Opinion of the European Central Bank of 18 June 2020 on the appointment of the Central Bank of Ireland as registrar for registers of beneficial ownership for certain financial entities (CON/2020/18)
Date: 2020-06-18
Institutions: European Central Bank
Subjects: legal basis

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 18 June 2020 

on the appointment of the Central Bank of Ireland as registrar for registers of  

beneficial ownership for certain financial entities 

(CON/2020/18) 

Introduction and legal basis 

On 27 May 2020 the European Central Bank (ECB) received a request from the Irish Minister for Finance 

for  an  opinion  on  draft  European  Union  (Modifications  of  Statutory  Instrument  No.  110  of  2019) 

(Registration  of  Beneficial  Ownership  of  Certain  Financial  Vehicles)  Regulations  2020  (hereinafter  the 

‘draft  regulations’).  In  addition,  on  9  June  2020  the  ECB  received  a  further  request  for  an  opinion  on  a 

draft  Investment  Limited  Partnerships  (Amendment)  Bill  2020  (hereinafter  the  ‘draft  law’,  and  together 

with the draft regulations, the ‘draft laws’). 

The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the 
Functioning of the European Union and the third indent of Article 2(1) of Council Decision 98/415/EC1, as 

the  draft  laws  relate  to  the  Central  Bank  of  Ireland  (CBI).  In  accordance  with  the  first  sentence  of 

Article 17.5 of the Rules of Procedure of the European Central Bank, the Governing Council has adopted 

this opinion. 

1. 

Purpose of the draft regulations and laws 

1.1  Draft regulations 

The  draft  regulations  provide,  inter  alia,  for  the  establishment  and  maintenance  of  the  Central 

Register  of  Beneficial  Ownership  of  Irish  Collective  Asset-management  Vehicles,  Credit  Unions 

and  Unit  Trusts  (hereafter  the  ‘Register’)  in  Ireland.  The  draft  regulations  give  further  effect  to 
Article  30  of  Directive  EU/2015/8492  as  amended  by  Article  1(15)  of  Directive  EU/2018/8433,  in 

order  to  facilitate  the  prevention,  detection  or  investigation  of  money  laundering  or  terrorist 

financing.  The  draft  regulations  require  certain  financial  vehicles,  including  Irish  collective  asset 

management vehicles, unit trusts and credit unions, to register information on this central register in 

Ireland. The Register will co-exist alongside the existing Central Register of Beneficial Ownership 

1  

2  

3  

Council  Decision  98/415/EC  of  29 June  1998  on  the  consultation  of  the  European  Central  Bank  by  national 
authorities regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42). 
Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use 
of  the  financial  system  for  the  purposes  of  money  laundering  or  terrorist  financing,  amending  Regulation  (EU) 
No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European 
Parliament and of the Council and Commission Directive 2006/70/EC (OJ L 141, 5.6.2015, p. 73).  
Directive  (EU)  2018/843  of  the  European  Parliament and  of  the  Council  of  30  May  2018  amending  Directive  (EU) 
2015/849  on  the  prevention  of  the  use  of  the  financial  system  for  the  purposes  of  money  laundering  or  terrorist 
financing, and amending Directives 2009/138/EC and 2013/36/EU (OJ L 156, 19.6.2018, p. 43). 

 
 
 
 
                                                 
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of  Companies  and  Industrial  and  Provident  Societies,  which  is  operated  by  the  Irish  Companies 

Registration  Office,  and  in  respect  of  which  corporate  and  other  legal  entities  incorporated  in 

Ireland  are  required  to  obtain  and  hold  adequate,  accurate  and  current  information  in  relation  to 
their beneficial owners.4 

1.2  The  draft  regulations  facilitate  the  appointment  by  the  Irish  Minister  for  Finance  as  the  registrar 

responsible for the establishment and maintenance of the Register.  

1.3  Draft law 

The  draft  law  amends  the  Investment  Limited  Partnerships  Act  1994,  the  Irish  Collective  Asset-

management  Vehicles  Act  2015  and  the  Investment  Funds,  Companies  and  Miscellaneous 

Provisions Act 2005 and provides for related matters. The draft law proposes to establish central 

registers in Ireland which will be established and operated by the CBI and will be called the Central 

Register  of  Beneficial  Ownership  of  Common  Contractual  Funds  and  Investment  Limited 

Partnerships (together with the Register, the ‘Registers’). 

