to be met.

Senator GEORGE CAMPBELL —Are you saying those will be disallowable instruments?

Mr Lindwall —They will be disallowable instruments under clause 46 of the bill. In addition, regulations under clause 43(4), which was testified to earlier in the day, can be made which explicitly require that APRA take account of these particular acts. As you might be aware, Minister Hockey made a commitment in parliament—I cannot remember the exact date but it was last month—to prescribe the relevant sections of the Trade Practices Act, the Financial Sector (Shareholdings) Act, the Insurance Acquisitions and Takeovers Act and the Foreign Acquisitions and Takeovers Act under subclause 43(4) of the transfers of business bill. Subclause 11(2) of the transfers of business bill states:

APRA must not approve the transfer of business if, having regard to a law prescribed for the purposes of subsection 43(4), it considers that the transfer should not be approved.

Furthermore, the effect of such prescription under 43(4) ensures that those particular acts operate independently of these acts. So, even if APRA did not follow this rule—don't forget that it says `must not approve' but let us say hypothetically it did approve something—it would still be subject to section 50 of the Trade Practices Act, and therefore the ACCC could void a divestiture. Does that go to your question?

Senator GEORGE CAMPBELL —Yes. Just on the question of the ACCC, the transfer of business bill currently provides that APRA `may'—rather than `must'—consult with the ACCC, ASIC and the Reserve Bank.


Mr Lindwall —That is correct; yes.

Senator GEORGE CAMPBELL —Are you aware of why it has that discretion?

Mr Lindwall —It is basically because—if you recall that there are a large number of institutions of varying size, some very small and some very large—there are cases where you can envisage that it would not be something that the ACCC would be interested in, nor the RBA. The Reserve Bank is interested in overall systemic issues. A transfer involving two small credit unions is not raising any systemic issues for the financial sector as a whole. It is not something the Reserve Bank would be interested in and, in the case of the ACCC, it also does not substantially lessen competition.

But because they are prescribed—remember that subclause 11(2) means that APRA must not approve the transfer of business—clearly, if APRA is in doubt as to whether it might, then it is incumbent on APRA to consult that. It would therefore, I would expect—I might ask APRA to confirm this—consult as necessary.

Dr Roberts —If I could just say a few things about that bill as well. First, perhaps I should mention APRA's accountability because I think the word `accountability' was mentioned in previous evidence. APRA is far more accountable than the Insurance and Superannuation Commission was, for example.

We have a board which has a majority of independent members. We are subject to the Commonwealth Authorities and Companies Act, which, for example, includes corporate governance requirements that parallel the Corporations Law in respect of non[hyphen]public sector companies. Among the act's requirements it sets out our accountability and our need to report to the minister. In the APRA Act as well, we have an ultimate accountability to the Treasurer. So there is a lot of accountability there and it is not possible for us to undertake major initiatives in the financial sector in a secretive manner.

The transfers of business arrangements: there is a history of experience with them in the FI scheme between 1992 and now. That has been almost entirely, according to my understanding, in relation to small mutual organisations that operate within the one state. Whether or not institutions operate within one state or several states is relevant because of stamp duty requirements which vary from state to state. The mutuality is relevant because there are far more complicated issues involved if there needs to be a balancing of the rights of shareholders as well as members of institutions as well as depositors.

It seems to us to be a useful extra tool to have in the prudential supervisors' armory, so that in the case of a troubled institution—and particularly a small troubled institution like a small credit union—you have the option of transfers of business where, in effect, you can fast[hyphen]track a merger between two credit unions in the interests of the depositors. However, it is inconceivable to me—this is a personal view, perhaps I should say—that APRA could ever invoke that kind of arrangement in relation to large institutions or institutions where there are sensitivities, where there are particular special issues or where there are any contentious issues.

The fact is that with any substantial merger proposal of a large, diversified institution operating in more than one state, listed on the stock exchange with shareholders whose interests have to be weighed up against the shareholders of the receiving institution, you are talking about a very complicated exercise. You are not talking about a six[hyphen]week transfers of business exercise. You are talking about an exercise where inevitably the Treasurer would have to be consulted, the ACCC would have to be consulted, probably the institutions would need—as they have in the past for major mergers—to go round and persuade states to enact special


state legislation to give them some relief from stamp duty, and there are capital gains tax implications at the Commonwealth level.

