Ms Gráinne McEvoy:

I thank the Deputy. To reiterate the point, we would support any legislative regime that strengthens and enhances protections for consumers. As I mentioned earlier, we do not have the legislative power to impose a cap. Any imposition of a cap would be a matter for lawmakers and politicians in that context.

I understand from the discussion earlier with Deputy Doherty that the proposals set out in the original Bill are being revised. To look at APR in isolation could be ineffective and counter-productive, as Deputy O'Callaghan said. A cap might, in one sense, provide one degree of stability but that can easily be circumvented by extending the duration of the loan. In the long term a customer may pay back a loan over a longer term than he or she would in other circumstances. That can often be the byproduct of the imposition of a cap.

Any proposals around this should be considered at a holistic level by all relevant stakeholders across Ireland. We have undertaken quite a bit of research in terms of workshops with industry in 2018 and with Amárach Research in 2013. T he UK has done quite a bit of work on the whole area of APR and their understanding and meaning, in particular in the context of high cost credit loans.

I do not have an alternative proposal, but I would caution that a proportionate and measured approach be taken. The certainty afforded to the total cost of credit regime supports a borrower because he or she knows at the outset what he or she is borrowing and what it is going to cost.

As I mentioned earlier, the existing framework does not allow for the charging of late or default charges, which is an important protection for consumers.