Professor Philip Lane:

The Chairman raises a number of very important points. I assure him that we are very aware of some of the following facts. The nature of what happened here and in other countries post-crisis means that there is a much wider range of firms now involved in dealing with customers. Banks have sold loans on to funds that in turn have these credit servicing funds which try to manage payments and so on. Partly because the Oireachtas passed the Consumer Protection (Regulation of Credit Servicing Firms) Act 2015, we as the regulator have a very broad perspective. The traditional banks are no longer the only game in town. There is a situation where these specialist firms which specialise in debt recovery are in place. The requirements of the code of conduct on mortgage arrears apply to the credit servicing firms. More generally, our conduct requirements are general and they apply. We have the framework and the awareness and we have engagement.

I will come back to a couple of points. As always, if the Chairman, other representatives or other people have individual experiences and information such as that just recounted it should be sent on to us. The more information we receive from every quarter, the more it helps us in holding these firms to account. I am emphatic in saying that, because of the way in which this tracker mortgage examination is set up, no matter who is now the owner of the mortgage, the originator is responsible. My understanding is that is working. No matter who people owe money to now, the redress and compensation is flowing from the originator of that loan. That is working. We have checked it.

To come back to the issue of culture, these culture reports for the banks give a general perspective. No matter who the regulated firms are that are interacting with the customers whom we are dedicated to protecting, our scope is general. Regardless of whether it is banks, insurance companies or these specialist firms, we have a general perspective on the issue and a commitment to deliver.

I will just make two more points. One is about our work and our communication. I fully agree with the Chairman that what matters ultimately is whether we get the job done in terms of protecting consumers. I have said in other ways that it has traditionally been our belief that we should be judged on our actions. Our tradition is to use bureaucratic language. There is a way in which central banks and regulators have communicated. We have always been very precise and careful, but perhaps the core meaning of what we are doing gets lost because people do not understand what we are saying. That may also be reflected in the discussion at our own commission. We have put more effort into this. It is reasonable to expect that we should cut through the bureaucratic language and say what is really going on. The way we have written this report tries to cut through such language. The message is the same. The underlying work is the same. This work has been continuous and has followed the same strategy, but we encountered this problem of our message being lost. We are trying and interaction with the committee is helping to force us to be clearer in how we communicate what we are doing. We are committed to that.