Ms Derville Rowland:

I recall having this discussion here before. An observation was made, which stands true, that a common set of incentives operated in the external environment which had clear pathways if anyone thought about it for half a second. It was a time of significant financial crisis. The tracker mortgage product was expensive for lenders. It also turned out to be a very good product for customers. That was not always the case, as the Senator knows, because we saw the complicated switching journeys of Irish customers as a feature of what happened. My message to all customers today would be to switch and shop around for themselves to get the best products. It was present in the market at that time. The tracker was sometimes expensive compared with other options. Later, as the products began to be withdrawn, it seems that it began to be expensive for lenders. There was a common set of external circumstances which, if one took a tiny amount of time to think about them, had an obvious answer.

Ms McEvoy might comment on a feature of what happened then that I never expect to see again. That was that these products were taken off the market and no real consideration was given to existing customers who might have choicer options that were good for them and that it was all one-way thinking, which might be about the financial situation of the lender and not about the duty owed to the customers. That is precisely the kind of thing that we have said is different now. We have a requirement, known as product oversight and governance, POG, which means that before a product is designed, approved, launched and sold, it must be clear whether it is appropriate and suitable for customers and what benefit it will give them. Proper consumer thinking has to be at the heart of the design and there has to be an approval system in the organisation. One has to think, when withdrawing a product from the market, about what existing customers are entitled to. One cannot just take it away and forget about the obligation to existing customers. The Senator made a wise observation about the system. The improvement in the procedural framework that is required should deal with the idea of taking away a product without thinking about obligations to customers.