1.4  Key attributes of the Registers under the draft laws 

As registrar, the  CBI will be required  under the draft laws to  enter the required information in the 

Registers and to keep the Registers in such form as the CBI considers appropriate. In the context 

of  discrepancies,  the  CBI  may  make  an  entry  into  the  Registers  that  specifies  the  particulars  as 

regards the notice of discrepancies received from a relevant entity required to register.  

1.5  As  registrar,  the  CBI  will  be  required  under  the  draft  laws  to  afford  the  maker  of  a  request  for 

inspection access, in a timely manner, to the Registers. While the Registers are available for public 

inspection,  persons  who  have  a  right  to  inspect  the  Registers  for  specific  information  (i.e. 

unrestricted  access)  include  specified  entities,  including  members/officers  of the  Garda  Síochána 

(Irish police), the Irish Finance Intelligence Unit, the Revenue Commissioners, the Criminal Assets 

Bureau, or a competent authority engaged in the prevention, detection or investigation of possible 

money laundering or terrorist financing, and do not include members of staff of the CBI, unless they 

are authorised and  of a  specified  grade. The  CBI  will not  alert any relevant  entity to the fact that 

unrestricted  access  to  the  Registers  has  been  afforded  to  any  other  entities.  The  CBI  will  also 

arrange for the connection of the Registers to registers in other Member States. 

1.6  The draft laws provide that the Commission of the CBI will make regulations prescribing dedicated 

levies to be paid by entities that are required to register information on the Registers. The moneys 

received  by  the  CBI  by  way  of  such  levies  will  be  used  to  defray  the  CBI’s  expenses  associated 

with its functions under the draft laws. The CBI shall not provide any funds from its own resources 

other  than  the  dedicated  levies  to  defray  the  CBI’s  expenses  incurred  in  the  performance  of  its 

functions  under  the  draft  laws.  Where  in  any  year  the  CBI  reasonably  apprehends  that  it  will  be 

unable  to  defray  all  of  its  expenses  arising  in  that  year  from  moneys  received  by  way  of  the 

dedicated levies, or where for any reason there is an insufficiency in any year of moneys available 

to the CBI to defray all of its expenses, the Irish Minister for Finance will, on written request of the 

CBI, advance to the CBI such sums as he or she thinks proper to enable the CBI to defray all of its 

4  

See  European  Union  (Anti-Money  Laundering:  Beneficial  Ownership  of  Corporate  Entities)  Regulations  2019  (S.I. 
No. 110 of 2019) (hereinafter the ‘2019 Regulations’).  

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expenses. The advancement of these sums will be made on such terms as regard to repayment, 

interest and other matters as may be determined by the Minister after consulting the CBI. As soon 

as may be after the commencement of the draft regulations, the CBI will consult, with the Minister 

in relation to what the CBI estimates, as best it may, to be the likely amount of expenses incurred 

by  the  performance  of  the  functions  under  the  draft  regulations,  and  will  have  regard  to 

recommendations  the  Minister  may  decide  to  make  to  the  CBI  insofar  as  the  Minister  considers 

them likely to limit the amount of those expenses.  

2. 

Conferral of a new task on the Central Bank of Ireland 

2.1  New task of the Central Bank of Ireland 

2.1.1  It is foreseen that the establishment and maintenance of the Registers will be conferred on the CBI.  

The  establishment  and  maintenance  by  the  CBI  of  the  Registers  is  distinct  and  separate  to  the 

CBI’s existing role as supervisor of compliance by credit and financial institutions with anti-money 

laundering  (AML)  requirements  and  combating  the  financing  of  terrorism  (CFT)  requirements. 

Rather, the maintenance of the Registers will facilitate the investigative role of the law enforcement 

authorities in Ireland, which have access to the Registers, and will enable obliged entities to meet 

their obligations under AML law to identify beneficial owners. 

