Mr. Paul Joyce:

FLAC used the term "reckless lending" long before it was either profitable or popular. It is extraordinary to us that after an era with no controls on lending, despite calls for prudence, we now have a paper proposing to introduce limits on 1 January that suddenly must be implemented very quickly. There are still serious and detailed questions to be considered. The questions asked from the Chair are excellent and very important for a debate like this. Regarding affordability, the consultation paper suggests a three and a half times loan to income ratio should be the limit but this does not take into account other debts that must be serviced. The paper simultaneously uses the term "debt servicing to income ratio". There is a huge difference between a person who comes into a mortgage carrying unsecured debt, for example, relating to credit cards, personal loans, various types of insurance and so on, and a debt-free person who borrows using a three and a half times loan to income ratio. In trying to define "affordability" in any application, surely a person's entire financial circumstances must be taken into account. Without a fully-functioning full disclosure and central credit register, how can this be done? It may seem surprising for FLAC to take this view but we should proceed slowly. There is some truth in the assertion that, at the moment, creditors are mostly self-policing, for understandable reasons. Perhaps there is an opportunity to have a wide-ranging and lengthy debate on hugely important issues for the future of credit and housing in Ireland. There is a tension in the paper between access and potential difficulties, particularly repeated consumer over-indebtedness. This is a difficult area to address quickly.