Ms Derville Rowland:

I agree with that point. The essence of the provision the Deputy cited is a civil law protection. It is not a financial services regulatory law protection. It is something that attaches and is afforded to everybody who has commercial dealings in this State as a consumer, and he or she can go to the court and vindicate that right separately.

We cannot chase down an enforcement case based on that provision but it makes perfect sense in Ireland, if consumer protection is at the heart of what we do, that we interpret our regulatory requirements in line with the law of the land and in line with consumer protection provisions in the wider corpus of law that protects consumers. It is our clear expectation that all lenders behave in a way that puts consumers' best interests at the heart of their behaviour and interpretation of such requirements. That attaches to the interpretation of contracts, the transparency provisions in our codes and what we expect as users and enforcers of financial services.