Mr. Paul Joyce:

The code of conduct on mortgage arrears states that when an alternative repayment arrangement is being offered to the borrower, the lender must show how it is appropriate and sustainable for the borrower's needs. For example, Bank of Ireland split mortgages carry interest on the warehouse part. I simply do not know how that can be appropriate and sustainable. The mortgage arrears resolution targets only apply to the six main lenders. There are 17,000 accounts in arrears over 90 days that are not with the six main lenders. They include sub-prime lenders and the books that have been sold by lenders to unregulated third parties.

It goes back to the point Ms Blackwell made earlier that we need an integrated service to assist people from the time they get into debt difficulty to the time the problem is resolved. Again, this is supposed to be the mortgage arrears resolution process, but where is the resolution? MABS is the basis of State-funded money advice in this country and it needs other services to assist it in terms of financial expertise, legal expertise and so on. Currently, we have a range of agencies, NGOs and State-funded services but we do not have an integrated service with all the tools in the toolbox to assist people in finding a solution.

We have written to the Central Bank a number of times. The Central Bank confirmed to us in July that it does not have the power to compel lenders to offer specific products. It remains the case that it is at the discretion of each lender which alternative repayment arrangement it offers to borrowers in arrears.