Oireachtas Joint and Select Committees

Thursday, 6 December 2018

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach

Sale of Permanent TSB Mortgage Loans: Discussion

2:00 pm

Mr. Cormac Ryan:

I thank the Deputy for his questions. The review period is talking about the restructuring arrangements. As I stated at the outset, the majority of the mortgages - approximately 4,000 - are split. Approximately 2,000 are in part-capital and part-interest arrangements. The review arrangements are a standard part of the terms and conditions. Reviews were going on with Permanent TSB. They are a standard part of any restructuring arrangement. I have already addressed the point that was made in respect of frequency. We will look at a range of factors, like we do in any alternative restructuring arrangement. The first thing I will say is that every single case, in reality with our consumers and under the CCMA, is unique. No two cases are the same. The first factor we take into account under the CCMA is the overall indebtedness of the customer, which may have changed in the case of somebody who has not been reviewed for a number of years. The second factor we take into account is the person's financial situation - whether there are two people working in the family, whether there is an additional person working in the family or whether somebody might have got a new job. The third factor we take into account is the person's personal circumstances - whether he or she has dependants or whether there are other things that are straining on their income.

When we have formed the overall picture, we take a view. Basically, there are three outcomes that can happen. We run it through our affordability assessment, which basically says what a customer can or cannot afford. The first of the three outcomes is when it is found, after everything has been considered together, that nothing has really changed. It has been mentioned that we are in a much better economy now than we were in five or ten years ago, thankfully. The customer may be in the exact same circumstance. If he is in the exact same circumstance, it is a fairly short conversation. We will say to the customer that he should stay in this arrangement and nothing should change. I want to talk about this in real terms rather than in the abstract. If the customer has received a promotion and is earning more money, or if additional money which is attributable to the property is coming into the family because the customer's partner is starting to work, we work with the customer to say that there is some additional affordability. We look at the customer's level of affordability under the previous circumstance and point out that there is now increased affordability.

This links into our obligation to be open, fair and transparent and to have the customer's best interests at heart. For example, we might remind the customer that a big bullet payment is due at the end because of the way these mortgages are structured. I did not structure them that way; it is how they are structured. We might suggest to the customer that because he is due to pay a certain amount in ten, 15 or 20 years, the right thing to do in his best interests is to increase his monthly repayment slightly. Over 20 years, that could make a difference between the customer having €50,000 due at the end of his mortgage and having €10,000 due at the end of his mortgage. Those are rough numbers, but the difference could be something like that. We might say to the customer that we think his arrangement should stay in place, with a slight tweak being made to it because that is in his best interests. This is one example of how things might change.

I would like to speak about our obligations. Most of my team of specialists have been doing this work for seven or ten years. We have to be able to stand over these arrangements. Quality assurance is done by internal teams that look at all the documentation to ascertain whether we documented the numbers correctly and explained these matters to the customer correctly and whether the customer understood what was happening. Any change in every single one of these arrangements is absolutely subject to review by the Central Bank of Ireland.

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