Skip to main content
Normal View

Joint Committee on Finance, Public Expenditure and Reform, and Taoiseach debate -
Wednesday, 20 Sep 2023

Banking Issues: Central Bank

I note the minutes of the meeting held in July were agreed at a private meeting of the committee earlier this morning. Apologies have been received from Senator Alice-Mary Higgins.

I welcome the Governor of the Central Bank, Mr. Gabriel Makhlouf, the deputy governor for monetary and financial stability Mr. Vasileios Madouros, and the deputy governor for consumer and investor protection, Ms Derville Rowland.

I remind members and witnesses of the note on privilege. Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official either by name or in such a way as to make him or her identifiable or otherwise engage in speech that might be regarded as damaging to the good name of the person concerned.

I remind members attending remotely that they must be physically present on the Leinster House campus to participate fully in public meetings.

I invite Mr. Makhlouf to make his opening statement.

Mr. Gabriel Makhlouf

I thank the Chairman and committee members for the invitation to appear. I am joined by deputy governors Vasileios Madouros and Derville Rowland. I will begin by giving a brief overview of the economic outlook before discussing how our monetary policy decisions to tackle inflation are transmitting through the financial system to the broader economy - to households and businesses. I will also give an overview of the strong protections we have in place for those who get into financial distress in this rising interest rate environment.

We very much recognise that this is a challenging economic environment for many people. The community has been facing an unprecedented inflationary shock which has impacted significantly on households’ weekly shop, their tank of fuel and their energy bills, to name but a few issues. In response, the European Central Bank, ECB, has raised interest rates at an unprecedented pace. This has meant an increase in mortgage repayments for some, particularly those on tracker rates, but also borrowers on variable rates and those newly applying for credit. Our measures are necessary, however, to ensure inflation returns back to our 2% target over the medium term. If inflation becomes entrenched across the economy, the overall costs to society, including of subsequent actions to bring inflation back to target, will be much larger.

Yesterday, we published our latest quarterly bulletin, which gives our current assessment of the Irish economy. Our forecasts suggest Ireland’s economy will grow by 2.9% this year, and by 2.6% and 2.3% in 2024 and 2025 respectively. We have one of the strongest growth rates in the euro area and labour market conditions continue to remain tight. Employment has reached record levels, unemployment is very low and vacancies across the economy, although they have eased more recently, remain above pre-pandemic levels.

We are entering a period where domestic growth may be more constrained than we have previously seen. There are different reasons for this. First, capacity constraints in the economy are becoming more binding, as evident in the very tight labour market. Second, tighter monetary policy is gradually beginning to weigh on demand conditions both in Ireland and abroad. Third, the growth outlook for the world economy remains subdued. Ireland, as a small open economy, is very exposed to developments in the rest of the world.

While the continued expansion of economic activity and employment levels have been positive developments, not least in the context of the extraordinary shocks that hit the global economy in recent years, inflation has been, and remains, a considerable economic challenge. When everyone pays more and gets less for it, it can have serious consequences on the economy and the welfare of people as a whole. We know inflation hits some, particularly the less well-off, harder than others, but everyone in society will be affected if high inflation persists.

Despite the recent easing of inflation in the euro area, to 5.2% as per yesterday’s Eurostat flash estimate for August, it remains too high. The outlook is for a decline in euro area inflation to 3.2% and 2.1% in 2024 and 2025, as energy, food and industrial goods price growth slows, offsetting more persistent upward pressure from services. To reinforce progress towards its target, we decided to raise the three key ECB interest rates by 25 basis points. Accordingly, the deposit facility rate has been increased to 4% and the rates on main financing operations and the marginal lending facility have been increased to 4.5% and 4.75% respectively. We consider that the key ECB interest rates have reached levels that, maintained for a sufficiently long duration, will make a substantial contribution to the timely return of inflation to our target. Ireland’s consumer price inflation also remains high but declining, and it is anticipated to reach 2.3% by 2025 in the central outlook. The monetary policy actions taken by the ECB for the euro area as a whole will also make a substantial contribution towards bringing inflation back to 2% in Ireland.

In line with normal practice, I wrote to the Minister for Finance in June outlining the key points I believe he should take into consideration in his budget. Since then, the summer economic statement signalled a budgetary package that is significantly more expansionary than was outlined previously. Such revisions can amplify demand in an economy already operating at capacity and shift the stance of fiscal policy in a pro-cyclical direction.

The governing council of the ECB is taking the necessary decisions to get inflation back to target but, of course, monetary policy is set for the euro area as a whole, whereas fiscal policy remains a national competence. As we come up to the budget, it is important that fiscal policy does not add to our domestic inflation problem. It would be counterproductive for domestic policy to stimulate demand and result in a period of higher and more prolonged inflation in Ireland than currently expected. It would damage the competitiveness of the Irish economy and potentially undermine its ability to deliver sustainable growth in living standards.

We are a small open economy with high debt levels and are vulnerable to shifts in the global economy. We tend to experience greater extremes compared with larger and more diversified economies, which has implications for both price and financial stability. We must take the opportunity to enhance medium to longer term resilience in the public finances and the economy as a whole. In this context, I again welcome the Minister’s proposal to establish a long-term savings fund, which takes into account the current windfall nature of excess tax receipts.

I will move on to the impact of monetary policy on lending, deposits and consumers. Monetary policy works through multiple channels. A central channel is the banking channel, via pass-through to credit and deposit rates. We are seeing monetary policy transmit to the Irish economy, with increases in the interest rates on loans and deposits through the past year. This transmission has been particularly strong in terms of new loans to, and term deposits from, businesses. To date, however, Irish banks have lagged behind euro area banks with respect to pass-through of interest rate increases to the household sector.

In terms of household deposits, our latest evidence, some of which we recently published, shows that pass-through has been slow, both relative to euro area peers and our own experience in the previous tightening cycle. There are a number of potential factors contributing to slow pass-through. For example, deposit-to-loan ratios in Irish banks are particularly high, which means banks do not need to attract deposits. Moreover, competition dynamics in the market for banking services are very different now, relative to the previous tightening cycle. Consumer inertia may also be a factor, as we have seen less of a shift into term deposits than in other euro area countries. Approximately 94% of deposits from households are in demand deposits and current accounts, rather than term deposits or notice accounts. In the EU, the equivalent figure is approximately 80%.

In terms of mortgage lending, interest rate pass-through has varied, based on the product type. The largest increases have been on tracker mortgages, the interest rate of which moves mechanically in line with the reference rate, typically the ECB’s main refinancing operations rate. For new mortgage lending, we have so far seen less pass-through than the euro area as a whole or what our own historical experience would suggest.

The ECB, or indeed the Central Bank of Ireland, does not have a role in setting commercial rates on bank products, but it is something we monitor closely to assess the extent to which our monetary policy measures are transmitting through the Irish financial system. It will take time for the full impact of rising rates to be felt fully by households and businesses. Given historical patterns, we expect the banking channel to strengthen in the months ahead. People should be prepared to continue to see increases in both their deposit and lending rates in the coming months. Firms will make their own commercial decisions, but the transmission of monetary policy measures is critical to ensure inflation returns to our target of 2%. Ultimately, low and stable prices protect consumers.

This is a very challenging time for people. The increase in the cost of living, along with rising mortgage repayments, puts additional pressure on borrowers.

Just last week we released the latest mortgage arrears statistics. We are seeing total primary dwelling home arrears over 90 days stabilising, having been in persistent decline for the last decade. Long-term arrears are still falling overall, but there was a slight increase in arrears over 90 days and up to one year, suggesting that some of the early arrears cases are transitioning into arrears cases. Although every case represents a person or household in distress, the numbers are very small at present. We remain vigilant to these issues as they emerge. Arrears can be a lagging indicator, which is why, over the past year as the interest rate environment changed rapidly, we have been focused on ensuring the financial sector is ready to respond to borrowers who find themselves in a difficult financial position in a consumer-focused manner.

Of course, our work did not begin a year ago. We have been taking action over the past decade to limit the build-up of risks for the financial system and households. For example, we have introduced and tailored our macroprudential mortgage measures, added to our consumer protection code, strengthened the requirements of the arrears framework and worked with industry to enhance supports they offer. All of that has led to a position where we now have one of the strongest frameworks in Europe to help us deliver better outcomes for consumers.

These measures, and positive developments in the Irish economy in recent years, mean households have entered this cycle in a more resilient position. The macroprudential measures we introduced have limited overborrowing and overlending, which was a problem in the past. This means the household sector as a whole has a debt-to-income ratio of 90%, compared to 200% in 2008. This lower indebtedness provides greater resilience in the face of rising interest rates. In addition, the balance sheet of the household sector has been bolstered by record levels of savings, although these are not distributed equally across households. The strong labour market and record levels of employment have also been supporting income growth.

Notwithstanding the aggregate resilience of the household sector, given the challenging macroeconomic environment we expect that some people will unfortunately find themselves in financial difficulty. Since I was last before the committee earlier this year, we have continued to progress our phased work with mortgage providers and servicers and their representative bodies. As we outlined in our update published in April, the initial phase of our work established that, properly applied, the regulatory framework is well positioned to deliver for consumers in the current context. Our analysis has also shown there is no evidence of discrimination for switching applicants coming from non-banks based purely on where their mortgage is currently held.

As we have progressed our current phase of work, we have seen tangible outcomes emerge from individual firms and collectively, including the following. Firms have further developed their early warning indicators to improve identification of, and proactive engagement with, customers who are in, or in danger of falling into, arrears. In response to these early warning indicators, firms have introduced a range of measures to help support borrowers, including increased resources to support customers. Firms have continued to enhance alternative repayment arrangement, ARA, supports for borrowers in or facing arrears, including the introduction of fixed-rate ARA options which has been announced publicly. Firms have enhanced borrower communications initiatives on switching and some have launched proactive outreach campaigns aimed at specific groups of borrowers. We have also seen a system-wide initiative across all firms with the recent announcement of the new support measures for borrowers in the Banking and Payments Federation Ireland, BPFI, "Dealing with Debt” campaign, which has introduced system-wide initiatives to support mortgage switching for the first time and increased co-ordination with the Money Advice & Budgeting Service, MABS, and mortgage brokers to enhance how the mortgage market operates for consumers.

These are important outcomes that matter to people. While measures taken by firms to date are welcome, we will continue to engage with them to ensure actions meet our expectations and all industry participants are extending themselves to support consumers in difficulty. This will include ensuring those borrowers who should expect to be able to switch product or provider are supported to do so, noting that the data on mortgage approvals for the first seven months of 2023 show that overall remortgage and switching activity fell by 78.6% in volume on a year-on-year basis.

The outlook for the remainder of 2023 and into 2024 will continue to be characterised by high uncertainty, as the battle against high inflation continues. The Central Bank will continue to focus on maintaining monetary and financial stability and ensuring the financial system works for consumers and the wider economy. Ms Rowland, Mr. Madouros and I are ready and happy to take members' questions.

Cuirim fáilte roimh na finnéithe. I will start by asking a couple of questions on mica. I met with the Central Bank team privately on these issues from a consumer protection point of view. I know the bank has also met with the focus group, which we have had before the committee. There are serious issues for householders in Mayo, Donegal and elsewhere who have to rebuild their homes as a result of light-touch or no regulation at the time and have deleterious material in their homes, resulting in them being demolished and rebuilt. The banks have washed their hands of the matter, in my view. They are not going to financially contribute to the scheme, even though their assets will be restored. What oversight has the Central Bank of a bank with a mortgage secured on a home that is to be demolished? How is that recorded in relation to asset values in the banks? Does the Central Bank have any guidance on that? Have the banks written down the asset value in relation to that? What is the witnesses’ view of the fact that all mortgage contracts require the individual to seek permission to demolish their home beforehand? Is there a responsibility on the financial institution, in giving that authorisation, to satisfy itself the individual demolishing the home - that is, the homeowner - has the resources to rebuild it appropriately? That is the problem. The Government has not given a 100% grant and many people have had to, as the committee has heard, go to parents looking for loans, get credit union loans at 8% interest and in some cases have had to get bridging finance at rates over 8%. It is €60,000 in some cases. Many people I know in my constituency will not get those loans. Some are over the age of 65 and will not get them. The BPFI is doing work on this and there will be an announcement tomorrow but there is an issue of consumer protection here. What action is the Central Bank taking in relation to the thousands of homeowners in this situation who are not getting access to credit to rebuild their homes and in relation to the conditions for extending their mortgage, in terms of permission to demolish and rebuild?

Mr. Gabriel Makhlouf

I will ask Ms Rowland to come in on this but I will say two things immediately in response. First, I have a lot of sympathy with all the households impacted by this. In my previous life, I know of similar but different situations arising and I know how stressful that can be for households. The Central Bank has met with some representatives of the group in question. Ms Rowland can expand on our role in any situation that arises, as opposed to anything unique to mica. I welcome the work the BPFI has done, incidentally. At one level, there is a limit to the additional things we can do. Perhaps Ms Rowland can come in on this.

