Writing yesterday in the Law Society Gazette, Aine Flynn (Director of the Decision Support Service) provided some clarification in response to an earlier article (4 January 2024) in the Gazette entitled “New system for EPAs not working“.
The article speaks for itself, and addresses various issues by way of response to what was raised in the January article. Ms. Flynn provides some data in the article which I find interesting:
Registered EPAs since commencement
While the January article suggested that only 27 EPAs had been registered in the first eight months after commencement of the ADMC Act, Aine Flynn says that the correct position is that, as of 8 December 2023, a total of 311 EPAs had been submitted and were pending registration. As of 8 February 2024 this number had risen to 529.
Ms. Flynn does not say how many EPAs had actually been registered – she simply provides information as to how many EPAs had been submitted for registration. She does not deny that only 27 EPAs had been registered in the first eight months after commencement. She does point out that under the 2015 act, a five-week notice period must elapse prior to review and registration of the EPA by the DSS.
‘Active’ EPA Applications
On 8 December 2023, a total of 1,408 applications were ‘active’ on the system, meaning that the donor had completed the substantive EPA instrument and proceeded to take up supporting documentation. On 8 February last, 2,036 applications had reached at least this point on the system.
No information is provided as to how many of these ‘active’ applications have gone stale or been abandoned, nor is any information provided as to the average lapse of time between the donor taking up the supporting documentation and the completed documentation being received by the DSS.
Comparing ‘active’ and ‘submitted’ applications
In the first place, is not clear if the ‘active’ number includes or excludes the ‘submitted’ applications. Are these separate categories or is ‘submitted’ a sub-set of ‘active’?
If the ‘active’ number includes the ‘submitted’ EPAs, than at 8 December 2023 there were 1,408 active applications of which 311 had been submitted. That’s about 22%. As of 8 February 2024 there were 2,036 applications of which 529 had been submitted. That’s about 26%. Between 8 December 2023 and 8 February 2024 the ‘active applications’ number increased by 628, and the ‘submitted’ number increased by 218.
If the ‘active’ number does not include the ‘submitted’ EPAs, than at 8 December 2023 there were 1,719 active applications of which 311 had been submitted. That’s about 18%. As of 8 February 2024 there were 2,565 applications of which 529 had been submitted. That’s about 21%.