It is a highly complicated exercise and to me it is inconceivable that, without any consultation, you would try and invoke this mechanism in relation to large institutions like that. It is very much something that is suited and tailored towards a small neutral operating within one state, where both the troubled building society or credit union and the receiving one were in agreement and where the members are protected and have been informed. So I think the notion that this has any relevance to the four pillars is just not realistic.

Senator GEORGE CAMPBELL —But, given all you have said, Dr Roberts, it still remains that there is a discretion with APRA in terms of whether it consults or not.

Dr Roberts —We would consult. I can assure you we would consult with the Treasurer and with the ACCC on any major proposal.

Senator GEORGE CAMPBELL —That is your assurance. The unions are not so happy with some assurances or indications that were given to them as little as six or nine months ago.

Dr Roberts —They have very suspicious mind[hyphen]sets, I might say. I think our assurances are worth something.

Senator GEORGE CAMPBELL —I think that Mr Douglas, on behalf of APRA, made it quite clear that the commitments they thought they had were no longer relevant. But I am really coming back to this point again: has APRA set up internal guidelines for the staff or for the board for when they are making judgments on whether or not certain mergers ought to be reported, or for what the criteria are for consultation?

Dr Roberts —We will comply of course with the letter and spirit of the legislation. I do not think it is appropriate—

Senator GEORGE CAMPBELL —Have you developed any internal guidelines?

Dr Roberts —We develop guidelines over time and we do not have this legislation yet. I would point out that, in relation to the ACCC, there has been a practice in relation to agencies with which we are required to cooperate—including the Reserve Bank, Treasury and the Australian Securities and Investments Commission—of developing memoranda of understanding which set out the respective responsibilities of the two agencies, the protocol that they will follow in consulting each other, information sharing and so on. Those have been completed in relation to the Reserve Bank, ASIC and Treasury and they are publicly available on our web site. We are happy to table those two. The likelihood is that we will be entering into discussions with the ACCC about protocols for matters of common interest between us. That has not happened yet but is just in the course of finding a convenient opportunity.

Senator GEORGE CAMPBELL —Do you consider that the transfers bill should operate to the exclusion of all other acts?

Dr Roberts —It would depend on the circumstances. In the case of a small credit union which is a mutual and which operates within one state where there are no systemic or national interest issues involved, that can be a convenient way to protect the depositors in that circumstance. It would not be appropriate for a substantial proposal involving major diversified institutions which raised sensitive issues.

Senator GEORGE CAMPBELL —Do you have any concern about any potential loss of legislative safeguards that currently exist for mergers and acquisitions?


Dr Roberts —No.

Mr Lindwall —Basically, the philosophy of having the way it is structured at the moment with a particular prescription under clause 43(4) was to not nobble the effectiveness of the bill, because there are a large number of laws which can ostensibly factor into a consideration. When you are looking at it as a prudential regulation tool, remember that, when an institution such as a bank gets into trouble, it is more likely to engage in risky behaviour, and that behaviour eventually comes at a cost to the public as a whole—the taxpayers—inevitably, for any particularly large institutions. That was quite easily seen in the US with the savings and loans situation. This is another tool for prudential regulation. It is nothing more than that. It is designed to provide a means to protect depositors in the event of certain conditions being met. That is basically what I would say about that.

Senator CHAPMAN —I have got a question to ask on behalf of Senator Watson in relation to the reductions in staff. Do you consider that there is likely to be any reduction in the scrutiny responsibilities of APRA as a result of not having as many staff available through those reductions?

Dr Roberts —No, there will not be any reduction in scrutiny or the degree of prudential security. Again, I was surprised by some previous evidence where numbers in the mid[hyphen]500s down to the mid[hyphen]400s were mentioned. I think that is completely wide of the mark. My understanding is that, once the state based staff are brought on board and the new APRA organisation is complete, there would be a reduction of about 10 staff from the existing complements. That 10[hyphen]staff saving reflects some overlap in back office activity.

Whereas, you have a number of agencies now—10, if you include the Commonwealth agencies, the eight state based ones and AFIC—bringing those into APRA means there will be some overlap in back office administrative support. My understanding is that there will be a very minor net reduction in staffing of about 10—from 456 to 446, essentially.

Senator GEORGE CAMPBELL —I have a series of other questions which are really Senator Conroy's questions. I am happy to put them on notice and get the responses in writing. There is a fair bit of detail in them and, rather than try to labour through them, we could do that and get a quick response.

Dr Roberts —Yes.

ACTING CHAIR (Senator Chapman) —If there are no further questions, I declare the hearing closed. Thank you for your attendance.

Committee adjourned at 12.41 p.m.