Ms Derville Rowland

I will try to answer the Deputy's questions in turn. I do not have the answer right now on the writedown of asset valuations but we are happy to come back to him in writing. We met with some of the people affected by mica last week.

They raised a number of issues with us, including shortfalls in financing, the rate of financing and the interpretation of contract terms in mortgages for these special and very unique circumstances as well as issues around insurance for their homes because, if you have to move out, that can affect your insurance. We asked them to come back to us with specific requests for the Central Bank because this is a unique situation.

I really welcome the support these homeowners are going to get from the Government redress scheme but it seems that a myriad of issues arise. There is now a need to focus more on a co-ordination mechanism to make the scheme that is in place work for the homeowners across a number of headings and on a consistency of approach between the terms and conditions of each of these elements and the scheme around contracts, because this is not the usual situation. There is a group of people affected by mica whose homes have to be demolished and rebuilt. That affects mortgages, insurance and financing and all of those things have to brought together in a co-ordinated fashion so that a standard set of answers can be applied to the scheme to help people make it work. The issue around the interpretation of the contracts and the demolition and rebuild is unique to the scheme and this needs to work in the context of the scheme. I am not able to answer across each of the headings here but I am very much in sympathy. We can see how, outside of the Central Bank's role in supervising the different entities, co-ordination is needed across all of the elements so that the homeowners can get where they need to get to, that is, get their homes rebuilt and get on with their lives. It is a little bit beyond the financial system.

Of course, I welcome the fact that Banking & Payments Federation Ireland, BPFI, has indicated a willingness to work on this. I believe Insurance Ireland has also indicated such a willingness. However, when you have a redress scheme like this, you have to bring all the issues together in a co-ordinated way so that a uniform set of answers and approaches can be delivered for the people. We are very supportive and very willing to encourage the financial services system to play a sensible role in supporting the working of the scheme but there will be a limit to what we can do in this respect. However, there is a strong place for practical co-ordination so that people do not have to keep going to different places, getting slightly different answers, to help the scheme to work. We are very supportive of that.

I thank Ms Rowland. We will continue this engagement because this is obviously going to take a while to work through. We will wait to see what the BPFI has to say about this later on in the week. The Governor made the point that the maintenance of the European Central Bank, ECB, rate for a sufficiently long duration will make a substantial contribution towards a timely return of inflation to the ECB's target. Before all of the ECB governing council's meetings, meetings where it decided to increase the ECB rate ten times in a row, economists are polled. In fairness to them, they have got it right nearly all of the time. It was probably the closest this time around but the majority still suggested that there would be an increase of a quarter of a percentage point. In the same poll, economists estimated that rates would start to decrease in March of next year. What are the Governor's reflections regarding the ECB achieving its target? He talked about achieving 2.1% in 2025 and a reduced rate next year. In his view, are the economists right again that it is fair to suggest that rates could start to reduce in March of next year if things stay along the course as set out?

Mr. Gabriel Makhlouf

At the moment, my view is that March is probably too early. People should certainly not be planning on the basis that March will be the start of this. They certainly should not be doing financial planning on that basis. The honest answer is that it is too early to tell. We have made it clear, and I have said it in my statement, that we live in a period of uncertainty which, unfortunately, has gone on for quite some time. I said before the summer that I believed we were getting close to the top of the ladder as regards interest rate increases and I believe we are now there or thereabouts. In the ECB's statement, we made the point that we were going to - these were my words - hold rates there for a while. People who are saying that we are going to start to reduce rates in March are just speculating. There is nothing wrong with speculating but my personal view is that I would not speculate at this stage.

Obviously, this is important for people making really important decisions. People have to make decisions based on their best assessment. I agree with the Governor's comment that people should not be banking on interest rates increasing in March just because the economists are telling-----

Mr. Gabriel Makhlouf

Decreasing.

Decreasing, yes. People should not bank on that just because economists have told them it would happen. However, there are people out there who are now thinking about what to do with their tracker rate. They are wondering whether to move to a fixed rate or whether the economists are right in what they have suggested, which is a decrease in March. They were thinking April before last month but now they are thinking about March and that there will be further stepped decreases throughout 2024 and 2025. They are not suggesting we will go anywhere near where we were but rather that there will be small decreases along that pathway. When does Mr. Makhlouf believe the ECB, or he himself as Governor, could give an indication? He has indicated in his opening statement that it is to hold. If things remain the same - and things can change - the ECB is unlikely to increase rates again so it is a question of holding at this point in time.

Mr. Gabriel Makhlouf

That is the Deputy's interpretation of my statement. I believe what I said was that we feel we have made a substantial contribution towards getting inflation back to the target. I am happy to confirm now that I am not saying that, at our next meeting, we are going to hold. Those who assume that we will hold are not speculating like those who believe we are going to cut in March but we are near the top. When will we know a bit more? In all honesty and to take a step back, as the Deputy will know, I do not give financial advice so people should not take what I say as the basis for decisions when planning what to do with their trackers and so on. When we have our next set of projections in December, we will have had more data points from now and what has happened over the summer will also have become a bit clearer. December will be the first set of projections to include 2026 in our horizon. We will then have a better sense, if not as certain a sense as the Deputy may want, of what the profile will be next year.

I want to move on to a number of other questions but there are some who will say that the ECB was too slow to act and that it risks holding for too long. We know that high interest rates can have a serious impact with regard to recessions, employment, pressures on households and all of the rest. Perhaps, in his commentary, the Governor might answer that question or say what he thinks about that response.

I also want to talk about the impact of these rates. Outside of the objective, which is to get inflation under control, there are winners and losers here. The Central Bank's own assessment has shown that 20% of households are paying an average of approximately €5,700 in additional interest when compared with last year. However, the banks are clearly winners in all of this, are they not? The Irish financial institutions have reaped a bonanza as a result of the ECB interest rate increases. The rate has gone from -0.5% to 4% and, given the fact that Irish credit institutions have €84 billion in deposit facilities at the Central Bank, is it not the case that they have generated an additional €3.3 billion as a result of the interest rates compared to the position last year?

Mr. Gabriel Makhlouf

That is 3.75%. The Deputy's maths are correct. Certainly, if you take a narrow window or snapshot, he is not wrong but I would say a couple of things.

The Deputy mentioned the banks, although there are other winners and losers. When looking at the banks specifically, one needs to look at what happens over a cycle. We have gone through an extraordinary period, which has now ended, of very low rates. That had a different effect on the profitability of Irish banks, which rely more on their deposit and lending functions for their profits than many other banks in Europe do. The fact that rates have increased has had an impact. On the other hand, there will be further consequences as a result of the tighter financial conditions that obtain currently. They will have an impact on those profits. I will invite Mr. Madouros to contribute, as it would be worthwhile to have him expand on this point a little.

The Deputy made a valid point. I want to pay – and we do pay – close attention to how monetary policy is transmitted in Ireland on the deposit side and on the lending side. The role that the deposit facility in the ECB plays, the way it works and what it means for banks will form part of a review of how we at the ECB operationalise our monetary policy framework. We are not ignoring these issues; we are very focused on them.

Mr. Vasileios Madouros

I will add a couple of points. The Deputy spoke about inflation and the importance of reaching the 2% target. That is because inflation has had such a large cost for society. The risks of not reaching the target are that the costs of high inflation are prolonged and, if that high inflation were to become entrenched in the economy, the policy action to bring it back down to 2% would be even more painful. That is why actions have been taken by the ECB to respond to the extraordinary combination of shocks that have led to the large increase in inflation.

It might be worth setting out how we think about bank profitability. As the Central Bank, we do not care about profits in and of themselves. We care about sustainable business models in financial institutions and sustainable levels of profitability. These are needed to ensure that the financial system is in a position to support businesses and households. When the Central Bank looks at profitability, we look at it through the cycle. Prior to the recent increase in interest rates, there was a period of low interest rates. Net interest margins were compressed and the return on equity for Irish banks was below the European average. More recently, we have seen an increase in profitability. To some extent, this has been due to timing and a sharp adjustment in the interest rate cycle. As the Governor mentioned, we expect that there will be some factors that will lead to profitability settling down. For example, deposit rates have responded already. We expect to see more depositors shifting from overnight to term deposits.

I am sorry for cutting across Mr. Madouros. I am not questioning the ECB’s decision to increase rates. It is independent and I would not dare question it in that respect. However, I am speaking about the consequences. By increasing the rate to this level, Irish financial institutions have made €3.3 billion in profits because they have so much on deposit, because of the lending facility, because of the deposit facility and because of €84 billion of Irish taxpayers’ money. Mr. Madouros stated that the Central Bank was not interested in banks’ profitability and that it was considering the long term, but the Financial Conduct Authority, FCA, in Britain sat down with banks and devised a pass-through plan for depositors. Banks in Ireland are increasing their deposit rates, but those rates are a fraction of what they are getting from the ECB. These banks were profitable last year when they made €2.2 billion in profit. They are now making €5.1 billion in profit. This is not because of innovation or additional lending, though. The driver of the approximately €3 billion in additional profit that banks will make this year is the ECB increasing the deposit facility rate. Ireland was at the bottom of the Financial Times’s league of pass-through rates. The Central Bank did not seem to have a plan. The FCA did, one that required firms to show it every six months how they were passing through and so forth. On the back of the consequences of the ECB’s decisions and the multibillion euro profits that the banks are making, are the witnesses satisfied that the banks are doing enough and treating their customers appropriately in terms of this bonanza for the banks?

Mr. Vasileios Madouros

As the Governor said, we are extremely focused on how monetary policy transmission is operating in Ireland. We published an analysis last week that examined this matter closely in terms of what was happening in other countries and here. It is true that, on the household deposits side, the Irish banking system has been slower than other parts of the euro area and what we would have expected relative to our history. We are looking at this matter closely. We are seeing advertised rates increasing-----

Mr. Madouros says that the Central Bank is "looking at" this matter closely. The consumer is also looking at it and is seeing interest rates increase. The interest rates on all mortgage lending, not just new mortgage lending, are still 50% higher than the European average whereas deposit interest rates are lower than the European average and Irish banks are making bonanza profits because Irish customers have so much on deposit with them. The Central Bank is “looking at” it. People feel screwed by the banks where this matter is concerned, and that is even before I talk about non-bank lenders. My time is up, though.

I welcome the Governor and deputy governors.

I will begin with the Governor on the issue of what is seen as an unprecedented pace of increase in interest rates by the governing council of the ECB. Mr. Makhlouf stated that this was to combat the “unprecedented inflationary shock which has impacted significantly on households’ weekly shop, their tank of fuel and their energy bills”. When the governing council considers increasing interest rates, does it ever take into account the impact its decision will have on the people Mr. Makhlouf mentioned, for example, household bills and mortgage increases?

Mr. Gabriel Makhlouf

Completely, but it also takes into account what inaction would do. Inaction means inflation would continue or increase further and the less well-off would be the most harmed. The reason we are increasing interest rates is because we do care about what happens to households and the economy. We need to get on top of inflation before it becomes embedded. As we know from history, if inflation becomes embedded, it is extremely damaging to the whole community, but particularly to the less well-off.

It appears to be axiomatic that, if inflation is high or remains high, interest rates will increase irrespective of the impact that will have on households.

Mr. Gabriel Makhlouf

Monetary policy will, in the end, bring inflation down. That is what we are projecting.

Am I correct that, irrespective of the care and concern that the governing council may have, it is axiomatic that interest rates are going to increase if inflation does not decrease?

Mr. Gabriel Makhlouf

Yes.

I wish to raise a separate point.

Mr. Gabriel Makhlouf

I am sorry, but I might say something, as I was trying to think about what the Deputy’s question was exactly. If inflation stays the same, it does not necessarily mean that interest rates will increase. They could just stay where they are for longer.

One of the methods that politicians have for trying to respond to the impact on household incomes of higher mortgage rates is mortgage interest relief. In advance of the forthcoming budget, the Central Bank and the Irish Fiscal Advisory Council, IFAC, have issued warnings to the Government about inflationary measures.

What is the Governor's view of, or advice on, the introduction of targeted and temporary mortgage interest relief to alleviate the pressures that households are under? Does he think that would add to inflationary pressures?

Mr. Gabriel Makhlouf

It would depend on how it was designed, how large it was and on whether it was something done through the tax system as opposed to a relief provided through the social welfare system. It would depend on a number of things.

The Governor is not set against it in principle. Is that correct?

Mr. Gabriel Makhlouf

It depends. I will be very frank. My general philosophy on tax reliefs is that I do not like them. My general philosophy is that it is much better to have a tax system that is broadly based because that minimises economic distortions. Where reliefs are intended to provide support to individuals, households or businesses, in my experience they are much better if they are targeted and are either done through grants or the social welfare system. That is my general philosophy. I am making a micro point as opposed to a macro point. As I said in my statement and in my budget letter, increasing the demand stimulus we put into the economy to essentially counteract what we are trying to do is not helpful.

I will deal with that issue now. I have noticed in the past number of weeks that both the Central Bank and the IFAC have been more vocal in making comments in respect of the forthcoming budget. What are the bank's concerns? The Governor said that the Government should be hesitant about introducing measures that could add to the inflationary shock. What specifically is he concerned about?

