Ms Gráinne McEvoy:

I will take the latter question first. We are aware of that proposal. Ultimately, it is a matter for the credit unions, but we would have no objection to the proposal as set out. It is important that the Deputy would seek the views of the Irish League of Credit Unions and other credit union members as regards the commercial realities and practicalities of that because we would not play a role in that context. However, on the level of principle we have no objection to it.

There is quite a lot in the Deputy's first point. I agree with much of what he said, in the sense that Covid-19 has certainly impacted on the door-to-door model of moneylending. Even more recently, we are seeing trends emerging where consumers are interacting with all financial services firms in a more digital manner. Covid-19 expedited some of that as well. There is an argument to be made that there are many different types of customers of moneylenders, and the Deputy alluded to some based on his knowledge and experience. There are people who have good existing relationships with other forms of lenders, but they use moneylenders as an additional form. There are those who are, perhaps, less fortunate and have been refused credit elsewhere and a moneylender is their only source of access to regulated finance or credit. The Deputy asked if now is a good time. As I said, we would be very supportive of examining any enhancements that strengthen the protections for consumers of moneylenders. Our approach has always been that we will do so. In our view, we have kept our regulatory and legislative regime up to date. We have been clear about expectations. We reacted to some of the examples the Deputy mentioned in terms of repeat lending to customers who are still on loans and so forth. That is prohibited under the regulations we introduced last year. From our perspective, we are very much in favour of a proportionate, but robust, regulatory model.

However, it is important to take into account that there are other key stakeholders in Ireland that should feed into this process. We have been involved with colleagues from the Department of Social Protection, the Money Advice and Budgeting Service, MABS, Abhaile, the Society of St. Vincent de Paul and many others on the high cost of credit working group so we are very happy to participate in any initiative like that. We are supportive of the objective it is trying to achieve. We have also engaged with the Department of Finance over the years on different proposals it put forward. To echo the point, we would be very supportive of initiatives that seek to enhance protections for consumers in a proportionate and measured way.