Mr. Edmund Honohan:

Yes. The problem with the credit purchasers the Deputy was talking about is that they were outside the jurisdiction. The Central Bank then said it could not do anything about these credit purchasers if they decided to mess around with the loan book and sell it on because they were outside the jurisdiction. The Minister, Deputy Michael McGrath, then had the bright idea that it was the credit servicers we should be going after and that the local agents here of the credit purchasers in Dublin would be the ones to regulate. This was how the 2015 Act emerged. It was in relation to credit servicers. It still remains the case that it is the credit servicers who are under the cosh, if we wish to put it that.

There is another interesting point I should make about this aspect concerning the notion that soft law and soft regulation could involve the imposition of fines. The imposition of fines on credit services is all right, but I refer to the view that it is not possible to impose fines on the credit purchasers because they have no assets in the country. That is not right because they do have assets in the country. It is just the case that they are not registered as owners of those assets. This is, therefore, another reason why they do not register themselves as owners of the burdens in the Land Registry. It is because they avoid the possibility of having fines imposed on them. This is very technical stuff, but it is the reality.