Mr. Gabriel Makhlouf

My comments were at a macro level. I am not specifically talking about anything in particular. The ECB, the governing council and Ms Christine Lagarde have, over the last couple of years, emphasised that any support given by governments through this cost-of-living crisis should be targeted, tailored and temporary. Obviously I agree with that as a general proposition. For the Irish economy, because it is operating at capacity, it is even more important, given that monetary policy operates at the euro area level, that fiscal policy does not militate against what we are trying to do and make the inflation problem worse domestically. One of the consequences of us having such a strong economy, paradoxically, is that fiscal policy decision making needs to be extremely careful. What I have been saying, in the letter I wrote to the Minister in June and in statements I have made in the past, is that the Government needs to take great care in how it designs its budget so that it does not exacerbate the problem that we are trying to address at the ECB.

In his statement the Governor mentioned that in Ireland we have one of the strongest growth rates in the euro area. Sometimes we take that for granted. If one looks at other countries, particularly the UK, they are desperate to try to achieve some level of growth and would have huge ambition and desire to have our growth rates. Why does he think we have been successful in achieving these growth rates? What political decisions have been made that have facilitated this?

Mr. Gabriel Makhlouf

Political decisions-----

Presumably politicians-----

Mr. Gabriel Makhlouf

I hesitate to get involved in a political discussion but I will mention a few things, if I may. First, I would encourage all members to spend less time comparing us to the UK and more time thinking about how we compare to other parts of Europe because increasingly one of the answers to the Deputy's question is that we are in the EU and the UK is not.

That is a fair point.

Mr. Gabriel Makhlouf

We are part of a market of more than 300 million people and the UK is not. That is one issue. Honestly, if one thinks about why the Irish economy is in the position it is in now, it is for a number of reasons including the fact that we have the rule of law operating, we are in the EU and we speak English. It is also because we have a much more special relationship with the US than the UK thinks it has and as a result, we have had incredible investment here. Another issue, which is underplayed and which for most people is forgotten, is that some of the education changes we made in the mid to late 1960s have fed through and have led to the development of a very skilled labour force. That has played a part, never mind the decision we made to open up.

This is one of the great paradoxes of what the UK has done. In the 1960s, Ireland decided to open itself up to the world but the UK has actually decided to close itself off from the world. For us, 60 years on, we have had ups and downs in this period but we will see in another 60 years how the UK is doing, having closed up, compared to how we are doing - and have done - by opening up.

I will take on board the Governor's advice to stop comparing us to the UK.

Mr. Gabriel Makhlouf

It is not so much that we should stop comparing ourselves to the UK but more about the need to look at what is happening in the rest of Europe because we are part of that club now and the guys next door are not part of it.

Are our growth rates not higher than those in the rest of the eurozone?

Mr. Gabriel Makhlouf

Yes, they are.

Obviously there is something else to explain it-----

Mr. Gabriel Makhlouf

It is part of what I said. It is the way our tax system is designed, our relationship with the US, the skilled labour force and speaking English. It is all of those things.

Finally, in respect of the failure of the banks to pass on the interest rate increases to deposit holders in accordance with the increases made by the ECB, in practical terms what legal powers does the Central Bank have to do anything about that?

Mr. Gabriel Makhlouf

We do not have any powers in terms of setting rates in practical terms. On the other hand, we do have powers, as I said in response to Deputy Doherty, at the ECB to set the deposit facility rate and to decide how that should apply to the deposits that the banks make and that could influence their decision making. However, these are commercial decisions. The banks, to be fair to them, have been slow in passing on the rate increases but it is not that they have done nothing. They have been slow but we have seen the banks making announcements recently.

From a monetary policy perspective, I would want to see much faster pass through of the decisions we make to the real economy on both sides of the ledger. As I said in my statement and as Mr. Madouras said, this is the first time in a long time that we have had an interest rate hiking cycle. How the monetary policy decisions are being transmitted through the economy is something we want to pay extremely close attention to, so this is not an issue that is going to disappear from our work programme.

Go raibh míle maith agat a Chathaoirligh agus gabhaim buíochas leis an nGobharnóir as a chur i láthair inniu.

The Government itself controls the prices of some products. For example, the Government increased excise on petrol and diesel on 1 June. It did the same on 1 September. It plans to do so potentially at the end of October. It plans to put up carbon taxes in the budget. We saw tolls increase in July and, potentially, will see them increase again at the start of next year. Has the Central Bank quantified exactly how much of the current inflation rate increases have been caused directly by Government decisions?

Mr. Vasileios Madouros

To the extent that some of our projections have been pre-announced, energy taxes or carbon taxes, for example, would be incorporated in some of them, but I am afraid I do not have the precise contribution within that. I do not know it. We can get that-----

Would it be possible to get it?

Mr. Vasileios Madouros

Yes.

The Government plays a significant role in causing inflation by these types of decisions as well, and it would be interesting to quantify exactly what proportion that is of the total inflation rate.

It has been reported that real incomes fell in 2022. They fell significantly in the lower deciles of incomes within the economy. Has the Central Bank forecasted if real incomes will fall again in 2023?

Mr. Gabriel Makhlouf

I think we are forecasting the reverse to happen this time.

Mr. Vasileios Madouros

Yes, that is right. As nominal incomes are starting to grow and inflation is starting to dissipate at an aggregate level, we expect real nominal incomes to grow again.

In 2023. Does that include right across the income spectrum, or might there still be an income fall for the lower quarter?

Mr. Vasileios Madouros

We do our projections on an aggregate level, so it is the aggregate figures I am quoting. We do not have distributional projections.

Okay.

The Central Bank has given warnings in respect of Government spend and the influence that that will have on inflation. The Government has committed about €165 billion into capital investment in the national development plan. Much of that investment is sorely needed because of infrastructural depreciation and capital depreciation over the past ten years. Do the witnesses think, however, that the Government's current commitment to that €165 billion in capital investment is possible, given the restrictions that exist within the economy at the moment? If it is not possible, how will it affect inflation?

Mr. Vasileios Madouros

This goes back a little to a conversation we had earlier. When we think about, for example, our advice in terms of fiscal policy, it is very much in terms of the aggregate fiscal position, that is, not necessarily about either the composition of spending, whether capital or current, or the balance between taxes and spending. When we think about what the effect on the economy and the effect on inflation would be, we think about it as the aggregate fiscal position, not adding to stimulus and, therefore, fiscal policy and monetary policy not pulling in opposite directions. Of course, there are major infrastructure challenges in terms of the economy. We have said that within the Government's own fiscal net spending rule, prioritising capital investment would help address some of these infrastructure challenges.

Mr. Gabriel Makhlouf

To put it another way, how the Government designs its capital investment programme will have, or could have, an impact on inflation. The design of particular projects, how much labour is actually needed, the timing you want to do it in, etc., all can have different impacts. What we have said, therefore, and what I will say right now is design your investment programme in the best way not only to deliver the outcome you want from the infrastructure but also to minimise the impact on the economy through the pressure on inflation etc.

I suppose the aggregate figures in many ways do not lend to differentiating policy decisions. Some infrastructural investment would actually decrease the restrictions that exist and the tightness of the market in the long run, which would allow for inflation to decrease in that space. Also, workplace planning, trying to get more particular skills into different sectors of society, even bringing home people from Canada and Australia who may have left within the past decade - those types of steps could have a positive effect in achieving policy objectives and not negatively affecting inflation.

Mr. Gabriel Makhlouf

I agree.

In other words, there is room for manoeuvre in a number of ways for the Government in trying to achieve its objectives while not negatively affecting inflation.

Mr. Gabriel Makhlouf

Yes.

Good stuff.

As for deposit interest, Mr. Makhlouf mentioned that there has been a yawning differential between interest rates charged on lending vis-à-vis interest given on deposits just in recent times in Ireland. Does that not make the argument stronger for significantly increasing the banking levy on banks? Currently, I understand the banking levy takes in about €87 million, where it was originally identified for €150 million. Given that excess profitability that exists because of those yawning differentials, would it be a possible policy lever for the Government to increase the banking levy to, let us say, €200 million or €300 million?

Mr. Gabriel Makhlouf

That is first and foremost a question for the Government. I will bring out two issues, first a general one around tax policy. My advice to anybody thinking about a tax policy change is to at a minimum consider three questions. First, what are you trying to achieve? Are you trying to collect more revenue for the Government or are you trying to correct some sort of externality? Be very clear on what you are trying to achieve. Second, where do you want the incidence of the tax to fall? Who is it in the end you want to pay this tax? Is it the shareholders of a business? Is it individuals? Is it the consumers of a particular product that that business makes? That is a question that needs to be thought through. I am talking in general terms now; I am not talking about the banking levy. It is a question that applies to all tax policy questions. Third, make sure you think very carefully about the indirect consequences of any decision you make. In particular, if you can think through the unintended consequences of any decision you make, that would be even better. That is a general tax policy thing. If anyone were to ask me, that is what I would reply.

From a Central Bank perspective, however, and specifically to the Deputy's question about the banking levy, at the end of the day this is a question for the Government. Our interest will be what the impact would be of whatever increase or change is made on the financial system and what the impact would be on the economy. Part of our job is to ensure financial stability, to ensure that the financial system works for the real economy.

I will speak hypothetically for a minute. One of the consequences of an extremely high banking levy – I will not say what that number might be – would be to disturb a bank’s capital position. What the impact of that change on the bank would be depends on the individual bank, so we must be careful about the design if we go down that road. The other issue I would be concerned about is that if there was a very high increase in that sort of tax, what would happen to the lending we want banks to do into the real economy? Would increasing the levy - I am not saying by what amount but by a very big amount - not only impact on the bank's capital position but also on its capacity to lend into the real economy, which would have negative consequences for everyone in the end? Those are the kinds of things we in the Central Bank think about but, at the end of the day, tax policy is a question for the Government and not for us.

I will be quick because I have to run to the Chamber shortly. The major issue in taxation is revenue collection, although economic justice is also relevant, to ensure all aspects of society pay a fair contribution in respect of the profits they make. Some of the issues around the differential between interest rates could be resolved if there was proper competition in the sector. One of the biggest failings of current Government policy is the fact that there is no real plan to increase competition in what is a duopoly. Two pillar banks have the vast majority of the market between them and, as a result, normal competition dynamics do not exist for many people, both lenders and deposit holders. That could be resolved with improved competition in the sector.

The last question I have-----

The Deputy's time is up.

I will leave it at that. Perhaps the competition issue could be dealt with.

Mr. Gabriel Makhlouf

I did not hear the question.

Will the Deputy ask the final part of his question?

The final part was that one of the big weaknesses we currently have in the banking sector is the lack of real competition. What is the Central Bank's view on what steps could be taken to increase competition and therefore increase the competitive dynamic in the sector?

Mr. Gabriel Makhlouf

That is a very big question. First, there is an issue with competition. We are not responsible for competition because the Competition and Consumer Protection Commission, CCPC, is. I think I have said before - I cannot remember if it was in this committee - that at some point in the future, I expect the CCPC will want to look carefully at how competition is working. At the end of the day, we encourage competition in all sorts of different ways. I say "we", the country, as opposed to "we", the Central Bank. Incidentally, competition as a policy objective was taken away from the Central Bank a decade ago. We do not have a direct interest in promoting competition so I am talking generally. It is of benefit to the community to attract more competition. The question we particularly need to be asking ourselves is whether we think capital that is available to be invested will come to Ireland or go somewhere else. Are the conditions in place in Ireland attractive enough for people to compete with the banks? That is a fundamental question about how competition can be made to work here. The reality is that some small players have entered the market, but unfortunately some big players have left the market. It is an important issue that will require a lot of attention.

Coming from a different point of view on the last point, would it be fair to say that competition in the Irish banking sector has been a disaster and that all the reckless lending practices by banks that we saw when there were more people in the market helped to contribute to the last economic crash? Indeed, when we look outside the pillar banks - not that the pillar banks are saints, by any stretch - at the non-bank lenders, the vulture funds are charging extortionate interest rates, some well in excess of the ECB rates. So-called additional competition has been damaging at just about every level for the Irish economy and for Irish society. Would that not be a fair comment on the actual experience as against theories of competition?

Mr. Gabriel Makhlouf

I do not think so. Competition was not the cause of the financial crash. The cause of the financial crash-----

Is Mr. Makhlouf saying that banks trying to outdo one another with reckless lending was not a contributory factor?

Mr. Gabriel Makhlouf

It obviously played a role, but ultimately the cause of the financial crash was that regulation was inadequate and the system allowed - I have used this phrase before - a lot of reckless lending and reckless borrowing, not only in Ireland but also in the United States and everywhere else. The system was not good enough. The past decade has seen that system strengthened. Certainly in Ireland, but I also think it is the case globally, we are in a much stronger position. Competition was not the cause of the crash. Competition ultimately brings benefits to consumers. We see in other parts of our economy and economic lives that competition drives out benefits for citizens.

