Professor Philip Lane:

I emphasise that I do not see what extra layer of consumer protection would be added. If we can do this to the credit servicing firms that are engaging directly with the debtors for consumer protection, what would be added by interacting in the way the Deputy is advocating? If the loan owners were regulated, we would be able to inspect a legal entity established by the funds, but we would be doing so within the same framework. We would be assessing whether the codes were being respected. I remind the committee that we regulate non-banks for conduct, not for prudential reasons. That is the fundamental issue. It is not the case that if we regulated for consumer protection purposes any entity that they would be compelled to set up, the outcome would be different. The Deputy played a lead role in passing the credit servicing Act. It was hoped beforehand that there would be voluntary compliance. The passing of the legislation was an act of leadership by the Oireachtas.