Oireachtas Joint and Select Committees

Thursday, 7 May 2015

Committee of Inquiry into the Banking Crisis

Nexus Phase

Mr. Michael Torpey:

It certainly would, Deputy, and would prompt a very close inspection as to what was driving these matters. The approach to policy in residential mortgages was ... and, as would be good practice today, indeed, that you had policies which then had a tolerance around them because prescriptive policies of their nature lead to a need for a certain level of exception. And, to be entirely frank, Deputy, once you're moving beyond low-teens, mid-teens exceptions, you have to raise a question as to the appropriateness of policy. The exceptions to policy were the subject of challenge by the board of UBIL throughout. And to the specific item of debt service ratio policy exceptions within ... within UBIL ... and you will note on the page to which you've referred me, the difference between the First Active and the UBIL experience; that arose largely because the exceptions were very highly concentrated on people with higher incomes such that the appropriate debt service requirement will not have been captured by policy and, indeed, the revision to policy will have captured that. So if we find that ... and I believe it to be the case when I was there, that the majority of debt service policy breaches were for high income earners, that is a mitigant which is acceptable and would have been reflected in the policy revision subsequently. And I believe also that a very high proportion of those exceptions will have been minor exceptions - as in, very marginally above the policy limits. It doesn't take from the fact - and it's very, very important, Deputy, I would agree - that where you do have exceptions arising, that they are challenged by the board and satisfactory explanations along the lines I've given or such other as they may be are arrived at to ensure that credit risk appetite is being adhered to.

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