We will agree to disagree on that.

Mr. Gabriel Makhlouf

I thought the Deputy might.

I think insane competition at every level in the banking sector contributed enormously to banks encouraging people to speculate, for example, on buy-to-let mortgages, including people who should never have got into that. That is one example. There are many others, but we will agree to disagree on that.

I will ask about the Central Bank's warning to the Government about not taking budgetary measures that could contribute to excessive demand and therefore to inflation. Does Mr. Makhlouf not think it would be better to look at what we mean by demand, including whose demand and what type of demand? Would it be fair to say that supply, in terms of the current shock, is a more important factor? I will explain what I mean. First, the explanation for the current cost-of-living crisis for ordinary people - I do not know whether Mr. Makhlouf agrees with it - has to do with something called supply chain bottlenecks. These are decisions made by producers of goods, such as corporations, companies, energy companies and so on, to reduce the supply of goods. Similarly, in the area of property, those who have taken over or bought up huge sections of the property market have been manipulating supply in order to keep up the value of their investments and, therefore, rents, property prices and so on. I question, therefore, a warning against measures - because that is how it will be translated and has been translated in popular discourse - which might compensate people for the loss of earnings and loss of income they have suffered. For the vast majority of workers, pensioners and students, the problem is not that they are spending too much. It is that they have lost the ability, in some cases, to put food on the table or pay the rent.

There would be nothing inflationary about just taking measures to compensate them to ensure they had not lost income. I worry that the narrative comes out that the Government must not do things to fuel inflation and that translates in popular debate that the we must not give the workers pay increases or increase social welfare or pension rates because, God, that would contribute to inflation. The underlying assumption there is that people getting paid too much or people getting excessive social welfare created the inflationary problem but it has not. Is it not a fair comment to say that it has not created it at all and in fact quite the opposite is happening to the majority of people? There may be luxury demand that is being boosted. If a lot of someone's income is derived from, say, bank shares, then that person might be doing very well. They might be buying more champagne, going out to more luxury restaurants or buying more expensive cars and, sure, we could reign in that kind of demand, but we should distinguish between different types of demand and ask whether it is the spending of ordinary people that has created this mess or whether it is manipulations by some big corporate interests who actually control supply.

Mr. Gabriel Makhlouf

I will ask Mr. Madouros to come in on this as well. First, the reason inflation kicked off the way it did was initially because of supply but the bottlenecks arose primarily as a result of the pandemic. The big chunk of the bottlenecks arose because China had a zero-Covid policy and it is one of the places that both produces a lot of the goods we need but also acts as a big demand engine in the global economy. When it closed down, it created lots of bottlenecks. I use China as an example but essentially the pandemic caused bottlenecks in many global supply chains. The energy crisis was part of that, exacerbated by Mr. Putin's war. Those initial supply shocks became much more broadly based in the economy. We probably differ a little in our analysis of how these things started.

To be clear, the Central Bank is not saying, "Do not provide any support to people who need it" or "Do not to provide wage increases" or whatever. What the Central Bank is saying is that in an economy that is running at capacity, do not add fuel to the fire by spending too much or by spending on the wrong things because ultimately that will fuel inflation. That is what we are saying. We are definitely not saying, "Spend money here, do not spend money there". As Mr. Madouros said earlier, we are operating at a macro level. Maybe he would like to come in.

Mr. Vasileios Madouros

I would make very similar points. On what has happened over the past two or three years, that is correct. There have been some enormous supply shocks hitting the global economy, including the Irish economy. The pandemic was one and had an impact on global supply chains and then, of course, there were energy supply shocks from Russia's invasion of Ukraine. These are big supply shocks. However, we have also seen demand factors at play. When the economy reopened, we saw a surge in demand for certain types of services that people could not access before.

I must interrupt Mr. Madouros as there is a vote in the Chamber. We will suspend.

Sitting suspended at 2.55 p.m. and resumed at 3.13 p.m.

Mr. Madouros was in the middle of responding to a question.

Mr. Vasileios Madouros

We were talking about the balance of demand and supply factors in relation to support. If one looks at the last two to three years, there has been a combination of supply and demand factors. Obviously, we had these enormous supply shocks, first related to the Covid-19 pandemic and the supply chain issues that came after that, and then those related to energy and Russia's invasion of Ukraine. We have also had a big increase in demand. For example, when the economy started reopening, we had this surge in demand for certain types of services that people could not have before, like hotels, restaurants and travel. We have seen elements of that. If one looks at some of the recent data published by the Central Statistics Office, CSO, it rewrote history to some extent and told us that if one looks at consumption, it is now about 3% to 4% higher in aggregate than we thought it was previously. There has been a demand and supply element overall.

Recently, we also did some piece of analysis to try to decompose what has been driving inflation, and the demand and supply factors. There one obviously sees, when one looks at headline inflation, for example, a big supply limit because of energy prices. The fall we have seen in headline inflation is because of the unwinding of some of these supply shocks. However, one also sees a persistent a demand component. If one looks at services inflation, which is more domestically generated, first, one sees it being more persistent because it has not fallen as much and, second, there is a material demand element to it.

Of course, we were also talking about supports. As the Governor said, when we had these extraordinary shocks, clearly there was some part of the population that was particularly vulnerable. Supports have been necessary to support those people in these very challenging conditions. Our advice has been temporary, targeted and tailored as well. At this stage, it is definitely targeted, and I am also thinking about sustainably funded as well.

To follow on that from that, first of all it seems illogical to say that any component of that demand is the demand of ordinary, low- to middle income workers or earners, given that every bit of analysis shows that they have lost, and that demand has been depressed as a result of the cost-of-living and housing crises. It behoves us, and maybe the witnesses - I know they are not the policymakers - to try to disentangle all of that. If there are demand elements, by which we mean spending too much in particular areas - that is really what we are talking about - they are not coming from the ordinary worker, pensioner or social welfare recipient. They are coming from somewhere else. To help us make the right policy decisions, we need to clearly understand that. I note that Mr. Madouros said that often the Central Bank's analysis is of aggregate incomes and aggregate demand, but does it not behove us to break that down a bit and have distributional analysis to see where demand is up and where it is very significantly down?

That brings me to the point about the danger of being procyclical. Is there also a danger of not being countercyclical, following on from that same point? There were alerts yesterday about exports possibly beginning to fall. Presumably that is because of falling demand in Europe and elsewhere. It certainly seems logical to me that if the vast majority of the population now has less real income, then at some point that is going to potentially impact the economy in a very damaging way. Maybe this is precisely the time to use what resources we have available to us to prevent a descent into a downward spiral. Countercyclical spending in key, targeted, strategic areas might prevent hardship, suffering and a significant slowdown in the economy. Maybe we could look at the areas where there are imbalances, if one likes, or where there is spending that is not contributing in a way that is beneficial to the majority of society or the entirety of the economy. Do the witnesses have any concerns about that potential for a downward spiral, and the need to use the surpluses that we have and so on to prevent a downward spiral? Could the interest rate policy now be contributing towards moving us into a downward spiral?

Mr. Gabriel Makhlouf

I will start and then hand over to Mr. Madouros. The quarterly bulletin we published yesterday does not support the Deputy's conclusion. Notwithstanding the fact that we have shaded growth downwards a bit, the economy is still growing. We are, as we said, at capacity. What we are seeing now is that the capacity constraints are now becoming more binding and it is slowing the economy down. That is what we are forecasting. We have not forecast a recession, or the sort of downward spiral that the Deputy is describing. The picture right now is a bit different.

That does not mean that it constrains the Government’s flexibility to spend on things that it prioritises. There is still much spending that is assumed in our projections and that Government is planning. All we are saying is that because we are at capacity – this is what I have been saying – one needs to be very careful, first, to not exacerbate the problem by spending too much generally and, second, to make sure to spend on the right things, because not doing so could also exacerbate the problem. At this stage, the economy is not in a world where fiscal policy suddenly needs to support the economy to come out of some slow down. Right now, it is not there.

Does Mr. Madouros wish to add something?

Mr. Vasileios Madouros

I wish to add a couple things related to that. There are two ways of thinking about it. One is the aggregate fiscal position and not making, in aggregate, inflationary problems worse. There is then the composition of these decisions – spending as well as revenues. We are talking about the aggregate position and what this might mean for the economy as a whole which, as the Deputy mentioned, in turn, also has distributional consequences. We look at many aggregate measures when we think about macro aggregate policies but we have done much work on, for example, the distributional effects of the inflation shock we have had. Those on lower incomes were particularly hurt in the most recent inflationary shock. We have a lot of distributional works on the savings that have been accumulated across the economy and who is holding them. I just want to make the distinction between the aggregate fiscal stance and the issue around difficult decisions for the Government on spending and revenue, which have a lot more important distributional consequences.

One of the terrible features of the current situation in respect of interest rate hikes - whatever about the Central Bank’s macro objectives, as it were, to prevent overall inflation – is that a huge number of people with mortgages are struggling to keep a roof over their head or, even worse, have had their mortgages handed over to vulture funds. These vulture funds are charging exorbitant interest rates in excess of the ECB rates but are using the ECB interest rate hikes to justify further increases. These people are taking a hit of €3,000, €4,000 or €5,000 a year. Is there anything more that can be done or that the Central Bank can do to prevent that sort of hardship and unfairness? Our view is that we should, certainly when it comes to residential mortgages, impose some sort of interest rate cap because everybody can see that the banks are making a fortune out of this situation but mortgage holders are getting hammered. The witnesses might say that it is not sustainable over the long term, but many things are being done over the short term to deal with this particular crisis. Surely, it would be reasonable to protect a group of people who are getting crucified and getting themselves into bigger debt and more unsustainable positions. I do not know if the witnesses have any comment at all on the particularly nasty, as I would see it, behaviour of these vulture funds and non-bank lenders that are charging absolutely exorbitant rates for no other reason than they can, it seems.

Mr. Gabriel Makhlouf

I will ask Ms Rowland to come in on this. We are very conscious, as I said in my statement, that the cost of living has impacted people and households. The financial system needs to play a role to support people through this. However, I do not think that interest rate caps would help in the end. For one thing, they would get in the way of tackling inflation. Inflation is the harm that we are all trying to fix and it would negate that. In addition, as the Deputy implied in his question, there are longer-term reasons in respect of interest rate caps. We do not have the power to control interest rates but I would not support caps. In the end, it is the financial institutions that need to manage risk and they understand their business and business models. By intervening, we would be taking ownership of that risk management, which would be problematic for everybody. Also, I think-----

We will agree to disagree on that.

Mr. Gabriel Makhlouf

There is probably quite a bit we will agree to disagree around this territory. Second, we talked earlier about competition and attracting new entrants. I do not think having interest rate caps would help to attract competition into this market.

Let us get to the substance of some of the Deputy’s concerns and perhaps Ms Rowland can come in.

Ms Derville Rowland

I will say a bit about some of this. I understand that increases in mortgages really affect people in the choices they have to make. Everyone is trying to run a family, buy food and get kids to school. It places a heavy burden on families. Some of the people who have experienced the highest interest rates are those who hold tracker mortgages because they are more directly experiencing the increase in interest rates that have happened over a very short period of time. With regard to some of the people who might be struggling most, it is not always about the highest interest rate number as regard those most affected, rather, it can be those who have had the biggest shock in moving from an interest rate that was quite low for many years. For people who have trackers, the interest rate may be less than those headline rates that the Deputy talked about but they are actually the ones who need the support most. Last year, many people switched either in their own lender or across the system to avail of more fixed-price mortgages. However, we still have many variable- and tracker rate mortgages in the system and they are the ones who might be experiencing it the most.

The Deputy talked about those customers in the non-bank sector, particularly non-lending. There has been focus on some of the higher rates. I think a group of customers has been identified in the region – the figures change because the interest rates are changing – of between 800 to a little more than 1,000 who might be paying very high rates. When we think about the mortgage market, we want to make sure that people have mortgages they can afford now and into the future. Things are vastly different from the crisis when there were super high loan-to-income ratios of 200%. Now they are down to 90%. This means it is a better story for people because the affordability of their mortgage is better for them.

We hope people in Ireland with a mortgage are better positioned to withstand the shock but we also want people to be able to avail of choice where they can. We think more work can be done for customers in the non-bank and non-lending sector where they could switch mortgages. We think work can be done there. Banking and Payments Federation Ireland, BPFI, has announced measures that we think will help certain groups of customers. It is an important feature that people can get access to better-priced products. That is one feature. Then, when those options are not available, we have the code of conduct on mortgage arrears. From the height of the worst of the crisis in Ireland, where in 2013 to 2015 there were 130,000 to 140,000 mortgages in restructure, those figures, with much focus and many different efforts, have come down. It is important that where people are concerned about their ability to repay their mortgage, they avail of that support.

That is what we are seeing now. Obviously, it is not a first-choice option for a family but it is really important that the option is there and it is used.

