Professor Philip Lane:

Everything that consumer protection delivers can also be delivered by regulated credit servicing firms. Nothing extra would be delivered by regulating the owners themselves. We went back and looked at that, because it was our view. It remains our view. We have examined the issue up and down. We are talking about reviewing how credit servicing firms are regulated, and the answer remains that for consumer protection purposes, regulating the credit servicing firms can be effective. Nothing extra will be added by regulating the owners.

I am aware that this is a long-standing issue. We have looked at this from the consumer protection point of view, and nothing extra will be added by regulating the owners. The issue concerns how these firms interact with those who are in distress. Anything that consumer protection can deliver on that question can also be delivered through the regulation of credit servicing firms. We have been carrying out inspections and we have not seen these problems in terms of consumer issues. Investors were mentioned earlier, for example, someone who might have an investment portfolio who may not fall under the consumer code. It is still relevant in terms of correct conduct, but we believe that this distinction is important, and that, for consumer protection purposes, the credit servicing firms are the appropriate venue.