Mr. Brendan Whelan:

In our opening statement, we said that we felt that the multiple of a reference market rate should be no greater than three. The question then is what the reference market rate is. If the average market rate is about 8%, then one is talking about a rate of no more than 24%. If it is 10%, then it would be no more than 30%. The 36% APR in the proposed Bill should, in our view, be the upper limit, and it may well need to be lower. It needs to be a multiple of the market rate to cater for the higher credit risk that exists with those customers, but we would have thought that a multiple of three would be the maximum ultimate rate.