Mr. Maurice Crowley:

While it begins with the servicer, I accept the point that at some stage, where borrowers are unhappy with what is emerging from the servicing process, based on today's hearings, the Department plans to draw the owners into the Financial Service Ombudsman's process with a view to making them responsible in those circumstances. This is what makes the most sense to me. While I am not sure how it would work legally, it would have a lot of merit. We have tended to shift the focus of servicing regulations around substance on the ground. Because the special purpose vehicle, SPV, which is what most of the companies use, has a legal substance but no physical or personal substance on the ground, it always seemed to make more sense to start with the servicer. However, we would have no difficulty with the owner being brought to account through the ombudsman's process. Some of it already happens for banks in this country in that if customers or borrowers are unhappy with a bank or appeals process, they always have the option of the Financial Services Ombudsman. If the Department is planning to mirror the process with the unregulated owners of the books, it would have a lot of merit.