This is a big part of the focus of our work, that is, looking at alternative repayment arrangements being made available to help people with mortgages. Some of the non-bank lenders have produced a wider suite of options, such as fixed-term alternative repayment options, which help families to avoid arrears and get back on their feet. We are seeing how early engagement and intervention, temporary measures and better supports can avoid the problem getting bigger. We are vigilant around this. We published data last week that show a levelling off in the figures and a continued decline in long-term mortgage arrears. However, we are concerned about arrears. We will have to remain vigilant, as will the firms. As interest rates go up, families will come under pressure, which makes it even more important that customers reach out to the firms. It is important to understand that both the banks and the non-bank lenders have a wide suite of options. Those options are being used and they are available to customers. People are entitled to that support and it is important that they reach out and take it when they need it. It is not a panacea for the whole of these issues. We do not want to see any family having trouble paying their mortgage. However, where they are in trouble or before they get into trouble, it is important that they can avail of the support. It is one of the most developed approaches in Europe. I am not saying it is perfect but it is important that we know it works, has worked in the past and that it is there for families to avail of when they need it. It is important that they can do so and opt to do so and that we continuously seek to make it work better.

I welcome our guests and thank them for their attendance and the information they have given. I support the points raised earlier by Deputy Doherty on the deficiencies in various housing developments all over the country and the various issues that have arisen in regard to defects. I strongly support the encouragement to bring together all the constituent bodies that might have had, or should have had, an influence during the building stages, including the construction industry, the banks, other lenders, etc. Previously, loans were not available unless certain criteria were followed and there was a certain insurance engagement. The insurance companies have a role to play in this, as do the various professional bodies. Due to what they described as light overseeing, the whole situation took a nosedive and everything was let go. The result was that nothing at all happened to protect the public. In the end, the State had to come in and is offering advice.

There is a shortfall. It should be handled by way of a contribution from those who should have fulfilled their responsibilities at that particular time in order to avert what happened. If those things do not happen, we will be in this state again and will have to visit this position again. As I said before at one of these meetings, I remember having the roofs stripped from a whole block of houses back in the late 1970s or early 1980s on the basis that there were structural defects. Those properties were covered by the house building guarantee scheme, gold bond, HomeBond, premium bond or whatever. What happened in those instances is that when the magnitude of the defects was recognised by the institutions that should have covered those situations at the time, they ran away. They paid a maximum of 30% or something, with the rest having to be borne by the individuals. I strongly support action to address that and I hope the witnesses can encourage it as well.

On the cost of living and mortgages, I realise the difficulty with anybody, whether the members of this committee or otherwise, predicting what will happen and saying a particular approach is the right way to go. I am concerned about the slow reduction in inflation rates. I wonder whether it would have been better to have a short, sharp shock, with a higher interest rate increase earlier, in order that the public would have begun to know what was the target. The answer I was given when I raised this previously was that the public would bank on the target. However, we have to give mortgage borrowers and the public some kind of light at the end of the tunnel. People would say there is no light at the end of the tunnel right now. Interest rates are going up on a regular basis and will continue to go up until such time, as the witnesses said, as that has an effect on the inflation rate. My simple response to this is that we need to watch it carefully. People are worried. If they had an end in sight, they would be better able to plan their households. There is no end in sight at the moment. People are worried and suffering, and they are suffering because of the unknown as much as anything else.

It behoves all in the lending institutions and the Central Bank to steer people in the right direction. I recognise that the Central Bank gives advice, and generally good advice. However, my colleagues from all parties and I can point to issues with some of the advice that was given before the crash. In granting mortgages, the main banks were able to ask customers if they would like the costs of a continental holiday or two to be added onto their mortgage, to be repaid over 30 years or something like that. It was outlandish behaviour and the craziest thing to do to people. Some were offered funding for a new car as well, in anticipation of having to replace it in the coming years, and so on. It went on like that. I am still dealing with people who fell into that trap. We can have all the competition in the world but the reality now is that competition is going downwards and will go backwards. I know who the people were who entered the market and did irreparable damage to the whole concept of banking in this country and then disappeared. However, that is work for another day. To what extent can the witnesses advise us in this regard? They mentioned that politicians have to make political decisions, which is true. We may find ourselves between a rock and a hard place from time to time but we need to have solid advice and clear knowledge as to what we are walking into and what is the best way to go. The public we represent have problems, worries and competing demands at this time, with monthly or weekly increases in the cost of living for a variety of reasons, including interest rates. I have another question on the rates, which I may come back to presently. I would like a response from the witnesses on the advice and direction aspect, if possible.

Mr. Gabriel Makhlouf

Inflation has fallen, is falling-----

Mr. Gabriel Makhlouf

-----and we are projecting it to continue to fall.

Will it happen more quickly?

Mr. Gabriel Makhlouf

It is not happening quickly enough. The rate is still too high; hence the decision we made recently to put up the lending rates again. However, inflation is falling and we are projecting that it will get to just above our target in 2025. As I said to Deputy Doherty earlier, I anticipate that the picture will become a bit clearer in our December projections. What is too hard to do is to say that in this month next year, we will see interest rates start to fall. It would be misleading people if I were to say that today. There is too much uncertainty to say it. However, we have taken action and it is working across the euro area. A big theme of what I said in my statement and what we have been discussing is that monetary policy needs friends. It cannot succeed on its own. It needs fiscal policy to work in the same direction to help us. That is the general message I would give.

For borrowers, especially mortgage holders, who are finding it very hard, my number one piece of advice is to talk to their lender without delay. I would say to people not to let the problem materialise and become bigger.

They should talk to their lender because their lender is obliged to talk to them. Their lender is obliged to find ways to help them. One of the things we learned from the last crisis was too many people hoped that things would get better. Too many people did not talk to their lender early enough and the problem just escalated. That is my number one advice for people who are finding it tough because, as Ms Rowland was saying earlier, there is a toolkit out there to help people in these circumstance but that toolkit can only really be used if the lender and the borrower are engaged and talking to each other.

There is a problem there now. The lender has or seems to have the right to reject what the borrower puts forward. From experience, and my colleagues here around the House have had similar difficulties, if the lender says that is not sustainable, that it cannot do that and that it is not the bank's policy to do that, all of which we have heard previously, that is where the officials in the Central Bank can be a positive influence and encourage them to open up their minds a little to the fact that some people find themselves in a particularly difficult situation. It will not be forever, we hope, but now is the time to do it.

Ms Derville Rowland

Maybe I will come in on that. I completely agree with Deputy Durkan that the lenders need to give the customers who need the support the benefit of the options that are envisaged in the toolkit. There are cases, undoubtedly, where maybe things do not work as well as they should but overall we closely watch and monitor the suite of options that the lenders - the banks and the non-banks - have, whether they are using them, how many they are giving and how they are supporting their customers.

When we look at mortgage arrears, we see, when we look at restructures, many restructures have been put in place. Nearly 62,000 restructures have been put in place. Many of those have come to a successful place where they are fully paying their mortgage with the support. There is much evidence to show that many people have had good support - good options that are helping them perform. Then when we look at the arrears groups, we see there are many restructures there too. We are watching where temporary restructures need to be given to people, particularly in early arrears because sometimes it is a short-term shock. We are watching to make sure that early warning indicators are there from the lenders so they can see stresses coming, that they are proactive and respectful in their communications with borrowers, and that temporary arrangements are being put in quickly. We have seen improvements that need to continue, such as dedicated points of contact between the Money Advice & Budgeting Service, MABS, and different lenders so it is not as complex for people to deal with this, because it is a very stressful time and there is information that has to be passed through. We are making sure that the lenders have staff in place to support people.

It is always true that issues will arise. If the Deputy has any information, we are always willing to take that and look at those issues. However, by and large, we are monitoring the system to make sure that the suite of offers and arrangements are wide and that they being applied, and we see that happening.

I agree that is the way it is supposed to work but, unfortunately, it does not always work that way.

Ms Derville Rowland

I agree with that.

It is the unworkables that I want to target in this particular area. We have all dealt with them, right from the beginning ten years ago. The problem is as great today in some cases as it was ten years ago because, as Ms Rowland must bear in mind, countless proposals were made to the lending institutions at the beginning made up of warehousing parts of the mortgage and the longest possible period of extension. Then one could not get past the late 60s in terms of age to facilitate that. All of a sudden, it is extended, because it suited the lending agencies, to 70 years of age and 80 years of age. One will be 90 years of age before it is paid. I have no problem with that. At least it leaves the person in the house in a position where he or she can work his or her way out of it.

I have two queries relating to investment funds in the property market and how they are affecting the cost of housing. For instance, are they paying the highest possible rates to acquire sites and build housing schemes or how are they regulated? Who is watching over their shoulder to ensure that they are not contributing significantly to house-building and ownership inflation, and finally by inflating the price of the finished product? Is there a possibility that some housing schemes are being held up for different reasons, not all of which are as visible as I would like, and that the customer eventually pays by paying more?

Finally, there are situations where older people find themselves in a very difficult situation now where they have been renting all their lives. There were advertisements in the media, five years ago and ten years ago, but not so many now, whereby one was a renter, one was not investing in bricks and mortar, and this was the cheapest way to go. It was absolutely wrong information. Those people now find themselves facing rapidly increasing rent costs and the local authority does not have the wherewithal to house them. The other group involved in that are the people whose income is too high for the local authority - the local authority will not allocate a house to them - and too low to get a mortgage in the market. Where are they supposed to go? They are going into the high rent that is charged by the investment houses.

Or else they cannot afford it.

They cannot, because they are on a fixed income. We need to deal with that somehow.

I will finish off on the question of moral hazard or whatever they call it nowadays whereby an individual write-down was not available. I and members here have dealt with cases where payments have been made every month for the past 15 or 20 years but, because of the banking crash, they were not able to meet the payments as they were at the beginning. As a result, we are now in a situation where the investment houses concerned made no attempt and refused point blank. Countless propositions were made and they ignored them. They said it was not their policy and it is not sustainable. Of course, they were protecting themselves. They sold them on in some cases. They sold them on at a write-down to another group of companies, which now are rounding on the customer and intimidating the customer on the basis that they have waited long enough. It was created by themselves in the first place. They are now rounding on the customer and putting severe pressure on many of those people. The simple reason for that is that different circumstances have affected different people. Some households have been affected by family illness, some by death, etc. These things all have an effect. It is no good the lending agencies or the investment houses saying they are not concerned about that kind of thing and they want their money. They bought an impaired debt from somebody. All the constituent factors were not included in the purchase either but they want the best factors to apply insofar as they are concerned now at the collection at this stage.

Mr. Vasileios Madouros

I will start with a couple of things, if that is okay, and maybe my colleagues will come in on others.

Maybe I will start with investment funds. There are different types of funds and some investment funds that invest in the property market are regulated by us. The vast majority of-----

Why not all of them?

Mr. Vasileios Madouros

Because some of it could be cross-border. It could be investment funds that are in other parts of Europe and some of it might be another type of vehicle that invests in these properties.

To be absolutely clear, the vast majority of assets of investment funds we supervise and regulate are in the commercial property market rather than the residential property market to which I think the Deputy was referring. Therefore, of the total assets of investment funds that are supervised and regulated by the Central Bank and authorised by us here, I think around 85% of their assets are in commercial property and about 15% are in residential. Now, this is a big change in the nature of financing that we have seen over the past 15 to 20 years. We have seen a growing role of investment funds in the commercial property market in particular. They are a much smaller proportion of residential properties. As the financial system changes, it is also important that the regulatory framework evolves with it. Last year we introduced measures to guard against risks stemming from leverage and also what we call liquidity mismatch in these plans. These are very much from the perspective of how we can ensure this form of financing is resilient at different points in the cycle and is not there in good times and disappears in bad times. It does not get into issues like the Deputy was talking about in terms of impact on pricing or rents, which of course are the much broader social issues rather than being within the mandate of the Central Bank.

The Deputy also talked about people renting for a long time. This also relates to these broader housing challenges we have had in Ireland for a number of years now, this persistent mismatch between the growing demand for housing and the supply of housing. That is an issue that is not just about the overall volume of supply, but the composition of supply also matters, whether it is private, affordable or social. That is also an important consideration. On this, there are a number of factors that have led to housing supply to be more sluggish. It has picked up. We are now at around close to 30,000 a year. Interestingly, we have seen a sharp slowdown in the commercial real estate market recently, partly because of rising interest rates but also because of some of the structural changes like working from home, which means demand for offices has fallen. One of the things we are getting in terms of our engagement as we try to understand what is happening in the economy is that some of the construction labour that might have been used for the construction of commercial property might now also be available for residential property, which can ease some of the significant constraints that are there in terms of housing supply. I will stop here on these issues and maybe colleagues might want to pick up.

Ms Derville Rowland

I will just focus on some of the issues the Deputy raised with customers who are challenged in paying their mortgages, particularly where those loans may have been sold once or more than once. It is true the Central Bank's framework to support consumers who are facing arrears and distress is one of a number of elements in the national framework to support customers. Some of the decisions about write-down go outside of the Central Bank's framework, but we continue to focus on pressing firms to offer workable solutions for their customers. That has been and remains a key focus for us to make sure solutions are delivered. Where we see families with a change in circumstances, where either they have an income fall or where illness or other events arise, firms are expected to talk to their customers to see what can be done to support them. That might mean putting a different type of arrangement in place, one that is more sustainable. Of course, they have a duty to do that, and we expect that they do that.

