Ms Mary O'Dea:

I did buy into the system of principles-based regulation. It was the internationally ... seen as the best model at the time. At the time, when that system was in place, I had the role ... the statutory role of consumer director and actually I think principles-based regulation worked very well in relation to consumer issues because we were in a very new regime. We'd had no best practice to follow in relation to the super ... the supervision of the consumer issues. If you recall, it was issues of consumer failing around National Irish Bank and around DIRT issues that led to the set up of the consumer area. And if I may tell you how I think it worked better on the consumer area, we were able to build into the consumer protection code specific principles, such as you must act in the best interest of your consumer and we were able to codify that. So when we wanted to take an enforcement action in relation to a consumer protection issue, we could look at not just the particular rule that may have been breached but also the principle, for example, acting in the best interest of the consumer - that was also breached. So I think codifying those principles on a principles-based regulation on the consumer side actually worked extremely well. On the prudential side, of course, much more depended on very complex supervisory models and it was a completely different system.