Mr. Paul Joyce:

We will not waste much time on this but we were not satisfied with the nature of the consultation with us. Formal written submissions were not sought and meetings were held at which opinions were presumably recorded in some form and subsequently appeared in the report to the Minister. As I understand, that work was carried out by the Central Bank in the latter half of 2018, furnished to the Minister in October 2018 and published in November 2018. Our simple point, which the Deputy and Mr. Hall have also made, is that there was not enough evidence for the Department's conclusion. In our original submission to the committee, we pointed out that in the course of quarter 4 2018, almost 14,000 loans navigated from regulated lenders to unregulated loan owners. As was outlined in the submission to the committee, however, it seems the significant majority of those loans are performing restructures. We find it surprising they were sold in the first place.

Deputy Burton asked a salient question on 2 April, which was what work the Department carried out to examine the profile of mortgage holders who are adjudged to be non-performing, even though their loans have been restructured and are being paid down. I do not think she received an answer to that question. The IMHO has quite a lot of clients while FLAC does not, but we do much work with the Money Advice and Budgeting Service and consider files in that regard. Many of the loans now in difficulty are ones where the household's problem is financial incapacity. While repayment arrangements have been in place, many of those arrears have been in place for five years or even up to ten years, which is the difficulty. The households do not have the financial capacity to make the kinds of payments we feel vulture funds, sooner or later, will demand.