In terms of communication, this is a really sensitive issue for people, and we have very clear expectations around how they communicate with their customers. They are expected to take a sympathetic approach with their customers. It is not meant to be or allowed to be intimidatory. There are rules around the kind of frequency and approach in terms of letters, etc. Once again, Deputy, I am not foolish enough to think that all systems work perfectly; they do not. However, we act on all information that we receive. We have a team of supervisors. It is their full-time job to look at all the various elements of arrears right across all of the bank, and our consumer protection team gets in touch with the firms. We will always act on any information the Deputy has. If he has particular examples, we welcome them. The team will always act. We have intensive regular firm-level engagement to look at how they are performing and supporting. We take complaints data from their own information. People write to us and tell us. We always act on that. Then, of course, we also engage with all of the lenders right across the system in group situations because there are some problems that need them to work together to solve. We will take it from a number of points of view, so we welcome any feedback.

I said I was not going to intervene anymore. I just want to finish with a last sentence. I finished my mortgage and concluded it successfully in the past couple of years. I paid 19% and 20%. If you missed a payment, you paid a 23% or 24% penalty, so you never got out of that if you missed two or three instalments. However, I borrowed on the basis of the value of the property at the time, which had a certain impact, and we were scared about it. Many other people were in the same category. Now, however, the value of the property is multiples of what it was then. We are talking about a €70,000 property going to €400,000. It can be €270,000 for ordinary people on limited resources. They are the people who are really worried at this stage now, and whatever has to be done to address their situation needs to be done. There has to be some clarity or hpe with regard to when this will end, about the end of or earlier than 2025, or some other means has to be found. We can have graduated supports from mortgage interest relief or whatever solutions, but we have to find a solution because the value of the property and the amount of money lent to buy the property is such now that it wipes out the family income. Every increase is making it worse.

I thank the witnesses for the information they provided and the ongoing assessments they give us. They are useful to us in terms of getting a picture of where things are at. Earlier this year, the Central Bank conducted the impact assessment of the shocked payment impact on the mortgage repayment increase that households would see if they moved from a 3.5% or 4.25 percentage point increase in the key lending rate. Could the bank update those figures? Do the witnesses have an update on those figures for the impact of a shock of 4.5%? I appreciate that they might not have that information here today but perhaps they could provide us with it as soon as possible.

Mr. Vasileios Madouros

Yes. We do not have it today. There are different metrics. There is one that looks at aggregate household mortgage interest payments to income and one that looks at the distribution by, for example, fixed rate or tracker.

Yes, I refer to table 3 and table 4. I will show Mr. Madouros the exact table we want updated.

Mr. Vasileios Madouros

Okay, perfect. We can update that.

We want that table updated because it is really important that we have up-to-date and accurate information on this.

I want to move to the vulture fund situation and to try to clarify where we are in terms of where people are at. At the end of March, more than 80,000 mortgage loans were held by the vulture funds. More than 70,000 of those mortgage holders were on tracker mortgages or variable rates. They have seen significant hikes, as we talked about here previously, of up to 10%, which are completely unsustainable.

Over the summer, the bank provided Deputy Doherty with the distribution of the average interest rates for banks and the non-bank lenders and vulture funds. We might compare March 2022 to March 2023. What is very significant from that table is that the number of people who were paying over 6% for the non-lending firms at the end of March 2022 was 1%. At the end of March 2023, that had risen to 19%, which is a huge increase, which tells us exactly what is going on. Could Mr. Madouros provide an update again on that distribution table for us? There is a real problem there. Again, I will show him the table if he is not sure which table it is. It is table 1.

Mr. Vasileios Madouros

Yes, once we are clear about what that is. Sometimes, the data comes with a bit of a lag so we will make sure of that.

Ms Derville Rowland

I think we have a letter in requesting that, if that is the reference. We are working on that right now. We got new data on the arrears figures that were published only last week and we have to pull information from the statistical perspective and other places to make sure we give the committee correct information that is up to date. We are working on that now and will provide that to the committee.

Will Ms Rowland give me an idea of when we will have that?

Ms Derville Rowland

I do not have a deadline. It is a priority piece of work. As soon as we can.

Mr. Gabriel Makhlouf

As soon as we can. I think it is a general thing. I agree with the Deputy completely. It is important that as much of the data as possible is published so everyone can see what is going on. We are on the case.

On the vulture funds, I want to try to get a figure. One of the most useful things that can be done by the Central Bank and by the banks to help in that situation is to bring back those mortgages from the vulture funds to the retail banks. The witnesses can correct me if I am wrong, but in March 2023, some 22,000 of those that were transferred were never in financial difficulty. Is it true that 22,000 of those that were transferred from the retail banks to the vulture funds were never in financial difficulty?

Mr. Gabriel Makhlouf

I do not know if we know this number or if we have it here, but certainly a proportion of the sales that were made-----

I will tell Mr. Makhlouf because this is from the Central Bank's own data and its own accounts. That were 22,000 that should never have been included and they were transferred without the consent of the homeowners. The Central Bank has stated:

A further approximately 32,000 accounts were classified as having ‘previously experienced’ financial difficulty. These figures represent the upper limit number of ... [non-bank lending] accounts who may be in a position to look for an alternative mortgage provider; however, the aforementioned criteria will be considered for any application to switch.

The figure is 54,000. What I am trying to get at is this. The eligibility criteria include repaying capital and interest in full, which I think is very harsh, the customer's credit history, a clean repayment track record, the customer having a sustainable income, obviously, and no unpaid items such as a direct debit or standing order, and, of course, the loan-to-value being less than 90%. Taking those criteria into account, how many mortgages are in a position to be able to be taken back by the retail banks?

Ms Derville Rowland

We are talking about the possibility of customers switching from the non-lending non-bank sector to other mortgage providers with the idea that they get a better priced product for themselves. I am just saying this so we are on the same page. The concern is that customers have choice, which is an important element in a functioning mortgage market. Switching generally is very low in Ireland. At a high level in the system, we saw it being a bit higher last year because many families could see the writing on the wall and they fixed for a while, where they could, to give themselves certainty. However, switching is generally low.

Nobody can give a 100% precise figure on how many customers will be eligible to switch from the non-lending non-bank sector to other sectors. We now have welcome clarity from the Banking and Payments Federation Ireland, BPFI, announcement on the criteria that a customer would need to meet to be able to switch. Some of those we can tell something about, which is that they would need to have a mortgage that is paying capital and interest and has been performing for two years. We gave the committee a figure of the outside scope of it to be 54,000 in the 4 July letter we wrote to Deputy Doherty. Deputy Conway-Walsh has given some figures. We have been trying to assess what kind of ballpark realistic figure there is, but they are estimates. The estimate we have is theoretical because we still do not know about their personal income and the loan-to-value, which is on a case-by-case basis. The figure we are getting from industry is an approximate one and it certainly could change, but it could be a ballpark of about 27,000 customers, although that is based on those loans fully repaying on capital and interest and having no credit difficulties for two years. There are then the additional criteria, which are loan-to-value and loan-to-income, so we cannot tell and it could be less than that. I am trying to give the Deputy an approximate figure but it could change because we are just looking at getting a fix on that particular area.

That is very useful. How many of those are trackers?

Ms Derville Rowland

I do not have that information precisely to hand in the data but, again, we can try to look at that for the Deputy.

I am coming across another problem for people whose banks shut down, be it Ulster Bank or the other banks that shut down. There can be an unpaid item through absolutely no fault of the customer, and that could be used by a bank to say it cannot accept this because a person has a missed payment, although that can be just in terms of the transfer from one bank to another.

Ms Derville Rowland

Everything is possible but we would not expect banks’ own errors to be a reason for a customer to have an adverse credit decision. More recently, we saw in the media, as I am sure the committee members did, where there were communications to customers with reference to the transfer of loans from one to another. However, no customer paid anything and they were not expected to pay. We expected all of that to be communicated properly and for any direct debits missed, no detriment flows to the customer, particularly when it is, in effect, the lender who has not had its ducks in a row.

Can Ms Rowland say that a person's credit rating will not be impacted because of a non-payment made during the transfer from a bank that was closing to the other bank?

Ms Derville Rowland

No. Maybe my colleague will talk about this. We have the credit register, but while it has information about issues, it does not have scoring. What I can say, though, is that our clear expectation is that where direct debits are missed or issues arise and it is through no fault of the customer, and it is the lender who has not done the execution of the transaction properly, we expect them to deal with that and fix that, and we do not expect customers to be fixed with detriment. If the Deputy wants to give us information about that happening, we will follow it through.

I will tell Ms Rowland of an incident. Sometimes when we talk about things here, they are far removed from what people are experiencing. Somebody misses their monthly mortgage payment of €375 because of the transfer over to the bank. This is a vulnerable customer. They go into the bank concerned and offer the €375 but the bank says they cannot accept it and it has to be done through the mortgage. I was very interested to hear what Ms Rowland said in terms of the frequency and the rules around that because they called her twice every day at 9.30 a.m. and 4.30 p.m. until last Thursday and they sent dozens of letters. This was a vulnerable customer who then stopped opening the letters. “Communication” is a very wide word in terms of the banks’ communications and their frequency. To me, that is an appalling way to treat somebody for €375.

I went into the bank with the person because I was concerned about any future credit rating if that person wanted to sell their home or whatever and avail of credit. The bank said that the information on the monthly missed payments would be sent to the credit reference agency, that the bank had no control over that whatsoever and the missed payments would be held against the person for five years. How can that be right for €375 in a switching situation for a vulnerable customer?

Ms Derville Rowland

I am very happy to say that I would like to get to the bottom of that if the Deputy could write to us with the information concerning a transfer, what was missed, the person's attempt to pay it, etc., to unravel the case.

Ms Derville Rowland

As I said to the other members, we have a team of people and this is their job. We look at the approaches. We look at individual examples and the system approach. We would be very happy to look at the case if the Deputy could, with the support of her constituent, supply the details.

Ms Derville Rowland

Perhaps Mr. Madouros wants to add things about the credit register, which is a separate issue.

I want the Central Bank to understand what is happening because it may not be aware that people are falling through the net, particularly vulnerable customers.

Mr. Vasileios Madouros

I agree with Ms Rowland that it would be useful to follow up on this matter.

On how the system is meant to operate in terms of the Central Credit Register, as Ms Rowland said, the register does not produce credit scores but factual information. Operational things happen sometimes so there is already, I think, one month's grace period where a missed payment is not recorded. With the transfers last year, we engaged with lenders. We made it very clear that if a politician or a customer says that something is happening because of transfers, then once that has been sorted out, it should not be recorded in the Central Credit Register.

Can the delegation see the power imbalance? The switching criteria stipulates that, "Customers must have a satisfactory bank account performance i.e. no unpaid items such as a direct debit or standing order". It does not qualify that in any way so all of the power is given to the individual bank, so there is an imbalance. There is an asymmetry of information in the first instance and there is a power imbalance with the consumers. Therefore, is it any wonder we have a low switching rate?

Mr. Gabriel Makhlouf

The more we know of the actual case, and any other cases that any of the members have like that, then the easier it will be for us to address the matter. What Deputy Conway-Walsh has described is not an acceptable situation.

Yes, and it is not about the one individual. It is about changing the system.

Mr. Gabriel Makhlouf

Yes.

We do not know how many more people have letters that they are fearful of opening because of this frequency of contacting people.

On that point, I want to discuss pyrite. As Ms Rowland will know, the pyrite issue is huge in County Mayo and is the same as the mica issue in County Donegal. Can Ms Rowland say here today, notwithstanding what the BPFI will announce tomorrow, that all impacted homeowners, without exception, should be dealt with in conjunction with the vulnerable client process? How can the Central Bank ensure that all homeowners are treated as a cohort of vulnerable customers, bearing in mind that there are other things that need to be answered this way?

Ms Derville Rowland

I will be perfectly straightforward with the Deputy. I do not necessarily think treating these customers as a vulnerable customer is going to help them necessarily get to where they need to get to. I am certainly very sympathetic, in that any of us could be vulnerable at different points of our life, such as following a bereavement or due to stress or health issues, and some of that could be permanent or temporary. It is not that I am against treating these customers as vulnerable customers and offering them additional supports but I think something else is going on. This is a special category of cases outside of everybody's control. It is so exceptional that a national support scheme has been put in place, recognising the injury to these people and their homes by pyrite and-or mica. I think there are about 7,500 family homes affected and a national scheme has been put in place. That, of itself, is exceptional recognition of the situation in which people find themselves. It is easy to say, by definition, these customers are very vulnerable because there is a national scheme of support.

