Ms Derville Rowland:

I will give some context. This issue arose in the aftermath of the Central Bank becoming responsible in 1989 for supervising building societies. It might be recalled that if a person had a mortgage with a building society, then he or she got rights to vote. That could be relevant. There was much talk in subsequent years of conversion rights which might lead to windfall profits. It did not transpire that way. That was, however, before the securitisation of mortgages took off in the market. There was a concern at that time, because we were in an immature state of evolution, that voting rights would be lost if a mortgage was securitised. Those voting rights were seen as being valuable in respect of a decision to convert from a building society to a public limited company and any profits that might ensue to the holder of the voting rights.

It was entirely in that context that the voluntary code of practice was put in place. It was with an eye to that. Since then, things have changed dramatically and we would never now issue anything on a voluntary basis. That is not that way the regulatory approach works. We do things on a very solid footing, as can be seen in respect of the code of conduct on mortgage arrears. This proposal confers no actual benefit on consumers. All the rights and protections they have now apply equally whether a loan is owned by a bank or a non-bank.