Mr. Larry Broderick:

It does not become very obvious until a communication like a letter needs to be sent to the customer about what happens at the end of a particular lending product like a tracker mortgage. What tends to happen is that this is centrally referred to the legal department and then a letter is pre-printed or pre-sent out to the customer to address that. It is likely that a bank official would not be aware of something like this until a customer expresses dissatisfaction or raises an interest, or until it has an impact on the official himself or herself. That is how these things tend to operate. That brings me back to the question of whether the 2008 regulation described how a tracker or fixed-rate product should be phased out and the circumstances in which this should be done. We would have thought the Central Bank would have had rules in this regard, for example setting out whether a similar product should be made available if a certain product was not on offer. I do not think such a regime was in place at the time. This problem was compounded when everybody looked at their legal contracts. Some contracts gave banks the right to do what they wanted and other contracts were very much in favour of customers. We are still in the debate about what the prevailing rate actually was and what that meant. There is a misconception that every customer has gone back to the tracker he or she was on many years ago. As we know, that is not what is happening. As the terms of most of these products are pre-structured and based on legal contracts, and therefore dealt with in that way, officials are often unaware of them until complaints arise and have to be dealt with. Indeed, that was done. Members may recall what happened in one bank where there was a lot of noise in this regard. It travelled into other institutions as it emerged over time. Many of our members are customers of a certain bank and are therefore facing this exact issue.