Having listened to the team who met some of the representatives of the scheme, a myriad of issues need to be dealt with together to give people consistency of approach and answers. A consistent solution is needed to make the scheme work for them and flow. Many people will have mortgages with different institutions with slightly different terms and conditions, and there needs to be an ability for each institution to see and interpret them differently, even sympathetically. The same is needed with insurance contracts and maybe some of the other things. It is a bit of cheeky of me to say so but I think what people need is one place to go and ask, "Can we get a line on the mortgage interpretation?" That would standardise the process for everybody and people would not have to go to different places in terms of insurance and lending and the approach. That would mean people could see how the scheme worked, look at the gaps where it was not working so well and get one set of solutions to support the effectiveness of the scheme and not hear different things from different institutional providers.

How quickly does Ms Rowland think that can be put in place?

Ms Derville Rowland

Strictly speaking, this is outside of the framework of financial services. I have made an observation. I refer to making the scheme work. There are a load of things coming up, and I do not like to refer to it but the tracker mortgages reminded me of some of this. There is a lot going on so you have to gather it together for people. You need to figure out common questions and answers and a common approach to try to solve problems in a consistent way and then deal with things one by one where they fall into the exceptions. That is just my view. Again, it is not a Central Bank view. It is just an observation that I have made through trying to fix things sometimes. I think that would be helpful to people because they are upset and frustrated, and financial systems, contracts and insurance are complicated. This is their home and these people need help. I really am very sympathetic to that.

I understand and appreciate that. This issue is time sensitive because many people have lodged applications. We do not want people to be locked out because of, say, their age, and be refused loans and finance purely based on this.

Ms Derville Rowland

I know the BPFI is going to marshal itself. We have also talked to Insurance Ireland and suggested that it proactively provides support. I think it would help people to have it all together, so they do not have to go to lots of different places.

Yes, and it would help to have somebody to talk to.

Ms Derville Rowland

Who could solve it.

We need a place for people to go and talk to a person who can solve issues and be consistent.

Ms Derville Rowland

With the parties in the room who can take a joint approach.

Yes. I will leave my questions at that. We would appreciate the updated information and I will supply the tables.

Ms Derville Rowland

Thank you.

Can I ask about the transferred Ulster Bank accounts that eventually ended up with NatWest? This issue is not on the agenda but I have read about it in the Financial Times and other publications. I am watching what is going on in the UK and the allegations that are being made regarding the Ulster Bank launching, potentially, enormous liabilities against SMEs, some of which are in Northern Ireland and in southern Ireland. Some of these allegations have come from a former head of capital at the Royal Bank of Scotland, RBS, and these accounts ended up in its global restructuring group, GRG. Has the Central Bank got sight of the issue? Is the Central Bank concerned about the Irish customers within those banks? Has the Central Bank sought information on the matter and how will it proceed?

Ms Derville Rowland

I do not have up to date information on the matter. We discussed this matter a number of years ago with this committee. I refer to the Ulster Bank's GRG issue where an external independent review was commissioned in the UK. The approach in Ireland was also looked at. For customers who were in scope, a scheme was set up and the matter was addressed. I certainly recall discussing this issue with the committee. I just do not have precise up to date information on the case but it was a matter that was a supervisory concern to us.

We looked at the UK report, the approach that was taken, the scope and any issues of concern that arose, whether those issues arose in Ireland, and how customers were dealt with. A scheme, together with an opportunity for complaints to be made, was put in place and overseen. I am happy to provide the committee with up-to-date information in writing.

If we look at what is being reported now in a number of publications in terms of what the whistleblowers have said and what the UK has outlined, I think it is a whole new complaint.

Ms Derville Rowland

Yes.

Perhaps the Central Bank would come back to us on that.

Ms Derville Rowland

I am happy to take it away, but I can say from memory that the issues that were present in the UK were not found to be present here.

No, that was back then.

Ms Derville Rowland

That was back in the original issue. I am very happy to come back to the committee with an update on it.

As I said, they are looking at an inquiry now. They mentioned the UK, the accounts in Northern Ireland and the southern Irish accounts. I would like to get an update on it because it would appear that there is a difference in what happened before and what is going on now.

Ms Derville Rowland

I would be happy to do that.

On many occasions, I have raised the issue of tied agents and AIB. I also want to raise that in the context of the Belfry investments. We had a meeting where evidence was given in relation to Belfry. It was held in private session and a whistleblower was involved. We decided to pursue the matter after we had heard the detail on the Belfry investments, including how many there actually are, how many customers were involved and whether they should get paid. The bank resisted and eventually, I presume because of the threat of public hearings before this committee, it agreed to pay some of the Belfry investors, refund them their money and compensation and so on. Has the Central Bank examined the two issues, namely, the Belfry investment funds and EBS tied agent issue? Both are an example of bad practice, which in the case of EBS continued over a 12 and a half year period. What is the Central Bank's role in both of those issues? Both would seem to be wrongdoing by the banks. As a regulator, what is the Central Bank's view on them, and what action can it take?

Ms Derville Rowland

I will deal with the EBS tied agent issue by saying that I know that that matter has been previously raised by the Cathaoirleach on a number of occasions and has been the subject of correspondence and discussion with the bank. I am happy to come back to the committee on that. I can say more, precisely, on the Belfry issue.

Ms Rowland said she will come back to us on the EBS issue. What is the Central Bank's role in that? There is potential exposure there for EBS in respect of the tied agents. Does the bank have to report it to the Central Bank? Can the Central Bank ask questions of the bank regarding why it has taken 12 and a half years? Yes, the Central Bank can come back to the committee with the relevant information, but as a guideline for me, what is the role of the Central Bank in that issue?

Ms Derville Rowland

I do not have to hand all the details around what the issue is with the tied agents, because a myriad of issues were raised. I believe litigation was raised with businesses and there were other issues as well. Because I want to be precise and accurate with the information I provide, I want the opportunity to go back and refresh the information to give it to the committee in an accurate format. I know there was litigation involved, so there are a number of issues from different perspectives. I simply want the chance to be precise.

That is fine. There was litigation involved but mediation was also put in place. Now, instead of that mediation bringing closure to it for the EBS tied agents, it seems to have stalled. Depending on which side you speak to, you get a different view on that mediation.

Ms Derville Rowland

Yes.

I will wait for the Central Bank to come back to committee, but surely to God, the regulator has some sight of what is going on here. I ask it to bring us up to date with what is actually going on.

Mr. Gabriel Makhlouf

To use the Cathaoirleach's words, we have some sight of what is going on. Like Ms Rowland, I am not completely up-to-date on this. What I can say is that for quite a period, I was hearing quite a lot about it and I have not heard a lot about it for a while. We will come back to the committee.

It has not gone away and it is getting worse.

Mr. Gabriel Makhlouf

We will come back to the committee.

What about the Belfry investments then?

Ms Derville Rowland

On the Belfry investments, as I am sure the Cathaoirleach will be aware, various tranches of investments were sold and at the time, there were limited regulatory requirements in place. That is going back quite a number of years. There was also litigation in that case and an outcome where AIB was found liable to some of the customers. Of course, with this committee and others, a scheme was set up to deal with all of the customers, not just those involved in the litigation. We were engaged with AIB from a consumer or retail investor participation point of view. Straightforwardly, I will say that because of the passage of time, we did not have the power to compel AIB to set up a redress scheme. We used our view that consumer-centric approach should be put in place and we had detailed supervisory engagement in terms of the fact that the characteristics of an approach should be fair. We used some of the experience from the tracker mortgage examination in the characteristics of a redress scheme. In effect, three categories were determined by the bank, which seemed fair to us, for unsuitable sales, suitable sales with errors and suitable sales. We challenged the bank on the categorisation and some of its approaches. We had extensive engagement with AIB behind the scenes to try to make sure that the design and the execution was as fair as possible to the customers, but the decisions-----

However, of course, not all of the Belfry investments have been covered. There are various schemes, including Belfry 1, 2, 3, 4 and 5. My understanding is that the bank has not covered all of the investments. I want to know what the Central Bank can do about that. Was it not surprised, now that we know that it had that sort of insight into the issue, that there were no documents? The documents had vanished.

Ms Derville Rowland

Well, there are a couple issues going on. There were documents in some cases and not in others.

In quite a large number of cases-----

Ms Derville Rowland

That is one of the issues that we took issue on. There are two ways to read a lack of documentation. It could be read that generally speaking, things would have been done fine, but actually, that was one of the areas that we challenged on. We said that in the absence of any documentation, the customer should have the benefit of that absence, that is, the benefit of the doubt should go to the customer where the bank cannot demonstrate that the sale was suitable. The Cathaoirleach asked if we were not surprised. Sometimes I am not surprised with the lack of documentation, particularly when we are going back to investments that were made in 2002 to 2006. I am not saying it is right, but having the unfortunate role of investigating banks out of the legacy period, it has been the case that-----

Is it not shocking when a bank-----

Ms Derville Rowland

-----they do not have document retention requirements and it does happen.

I cannot believe you are saying that. Documents are meant to be retained, particularly by a big bank like that. My understanding is that it claimed there was no documentation for a vast number of these cases, particularly a document that would refer to the compatibility of this particular product for the individual it was dealing with, yet the whistleblower had all the documents. I just think it is unbelievable. It raises the question, therefore, as to how much information the Central Bank is given or how much information it can beat out of these banks using the muscle that it has when it goes into them.

We get the line that there are no documents, but we are going to settle everything anyway. It shows that the employees of the bank are put into a position whereby they have to tick boxes qualifying these investors, but they knew damn well that they were not informing the investors. When we investigated, lo and behold the documents were not available. They settled a lot of those cases, as I understand it, and there are still cases outstanding. If the banks had changed their culture and approach, one would imagine that regarding Belfry and the EBS tied agent issue, things would be upfront. If they had any figure in the Central Bank, they would be upfront and show the bank what was happening.

Ms Derville Rowland

A lot of various issues were raised. On Belfry and the document issue, it should have its documents. I am not going to stand apologetically for banks when they do not come up to scratch. That is a matter for them. We have rigorous expectations around this. This is a matter going back to before the consumer protection code was in place, arising from 2002 to 2006. That will be a matter for the institution in terms of documents arising from that period.

What I am clear about is that when we engaged with the banks we were perfectly clear that we expected them to produce the documentation and, where they did not, the customer gets the benefit of the doubt on that. We are clear that where there were issues about knowing a client or assessments were not there, the customer got the benefit of that. That is one of the areas that we focused on because unless banks could demonstrate the suitability of the sale and did not have the documents to demonstrate that, one of the approaches in the redress scheme was to say that where they could not demonstrate that, the way they should look at the categorisation for the client was to the benefit of the client.

I do not know about the information you received in private session from the person you are calling a whistleblower. I do not know what documentation the person brought to you, nor could I know. I am very happy, as I said, because the team engaged extensively on this. Even though it was outside of our powers and role, because we take our view of treating the customer and retail investors seriously we were demanding on this. I am very happy that if you have concerns around scope or anything else for you to provide that information to us. As part of our engagement, we can consider that.

I am concerned about the balance of the Belfry investors and how they will be dealt with. I am concerned about the EBS. Ms Rowland can come back to us on both of those.

Ms Derville Rowland

If you could tell me the particular concern on the Belfry investor I am very happy to-----

Lack of paperwork.

Ms Derville Rowland

You also said there was a scope issue. I think you-----

Yes, in terms of whether the person making the investment was fully informed, the investment was compatible with his finances and was given the knowledge around the investment itself.

Ms Derville Rowland

Yes, I am in complete agreement with you. The categories in the redress scheme include compensation and a full refund for customers where there was an unsuitable sale. That is the first category in the redress scheme. We are in full agreement that where a sale was unsuitable, banks have promised to give customers a full refund of the investment including time value of money.

We will await your update.

Ms Derville Rowland

Thank you.

I refer to the sale of loans to vulture funds. In the case of the sale of a loan to a vulture fund, all of the paperwork and commitments regarding it goes to the vulture fund. If there is a decision in court that legal fees should be paid by the bank that sold the product, is it the bank or the vulture fund who pays? I presume it is the bank. The evidence I have is that in a number of cases the same bank has refused to honour its commitments to a customer, some arising from a court case. The bank has said the vulture fund is responsible. Substantial money is involved and the customer is again pushed out to try to have a fight with the bank. Of course, all a bank has to do nowadays is stonewall the customer, in particular if it is no longer operating in this jurisdiction. In a case like that, what role does the Central Bank play in ensuring that a bank that sold loans honours the obligations it had when it had the loan?

Mr. Gabriel Makhlouf

I will come back to you on that because it is only last night that I was made aware of an issue. I think it is the one you have described. I do not know enough to answer you now. One of my answers would be that it depends on the contract between the bank and the fund that it sold it to.

The court decided this. The original bank-----

Mr. Gabriel Makhlouf

We are now speculating. That is what I would have said. That is another one to take away and come back to the Cathaoirleach on.

Has the Central Bank received many complaints from customers of banks who had their loans sold to vulture funds regarding how they are or have been treated? If they wrote to the Central Bank, how would it deal with those complaints? Does it register the number of complaints?

Mr. Gabriel Makhlouf

Complaints about?

Vulture funds.

