Mr. Ger Mitchell:

The mortgage product review group began in September 2015 which put us three months ahead of the curve. I do not think we have gathered everything as part of the mortgage redress programme because it was a very specific task to identify customers who had broken early from a fixed rate contract and lost their right to a tracker. We were guilty of an information deficit. We did not communicate sufficiently with customers about the potential loss of a right down the line.

The CBI review, however, is very broad. It attempts to check for the contractual entitlement, to view it through a regulatory lens in terms of adherence to regulatory policy. The third element pertains to the reasonableness or conduct of the organisation during that period. We have taken every tracker mortgage customer going back 12 years. This is business live in our systems today - business we have sold, business that has been redeemed - and we have recommissioned legacy systems to make sure we get all the data. We are working hand in glove with the Central Bank to make sure everybody potentially affected is assessed, reviewed, and where we find a failing, that they are remediated properly.

There are six steps in the remediation policy: put the customers on the right rate to stop the harm; refund any overcharge of interest; allow a time value of money; a separate payment of €400 to allow them get independent advice; pay 10% or €1,000 minimum in compensation; and two appeal panels depending on what cohort the customers fall into, those who have not lost their homes and those who have. Beyond that, everything is open to the customer including the Financial Services Ombudsman, FSO, thereafter. There are four stages in the Central Bank review. We have just completed phase two and are moving into the full assessment of our book and expect to go through phases three and four in the first half of next year.