Mr. Cormac Ryan:

There is the vehicle and there are the bondholders. The vehicle will continue to hold the loans even if the bondholders change in the background, as we have established already. There is probably a double or triple lock to protect the consumers behind this. In simple terms, the assets that underpin Glenbeigh are the 6,000 borrower relationships, equating to approximately 4,000 split loans and 2,000 part-capital and part-interest loans. Those are the assets underpinning Glenbeigh . Looking at this from a consumer perspective, which is important to do, regardless of who owns the loans, who the bondholders are and what vehicle owns them, the contract, original facility agreements and any future alternative repayment arrangement carrying the full weight of law, are protected. Those contracts cannot be unwound. They persist. There are, as the Senator stated, some carve-outs if there are material changes, but the actual contractual rights can be enforced in law. That is one protection that, regardless of ownership, sits with and protects the underlying customer.

All of these mortgages, whether split mortgages or part capital part interest mortgages, have been restructured. They are alternative repayment arrangements, ARAs, so while they are performing against their new terms, strictly speaking, under the regulatory code, they still fall under the protections of code of conduct on mortgage arrears, CCMA. Ultimately, everything around CCMA, including how we conduct reviews, contact customers, run reviews, come to alternative arrangements and how we conclude that nothing has changed and that they should stay the same, is strictly governed by consumer protection code, CPC, and CCMA and will be regulated by the Central Bank of Ireland on those. There is very little wriggle room in terms of what can happen. The only thing that can really change things is a change in the circumstances of the individual customer.

The third protection to bear in mind is that if the mortgage moves to another loan owner, by law in Ireland, the loan owner or unregulated owner must have a regulated entity in Ireland to service their loans. It is not legal for a loan owner not to have a regulated entity, be it Pepper or another company, servicing those loans. The regulated entity must follow all the rules of the CCMA, CPC, SME and all the other codes as applicable.

I hope I have answered the questions regarding ownership. In the context of the vehicle, the question is what is in place to protect the consumers. The contracts will persist, the ARAs and other protections of the CCMA will persist, and ultimately, if the loan moves around, a loan owner has to appoint a company such as Pepper or another regulated loan owner which is overseen by the Central Bank.