2.1.2  The ECB underlines that a proposed conferral of new tasks on a national central bank (NCB) in the 

European System of Central Banks (ESCB) must be assessed against the prohibition on monetary 

financing under Article 123 of the Treaty. For the purposes of that prohibition, Article 1(1)(b)(ii) of 
Council  Regulation  (EC)  No 3603/935  defines  ‘other  type  of  credit  facility’,  inter  alia,  as  ‘any 

financing of the public sector’s obligations vis-à-vis third parties’. 

2.1.3  Ensuring that Member States implement a sound budgetary policy is one of the key objectives of 
the  monetary  financing  prohibition,  which  may  not  be  circumvented6.  Therefore,  the  task  of 

financing  measures,  which  are  normally  the  responsibility  of  the  Member  States,  and  which  are 

financed from their budgetary sources rather than by the NCBs, must not be entrusted to NCBs. To 

decide what constitutes financing of the public sector’s obligations vis-à-vis third parties, which can 

be translated as the provision of central bank financing outside the scope of central bank tasks, it is 

necessary  to  carry  out,  on  a  case-by-case  basis,  an  assessment  of  whether  the  task  to  be 

undertaken  by  an  NCB  is  a  central  bank  task  or  a  government  task,  i.e.  a  task  within  the 

responsibility  of  the  Member  States.  In  other  words,  adequate  safeguards  must  be  in  place  to 

ensure that circumventions of the objective of the monetary financing  prohibition of maintaining a 

sound budgetary policy of Member States do not take place. 

2.1.4  As part of its discretion in the exercise of its duty, on the basis of Article 271(d) of the Treaty and 

Article 35.6 of the Statute of the ESCB, to ensure that NCBs honour the obligations laid down by 

the Treaty, the Governing Council has endorsed safeguards of that kind in the form of criteria for 

determining  what  may  be  seen  as  falling  within  the  scope  of  a  public  sector  obligation  within  the 

5  

6  

Council  Regulation  (EC)  No  3603/93  of  13  December  1993  specifying  definitions  for  the  application  of  the 
prohibitions referred to in Articles 104 and 104b(1) of the Treaty (OJ L 332, 31.12.1993, p. 1). 
Article  123  of  the  Treaty  also  serves  the  objective  of  maintaining  price  stability  and  reinforces  central  bank 
independence. 

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meaning of Article 1(1)(b)(ii) of Regulation (EC) No 3603/93 or, in other words, what constitutes a 

government task as follows: 

First, central bank tasks are in particular those tasks that are  related to the tasks that have been 

conferred upon the ECB and the NCBs by the Treaty and the Statute of the ESCB. These tasks are 

mainly defined in Article 127(2), (5) and (6) and Article 128(1) of the Treaty, as well as Article 22 

and Article 25.1 of the Statute of the ESCB. 

Second, as Article 14.4 of the Statute of the ESCB allows NCBs to perform ‘other functions’, new 

tasks, i.e. tasks that are not related to tasks that have been conferred upon the ECB and the NCBs, 

are  not  precluded  per  se.  However,  new  tasks  that  are  undertaken  by  an  NCB  and  which  are 

atypical of NCB tasks or which are clearly discharged on behalf of, and in the exclusive interest of 

the government or of other public sector entities should be considered government tasks. 

Third, an important criterion for qualifying a new task as atypical of an NCB task or as being clearly 

discharged  on  behalf  of  and  in  the  exclusive  interest  of  the  government  or  other  public  sector 

entities  is  the  impact  of  the  task  on  the  institutional,  financial  and  personal  independence  of  that 

NCB. 

In particular, the following aspects should be taken into account: 

(a)  whether  the  performance  of  the  new  task  creates  conflicts  of  interest  with  existing  central 

bank  tasks,  which  are  not  adequately  addressed,  and  does  not  necessarily  complement 

those  existing  central  bank  tasks.  If  a  conflict  of  interest  arises  between  existing  and  new 

tasks, sufficient safeguards to mitigate that conflict should be in place. The complementarity 

between a new task and existing central bank tasks should not be interpreted broadly, so as 

to lead to the creation of an indefinite chain of ancillary tasks. Such complementarity should 

be examined in relation to the financing of those tasks; 

(b)  whether without new financial resources the performance of the new task is disproportionate 

to  the  NCB’s  financial  or  organisational  capacity,  and  may  have  a  negative  impact  on  the 

capacity to properly perform the existing central bank tasks; 

(c)  whether the  performance  of the  new  task fits into the institutional set-up  of the  NCB in  the 

light of central bank independence and accountability considerations; 

(d)  whether the performance of the new task harbours substantial financial risks; 

(e)  whether the performance of the new task exposes the members of the NCB decision-making 

bodies  to  political  risks  that  are  disproportionate  and  may  also  have  an  impact  on  their 

personal  independence  and,  in  particular,  on  the  guarantee  of  term  of  office  set  out  in 

Article 14.2 of the Statute. 

