Mr. Noel Brett:

We welcomed as an industry the regulation of loan servicers, which was a big step, because until recently, the lender was regulated but the loan servicer was not. Thankfully, servicers are now regulated and we have taken some of them into our membership on the basis that they are regulated entities. Clearly, it is very much within the gift of the Central Bank, as the regulator, to determine how best it wants to deal with the next step in terms of investors. We do not represent investors or speculators or others who buy in that context and, therefore, I do not have a view on what their view might be. It is very much within the gift of the regulator to determine the most appropriate policy intervention but our submission welcomes and supports the regulation of loan servicers. Clearly, that is an important part of the equation and I agree with the Deputy that there is an unregulated third element. That is perhaps something for further discussion with the Central Bank.

With regard to a credit bubble, I agree there is no point driving up house prices, thereby causing further indebtedness of individuals and families. That will not address the core issue we are discussing, which is housing and homelessness. An increase in supply is needed rather than pushing up prices and increasing indebtedness without solving the problem. A co-ordinated intervention is needed on four levels. We need a proper approach to social housing, an integrated approach to affordable housing and interventions in the private rented sector.

Finally, the element my members are predominantly involved in is the mortgage sector. I have set out mortgage levels. We are supportive of the Central Bank's intention of trying to prevent a credit driven bubble. It is important that the Governor is seeking written submissions from all stakeholders. We will submit on that basis but we are supportive of the principle of trying to avoid another credit driven bubble. We have to understand what happened last time out, not just in our sector, and we cannot repeat it. I am of the same mind as the Deputy in terms of not driving up house prices through intervention and making sure we do not force families into further indebtedness. Supply is the key issue in each of the four areas to which I referred and it will differ in various locations around the country.

Deputy Ó Broin asked about relationship breakdown. It is not an issue I have encountered. As a federation, we do not get involved between customers and their banks but it is an issue I will discuss with lenders. I might talk to the Deputy separately to try to understand the issues. I can imagine from the lenders' point of view that they have two parties to a mortgage, which has been granted on the ability to repay. If one of the people exits, that potentially is an issue.

I might talk to the committee separately about that matter, but I am willing and very keen to go back and talk to lenders about it.

In terms of vacant possession being sought, I am surprised to hear any lender would be sitting on vacant properties. Banks and lenders are not good operators of property or good at managing property as it is not their core business and all they would be doing is depreciating the value of their asset and adding cost for themselves. If it is just a localised problem, it would be useful for me to get the information and I will take up the matter with individual banks. It is not one of which I am aware across the industry and it seems to be an unusual practice. I am not saying I disagree and, if it is an issue, I will accept that it is, but I would like to go back and talk to the lenders concerned.

I have touched on the mortgage-to-rent scheme and hope I have answered the question for Deputy Eoin Ó Broin. In terms of supply, the big issue for me is equity in order that people can access appropriate housing. Clearly, we must not have a one-trick solution. The solution is not just providing loads and loads of credit and mortgages. Credit and mortgages are important for people in that sector who have the ability to repay, but that is not going to address the homelessness issue. There is a supply issue. I note with interest the other parties coming to give evidence. It is very important, whatever recommendations are brought forward by any of us coming to the table, that we realise there is no one solution and that every single solution needs to be stress-tested for unintended consequences. We must not go down the route of having just one solution.

With regard to private developers getting credit from my members, the message I have for the committee is that if lenders do not lend prudently and properly, they will not make a profit. However, they need to lend. One of the key challenges is to ensure people with enough equity come to the table to do those deals. It is interesting to talk to the Credit Review Office about those people who have been declined. The office has powers to force banks to look again at their decisions. Equity is the key issue. I believe there is a lot of credit available in the system. It is my understanding that, in many instances in the past, people used the equity from the previous development to leverage the next one. We now understand, as a country and sector, where that leads. Clearly, if people look to fund a development or business, they need to have equity. That is the challenge. The banks cannot provide 100% finance without equity. As a country, we have to find a way to plug the equity gap. There are a number of sources of funding; for example, there is straightforward bank funding, State funding, strategic investment fund money and European Investment Bank funding. The problem is equity and how we bridge the equity gap. Continuing to leverage on past performance is not the way to go. That is an important point. The role of the Credit Review Office, its findings and powers are significant in this regard. It might be interesting for the committee to even receive a written submission from the Credit Review Office on what its findings and views are on the housing sector.

With regard to the Central Bank's rules and Deputy Eoin Ó Broin's point on the rate of refusals above and below the figure of €220,000, I do not have that data available. I suspect the Central Bank would have them, but I do not receive individual data and I am not sure if my colleagues do.