Ms MaryRose McGovern:

If I may follow up on that, the Central Bank of Ireland has an expectation that where a direction is made by the FSPO in any decision, that the financial services provider will apply that direction to consumers who are equivalently impacted by the issue. We do not always see the overall impact. The Senator asked a question earlier as to whether we sit down and analyse what the impact is. We do not always see what the wider impact is because we will not know in any given instance how many accounts or policies of that nature exist. We are aware of that expectation, however.

In addition to that, and touching back on what the ombudsman said in his opening statement, in 2023 there were nine decisions which were referred to the Central Bank. Those are nine decisions which were very specifically referred in order to highlight something we had a concern about. As it happened, in 2023 there were some themes to those nine formal referrals. Three of them, which is quite significant in number, concerned the manner in which financial service providers were notifying information to the central credit register, CCR, potentially having a negative impact on somebody who had found themselves in difficult circumstance, not so much because of wrongdoing by the financial services provider but more about the nature of the information that the CCR made available to the financial services provider. For example, in very complicated bankruptcy or post-bankruptcy situations, the indicators were not there to accurately describe that. A number of those referrals concerned the CCR and, as I understand it from ongoing engagement with the Central Bank, the central credit register has been looking at that with a view to making it perhaps more workable with regard to those difficult circumstances.

Another two of those referrals concerned insurance decisions where we certainly took the view that there was a potentially systemic impact arising out of the manner in which the cover interplayed with the exclusions given on one hand, perhaps taking away in how that worked, with potential confusion arising out of that. It is not just the decisions, therefore, because it is sometimes the far wider stakeholder engagement and that plays a very important part in how we contribute to the overall consumer protection framework.