2.1.5  Based on the criteria set out above, the following paragraphs assess whether the CBI’s new task is 

in line with the prohibition of monetary financing. 

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2.2  Tasks  related  to  the  tasks  conferred  upon  the  European  Central  Bank  and  the  National  Central 

Banks by the Treaty and the Statute of  the European System of Central Banks 

The task of operating the Registers for the purposes of the prevention, detection or investigation of 

possible money laundering or terrorist financing is not in any respect related to the tasks conferred 

upon the ECB and the NCBs by the Treaty and the Statute of the ESCB. 

2.3  Tasks which are atypical of central bank tasks  

The task of operating the Registers is an atypical task for a NCB. The ECB understands that this 

task has not been allocated to any NCB in the ESCB. However, NCBs have been given – in certain 

Member  States  –  the  task  of  operating  registers  of  bank  accounts  for  criminal  law  enforcement 
purposes,  including  the  investigation  of  money  laundering  and  terrorist  financing7.  It  should  be 

recalled in this respect that the ECB has previously opined that tasks entrusted to an NCB relating 

to the establishment of a central register of bank accounts are not central bank tasks nor do they 
facilitate the enforcement of such tasks8. 

2.4  Tasks clearly discharged on behalf of and in the exclusive interest of the government 

This task is not part of the CBI’s AML/CFT supervisory role. The new task conferred on the CBI is 

essentially  a  government  task  as  its  purpose  is  to  further  the  State’s  interest  in  being  able  to 

efficiently access information for the prevention, detection or investigation of money laundering or 

terrorist financing by specified State authorities, such as the Garda Síochána, the Criminal Assets 

Bureau and the Revenue Commissioners, and thereby protect the financial interests and security of 

the State and to require obliged entities to meet their AML obligations. This new task is therefore 

discharged primarily in the interest of the government, and cannot be regarded in any respect as a 
central  bank  task9.  The  Registers  could  be  operated  by  any  competent  State  authority.  In  this 

regard,  it  is  noted  that  corporate  and  other  legal  entities  incorporated  in  Ireland,  other  than  the 

financial vehicles subject to the draft laws, are required to register beneficial ownership information 

with a register operated by the Companies Registration Office, which is a central government body. 

2.5  Extent to which performance of the new task creates conflicts of interest with existing central bank 

tasks 

It is difficult to perceive any conflicts of interest arising with other aspects of the CBI’s mandate.   

2.6  Extent to which performance of the  new task is disproportionate to the  financial  or  organisational 

capacity of the Central Bank of Ireland 

2.6.1  As  previously  noted  by  the  ECB10,  the  principle  of  financial  independence  requires  that  Member 

States not put their NCBs in a position where they have insufficient resources to carry out both their 

ESCB-related  tasks  and  their  national  tasks,  from  an  operational  and  financial  perspective. 

Furthermore,  when  allocating  specific  new  tasks  to  NCBs,  each  NCB  concerned  should  have 

7  

8  

9  

10  

See, for example, Opinions CON/2011/30, CON/2011/98, CON/2016/35 and CON/2018/4 (Belgium), CON/2015/36 
(Czech  Republic)  and  CON/2015/46  (Bulgaria).  All  ECB  opinions  are  available  on  the  ECB’s  website  at 
www.ecb.europa.eu.  
See paragraph 2.1 of Opinion CON/2011/30, paragraph 3.1.3 of Opinion CON/2015/36, paragraph 3.1.3 of Opinion 
CON/2015/46 and para. 2.2.5.1 of Convergence Report, May 2018. 

See  paragraph  2.1  of  Opinion  CON/2011/30,  paragraph  3.1.3  of  Opinion  CON/2015/36,  and  paragraph  3.1.3  of 
Opinion CON/2015/46. 

