Mr. Colm Kincaid:

I will complement that. To return to my earlier remarks, another area is where we are coming into an economic scenario whereby the system, resources, and knowledge in the system on dealing with mortgage arrears, in particular, are significantly advanced, which is unfortunately due to the problem we have to deal with. That is one of the reasons we put so much effort into that in 2020, 2021 and leading into 2022. One of the key lessons from that, and one of the reasons we are so proactively engaged with lenders now, especially non-bank lenders, to refer to Deputy Durkan's comments and to be very clear, is that our demeanour is the institutions we regulate have a duty to support their customers and behave sympathetically towards them. We see a mixed bag in respect of performance under that. It is one of the reasons we are so proactively engaged with firms on an ongoing basis, as well as getting information that we review, as I mentioned in response to Deputy Tóibín.

One of the lessons we learned was the importance of early engagement and trying to quickly get to solutions with people and not allow a situation to drag on for too long regarding what options are available to them. To link that to the point Deputy Durkan made, and to be very clear, under the code of conduct on mortgage arrears, lenders have a duty to have a suite of options to assess the financial position of customers and to make offers to them, or to identify with customers that they cannot, and why they cannot, avail of a certain option. Any of these scenarios where consumers feel it is on them to find the solution is certainly not consistent with what we expect of firms.