Mr. Tom Kinsella:

We have established over 40 different groups of customers that were impacted and each and every one of those has led to a root-cause analysis of why it happened. There were control failures, miscommunications, failures to meet our terms and conditions and cases in which the wrong terms and conditions were sent out. There was a range of reasons and we have corrected the causes as we have gone along to ensure it will not happen again. We have not found one case in which a deliberate action was taken by anybody to remove trackers from customers in any of those investigations. Trackers were removed for new businesses in October 2008 and 104,000 customers who had trackers before that date kept them. There were unintended consequences of that decision whereby some customers who had a right to a tracker no longer had one and that is the issue we are dealing with today.

The Central Bank enforcement issue is going through the organisation, root and branch, and will leave no stone unturned in looking for deliberate attempts to remove trackers from customers.