Mr. Dermot Sreenan:

At the moment the inflexibility we are experiencing with nonbank entities is, for example, when they pass on the interest rate hikes directly to the consumer. As I said earlier, a nonbank entity is getting the loan book from the bank, writing directly to the MABS client and asking that person to make a serious decision about going to mortgage-to-rent, MTR, and asking the client to respond within 21 days, while knowing that the person is a MABS client, but not involving us and bypassing MABS. It is really good for us to talk about specifics because then we can create the picture of the power imbalance that lies at the heart of it. The client needs MABS to be there. We need MABS to be the advocate in order to get the client to establish what is affordable and what is sustainable. MABS has dealt with thousands of cases where we are now seeing people starting to come into trouble because of these interest-rate hikes. Previously there were affordable and sustainable options we were trying to fix with the nonbank entities, and now we must deal with interest-rate hikes. We are looking to deal with that matter. In the way we operate, we look to deal with that at a local level in the first instance, and then we deal with it at a national level, and then we deal with it under the Banking and Payments Federation Ireland, and go back to the consumer code on mortgage arrears. We also would have regular contact with the Central Bank with regard to the regulation in this area.

What we have brought before the committee today relates to the credit services directive. This is important legislation. My colleague, Mr. Gerard O'Brien, spoke to the importance of ensuring that there are consumer protections within that. We ask that the committee would seriously consider this. As is the case with all submissions from MABS, our submissions are based on and grounded in the client experience and in trying to address this power imbalance, which we do and have been doing for 30 years.