See, for example, paragraph 4.6.1 of Opinion CON/2018/21. 

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sufficient financial and human resources at its disposal to ensure that the tasks can be carried out 

without impacting on the NCB’s financial or operational capacity to perform its ESCB-related tasks. 

In order to ensure that the CBI’s capacity to perform its ESCB-related tasks is not impaired, the CBI 

must, therefore, be able to avail itself of the necessary resources to carry out its duties under the 

draft laws. At this stage it is not possible for the ECB to comment on what additional resources the 

CBI will require in order to perform its new task.  

2.6.2  It seems  clear  that  the  CBI’s  performance  of  the  new  task  is  not  disproportionate  to  the  financial 

capacity of the CBI, since the draft laws expressly provide that the CBI may not use funds from its 
own resources to defray expenses incurred by discharging its functions11. Rather, these expenses 

are to be met by the industry levies to be paid by those entities required to register information on 
the registers12. In addition, if the CBI reasonably anticipates that the industry levies will not suffice 

to defray all of its expenses, or if there is an insufficiency in any given year, the CBI may request 
the shortfall from the Irish Minister for Finance13. Insofar as the Minister in turn may advance such 

sums as he or she thinks proper to enable the CBI to defray all of its expenses, the draft laws retain 

an element  of  discretion  for the Minister  in regard to the  advancement  of  sums requested  by  the 

CBI to defray its costs. In addition, the draft laws provide that sums advanced by the Minister can 
be subject to repayment, interest and other terms set by the Minister after consulting with the CBI14. 

These  repayments,  interest  and  other  terms  are,  however,  not  specified  further  or  limited  in  the 

draft  laws.  It  would  not  seem  appropriate  to  charge  interest  on  any  moneys  advanced  by  the 

Minister to the CBI insofar as the task performed by the CBI is a government task discharged in the 

interest of the government. Finally, it is noted that the current wording of the draft law in relation to 

the defrayal of the CBI’s expenses incurred in discharging its functions with respect to the Central 

Register of Beneficial Ownership of Common Contractual Funds does not cover all of the specified 
functions allocated to the CBI in respect of this particular register15. 

2.7  Extent to which performance of the new task fits into the institutional set-up of the Central Bank of 

Ireland, in the light of central bank independence and accountability considerations 

2.8  The performance of the new task does not fit smoothly into the institutional set-up of the CBI. The 

new  task  does  not  complement  the  CBI’s  other  tasks.  The  operation  of  the  Registers  will  be 

functionally separated from the AML/CFT and prudential supervisory roles of the CBI. 

11  

12  

13  

14  

15  

See Regulation 31A(2) of the draft regulations, Section 36 of the draft law (adding Section 45(2) of the Investment 
Limited Partnerships Act 1994 (hereinafter, the ‘1994 Act’) and Section 61 of the draft law (adding Section 5(2) of the 
Investment Funds, Companies and Miscellaneous Provisions Act 2005 (hereinafter, the ‘2005 Act’)). 
See Regulation 31A(3) of the draft regulations, Section 36 of the draft law (adding Section 45(3) of the 1994 Act), 
Section 61 of the draft law (adding Section 5(3) of the 2005 Act) and Section 32D of the Central Bank Act, 1942, as 
amended. 
See Regulation 31A(4) of the draft regulations, Section 36 of the draft law (adding Section 45(4) of the 1994 Act) and 
Section 61 of the draft law (adding Section 5(4) of the 2005 Act).  
See Regulation 31A(5) of the draft regulations, Section 36 of the draft law (adding Section 45(5) of the 1994 Act) and 
Section 61 of the draft law (adding Section 5(5) of the 2005 Act).  
See Section 61 of the draft law (adding Section 5(2)-(4) of the 2005 Act), which only makes reference to the defrayal 
of  the  CBI’s  expenses  associated  with  its  functions  under  Sections  18O  to  18T  of  the  2005  Act.  No  reference  is 
made to the defrayal of the CBI’s expenses associated with its functions under Sections 18L to 18N of the 2005 Act. 

