Ms Gráinne McEvoy:

We wrote to all the banks and non-banks clearly setting out our expectation that if one is in a situation where one is meeting the terms of one's arrangement, that arrangement should carry on. Equally, it is important for the customer that a review period be built in because there could be factors that need to be taken into account. Most arrangements exist for three to four years. The borrower's circumstances may have changed in that period and it is important that it is built into the contract that the customer engage with the lender again at that point in time if their circumstances have improved or disimproved. That is factored into the mortgage amount the person will continue to pay back on the mortgage, which is important.

When the regime was introduced in 2015 to require the regulation of Pepper and other credit servicing firms, the Central Bank was strong in advocating that its consumer protection code dealing with customers in mortgage arrears would apply equally to the non-banks as it would to the banks. That is to ensure the protections exist for all borrowers regardless of whether one is a borrower with a lender that is a bank or a non-bank. The protection framework that exists, the transparency obligations and the manner in which we expect the firm to deal with its customers are clearly articulated in the code. It is something on which we supervise the banks and the non-banks. I hope that addresses the question.