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2.9  Extent to which the performance of tasks harbours substantial financial risks 

The performance of the new task does not harbour substantial financial risks for the CBI. As noted 

above, the draft laws expressly provide that the CBI may not use funds from its own resources to 
defray expenses it incurs in discharging its functions. In addition, if the CBI reasonably anticipates 

that the industry levies will not suffice to defray all of its expenses, or if there is an insufficiency in 

any given year, the CBI may request the shortfall from the Irish Minister for Finance. Moreover, the 

CBI  is  not  liable  for  damages  for  anything  done  or  omitted  in  the  performance  or  purported 

performance  or  exercise  of  any  of  its  functions  or  powers,  unless  it  is  proved  that  the  act  or 
omission was in bad faith16. 

2.10  Extent to which the performance of the new task exposes members of the decision-making bodies 

of  the  Central  Bank  of  Ireland  to  disproportionate  political  risks  and  impacts  on  their  personal 

independence 

The performance of the new functions conferred under the draft laws do not appear to expose the 

CBI’s  decision-making  bodies  to  any  disproportionate  political  risk  or  have  an  impact  on  their 

personal independence. However, the possibility cannot be entirely excluded that the CBI would be 

exposed  to  reputational  risks  should  the  information  in  the  Registers  be  accessed  by  non-

authorised persons.  

2.11  Conclusions 

2.11.1  The new task conferred on the CBI is essentially a government task as its purpose is to further 

the State’s interest in being able to efficiently access information for the prevention, detection or 

investigation of money laundering or terrorist financing by specified State authorities, such as the 

Garda  Síochána,  the  Criminal  Assets  Bureau  and  the  Revenue  Commissioners,  and  thereby 

protect  the  financial  interests  and  security  of  the  State.  This  new  task  is  therefore  discharged 

primarily  in  the  interest  of  the  government,  and  cannot  be  regarded  in  any  respect  as  a  central 

bank  task.  Consequently,  as  a  safeguard  against  the  circumvention  of  the  monetary  financing 

prohibition, the CBI needs to be fully and adequately remunerated when carrying out its tasks in 
relation to the registers17.  

2.11.2  In this respect, the ECB strongly welcomes the provisions of the draft laws providing that the CBI 

may  not  use  funds  from  its  own  resources  to  defray  expenses  it  incurs  in  discharging  its 

functions, and that if the CBI reasonably anticipates that industry levies will not suffice to defray 

all  of  its  expenses,  or  if  there  is  an  insufficiency  in  any  given  year,  the  CBI  may  request  the 

shortfall  from  the  Irish  Minister  for  Finance.  These  provisions  should  greatly  help  to  ensure 

compliance by the CBI with the prohibition of monetary financing.  

2.11.3  For the avoidance of doubt, and for the sake of legal certainty, the consulting authority is invited 

to clarify through appropriate amendments to the draft laws that any anticipated or actual shortfall 

of funds to defray the CBI’s expenses will be granted by the Irish Minister for Finance on a regular 

16  
17  

See Section 33AJ(2) of the Central Bank Act 1942.  

See  paragraph  2  of  Opinion  CON/2011/30,  paragraph  2  of  Opinion  CON/2011/98,  paragraph  3.2  of  Opinion 
CON/2015/36,  paragraphs  2.2,  3.2  and  3.8  of  Opinion  CON/2016/35,  paragraph  4.4  of  Opinion  CON/2017/20, 
paragraph 2.3 of Opinion CON/2018/4, paragraph 2.1 of Opinion CON/2018/57, and the ECB’s Convergence Report, 
May 2018, p, 30. 

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and prompt basis as the costs arise in order to ensure that the CBI does not have to fund the cost 

of its task under the draft laws from its own funds under any circumstances. In addition, it would 

be helpful to clarify that repayment terms for amounts advanced by the Minister are, in all cases, 

subject  to  the  overarching  principle  that  the  CBI  may  not  use  funds  from  its  own  resources  to 

defray  its  expenses  arising  under  the  draft  laws.  Finally,  it  should  be  clarified  that  the  CBI’s 

expenses  incurred  in  discharging  all  of  its  functions  with  respect  to  the  Central  Register  of 

Beneficial Ownership of Common Contractual Funds will be defrayed. 

This opinion will be published on the ECB’s website.  

Done at Frankfurt am Main, 18 June 2020. 

[signed] 

The President of the ECB 

Christine LAGARDE 

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