Ms Derville Rowland

I can come back and we can give the Cathaoirleach more precise information. We would look at complaints about the non-bank sector from two points of view. One is anyone who contacts the Central Bank directly or through his or her representatives. We record that and bring it into the supervisory teams. We look at those issues.

We also inspect and meet firms. We then examine their data about what their customers are complaining about directly to them. We also monitor social media, for example, to see what people might be saying online about behaviours or practices. We get other feeds that give us our intelligence around issues in the system and risks. If people tell us something directly, we take that into account. We will give you some information about that. We get information from people such as committee members who are in a position to talk to an awful lot of people and can hear intelligence or commentary. We particularly expect the firms themselves to look at their own complaints data. We look at that for trend analysis and bring it together at system and firm level. We have myriad levels of information that we gather. Through other connections with society, we will listen and take all of that into account. There are multiple ways for us to hear intelligence.

I attended a meeting of the Irish Banking Culture Board last week. I was shocked to hear Padraic Kissane tell me that some of the harrowing cases we heard at this committee at the very beginning of the tracker mortgage issue had still not been resolved. I know the Central Bank does not deal with individual cases. He was not dealing with individual cases, but the day they came before us people poured out their life stories to us. The level of information they put out about themselves and the difficulties they had took everyone in the committee by surprise. We could not help but be moved by the stories they told of the experiences they had with banks, how that affected their lives, how they lost everything, how they lost homes and so on.

For Mr. Kissane, who was the one we were dealing with and they were his clients, to tell us that cases have not yet been resolved shows us how bad the banks are about dealing with some of these cases. Is there no urgency that the Central Bank can bring to banks regarding issues going back 12 and half years in the EBS or the tracker mortgage issue and the destruction of a person's life and well-being?

Still, they are not resolved. How many more tracker mortgages have to be dealt with?

Ms Derville Rowland

From a Central Bank point of view, I am concerned to hear that any of those cases has not been dealt with. Part of our approach has been to ensure that: customers were identified; remediation and compensation were paid; the appeals procedures that were available to people were working; and the money was being handed over to customers. I recognise there are cases being dealt with by the Financial Services Ombudsman that fell and fall outside of the scope of tracker mortgage redress. However, we have been active and vigilant about making sure that people got their dues. I am not saying that it would make good the harm that was done, but I would like specific details around that because we have been vigilant to follow through. As the Cathaoirleach knows, a vast number of customers were identified and have received their money. I remember following up on the cases of the people who came before this committee because it was totally unsatisfactory that they not only had the experience but then came and shared the sensitive details of their lives in public and they had not been remediated. If these cases are in a different system, such as the ombudsman system, I will have no direct ability to deal with that. However, if they are in the tracker mortgage examination, I will find that very unsatisfactory and deal with it as a priority.

Could Ms Rowland tell the committee how many unresolved cases there are with respect to each of the banks? Does she know that figure? Does she know the figure of the cases still being dealt with by the ombudsman?

Ms Derville Rowland

I am certain that €744 million has been paid out to 42,000 customers to date.

I am referring to the ones who have not been dealt with.

Ms Derville Rowland

I believe, as far as I am concerned, they all have been paid to date. There are 38 unresolved complaints in the system. Before the ombudsman, 2,713 cases have been lodged, with 1,101 yet to be decided – this just information that I have. There are 200 active cases still before the courts. A number of cases have been rejected before the ombudsman. They will be able to give their own figures in more detail. This is an area where we have been vigilant in following through.

How many are in each of the banks?

Ms Derville Rowland

I do not have a breakdown but I would expect that most of-----

The witnesses can give us those figures.

Mr. Gabriel Makhlouf

I refer to one of the cases the Cathaoirleach described as unresolved. Was it in the courts or with the ombudsman? Did he-----

I will come back to Mr. Makhlouf on that.

Ms Derville Rowland

I am happy to come back to the Cathaoirleach, but redress and compensation is yet to be completed in 155 accounts because most of those customers cannot be contacted. There may be a small number of newly identified customers. However, under no circumstances do I expect cases that are long in scrutiny to be unresolved in the system that the Central Bank is responsible for. We track this in great detail.

So the witnesses will come back to me with the numbers in each of the banks.

Mr. Gabriel Makhlouf

We will come back to the Cathaoirleach with what we know.

Ms Derville Rowland

Could the Cathaoirleach please tell me the information he has so we can square it off because that situation would be very unsatisfactory?

Yes, I will. Mr. Makhlouf wrote to the committee arising from an issue I raised with the Central Bank about accounting standards. Are the witnesses satisfied that these standards are being met? Sorry, are they satisfied that the accountancy bodies are ensuring that their members are using the standards and regulations set down by the European Union and they are not being advised to do otherwise? This is the letter from 9 June. A long time before that, I asked the witnesses to reply to an article in The Irish Times or the Financial Times on the non-compliance, if you like, of banks relative to EU regulations.

Mr. Gabriel Makhlouf

My letter indicated that we were satisfied. But clearly-----

Mr. Makhlouf was satisfied then. I am asking whether he is satisfied now that there is no evidence that the accountancy firms are giving advice contrary to European regulations.

Mr. Gabriel Makhlouf

I am not aware of any evidence that would make me not satisfied. I will double-check whether there is anything. However, I have seen nothing that would change my letter to the Cathaoirleach.

But Mr. Makhlouf will check?

Mr. Gabriel Makhlouf

I will check.

Because this is a recent complaint that I have received.

Mr. Gabriel Makhlouf

Could the Cathaoirleach share that complaint with us?

Mr. Gabriel Makhlouf

That would be good. Thank you.

Pepper has 80,000 mortgages. It is one of the biggest mortgage holders of private houses. We are told there is a wide range of options on offer from the vulture funds to deal with issues of the customer not being able to pay. However, my information – again, I can send the witnesses individual cases – is that they are still being treated badly. Some of the range of options are not compatible with the clients’ profile and ability to repay or to pay. Getting a problem resolved with any of these vulture funds is very difficult for a customer and even more difficult for the likes of me. It can also be said that they will just not come before the committee. Who will take control of them and regulate them? Who will stand up for the customers they continue to harass? From the cases I have seen, it is harassment. Turning to the Central Bank, if its officials say they do not have the remit to do that, do they suggest to the Government at any time what legislation it might pass to give the Central Bank the authority to deal more significantly with the vulture funds?

One of the key issues that emerged in our hearings with Money Advice & Budgeting Service, MABS, and Free Legal Advice Centres, FLAC, and so on was the difficulty consumers have in engaging with the investment funds. I am not just saying it from hearsay. They are saying it from their engagement with their customers. They told us at committee that that was the experience.

Ms Derville Rowland

There are a couple things in what the Cathaoirleach said. First, it is true that customers were experiencing difficulty engaging with some of their lenders. Some of the reasons are that it is a very stressful time and administratively they did not know who to talk to. Therefore, it is welcome that the approach developed with MABS, rolled out and promoted by the BPFI, is there with named people to engage with. Somebody in MABS, for example, can phone a named person in one of the non-bank lenders, or any lender, to be able to advocate on behalf of somebody. They know who to talk to so they are not chasing around different people to find information. That is very helpful. We have powers to deal with any information the Cathaoirleach has about harassment. We are very clear on our expectations. If the Cathaoirleach gives us specific information, we follow through. I welcome that information.

As for appearances before this committee, we have been clear over a number of years about the dissatisfaction of the non-bank lenders not appearing before this committee. The committee has asked us to communicate that to them and we have. Just a few weeks ago, I was at a meeting with the Minister for Finance with all of the lenders – banks and non-banks – where he made very clear his expectation that everybody should attend before the Oireachtas committees when invited to do so. I heard him tell them that; he said it loud and clear. We support that message as well.

That is a little outside of our direct power but there are things within our powers. Definitely within our powers is any behaviour that amounts to harassment or inappropriate communication with people. We definitely can take action and welcome information.

Does the Central Bank get individual complaints regarding vulture funds? I think I asked Ms Rowland this already.

Ms Derville Rowland

You did. You asked me that and I said we did. I also outlined the myriad of sources of complaint, and risk and data information we take to inform our work so we can look closely at behaviour and take effective action where that is needed.

I am sure the members would agree that we should contact the vulture funds again on foot of what the Minister for Finance has told them, issue the invitation and see would they come before us. That might be a way.

Or we could just take their licence off them if they do not agree to appear before democratically elected members?

I mention two other things. On the bank IT glitches, are the systems robust enough now to withstand further IT glitches?

Ms Derville Rowland

A key area of concern for us as regulators is the resilience of the banking system, and its IT infrastructure has been, is, and will be, of critical importance more and more with digitalisation. The Single Supervisory Mechanism, SSM, the prudential regulatory authority, is a key priority focus and we certainly think the Irish banking system has considerable work to do to make continued need for progress in this area. Recent events have come up through a number of banks. There is more work to be done. It is not at the standard we expect. There were consumer-facing issues and clearly they should not have happened. Customers are entitled to expect continuous reliable service, but it is also fair to say that millions of transactions a day happen in Ireland in the banking system with no problems arising. We want to have confidence in our banking system to work for us but more work is to be done. In Europe, there is a continued and ever-increasing focus on this with more regulation with the Digital Operational Resilience Act, DORA. It is a new area of focus because all big businesses run on their IT systems and most businesses interact with their customers in a digital interface. It is more and more important.

Does that include hacking?

Ms Derville Rowland

Certainly cyber resilience and resistance to hacking is a key part of that and, because of the way the world has moved, it is an increased threat, not just in the banking sector but in all sectors. Of course it is a key area of priority. The Governor or Mr. Madouros may want to add to that. It is a huge issue.

Mr. Vasileios Madouros

Cyber is a major area of focus across the board indeed.

The last matter I want to bring to the witnesses' attention-----

Mr. Gabriel Makhlouf

I have a small point to add to what Ms Rowland just said, which is that we in the Central Bank are playing a pan-European role in this digital operational resilience work. It is important to us and to the whole regulatory community.

The last issue I want to mention to the witnesses is the politically exposed person, PEP. The committee has just completed a report, which will be published later, on the PEPs issue. Deputies are subjected to it, as are the staff in our offices, and then on to family members and extended family members and so on. As soon as banks hear you are a public representative, it is like it is a dirty word. Suddenly, you have another 20 pages to fill out. Are all of the banks, credit unions and so on acting on what the Central Bank has asked them to do relative to PEPs? Has the Central Bank set out exactly who these people are in PEPs and what needs to be done regarding a politically exposed person?

Mr. Gabriel Makhlouf

I point out that I am one of these as well.

I know that, yes.

Ms Derville Rowland

This is legislation coming from Europe and to Government level, and the guidelines around this are issued by the Department of Justice. Regarding the rule framework, we are a very important overseer of effective integrity controls for the financial system to prevent the proceeds of crime and financial crime. However, the legislation is devised at the European Commission and at Government level and then there are the guidelines. We have a lot to say about how it is operated but those in prominent public functions and the PEP legislation comes from there. We do not set all of the rules but of course we look at the effectiveness of controls and approaches of lenders. We have an influence in frequency of testing, etc., but the rule framework is set separately.

Therefore, the Central Bank is just overseeing what someone else has written. Is that right? Is that fair to say?

Ms Derville Rowland

We do not write the PEP framework. The Central Bank is a key player in a lot of ways but we do not write the legislation.

Does Ms Rowland think that the general purpose of PEPs should be extended to all citizens of the country?

Ms Derville Rowland

I have a view on that. I do not think so because it is not effective. Money laundering and every kind of system is a risk-based system, so it would not make sense to dissipate resources everywhere because we cannot do everything well all at once. A more target risk-based approach makes sense in a lot of walks of life, including this.

Mr. Gabriel Makhlouf

If you look at it in a slightly different way, it applies to the whole country in the sense that financial institutions - banks - need to apply "know your customer" rules. At one level, what the PEP rules are is just a heightened version of rules that apply to everybody.

Did the Cathaoirleach say there is a report coming from this committee?

I am just finishing a report from the committee, yes.

Mr. Gabriel Makhlouf

We look forward to reading it.

I have a very quick question. The Central Bank's quarterly report, which I always find a very useful document, contains something I have asked about, that is, the net household wealth figures, which I have a particular interest in. We all should have an interest in them. There was a good article on the evolution of the net household wealth. I think it was written by Paul somebody, a member of the Central Bank staff. I cannot find it now because my computer is locked up. The article showed the evolution in terms of the amount of information you get about the distribution of net household wealth. It showed staggering increases in net household wealth now based on the household finance and consumption survey, HFCS, and the distribution of that, which again to my mind is jaw-dropping that the top 10% have 54% of the wealth and the bottom 50% have 10% of the wealth. This is very interesting information. One of the things I ask for, if it were possible to further break that down, is whether we can look at the make-up of the different groups. What the article and the information provided by the Central Bank so far states that the top 5% have this much, the top 10% have this much, the middle 40% have this much, and the bottom 50% have this much. It is a kind of an upside-down pyramid, which is interesting and shocking. However, there is also then a debate about what it is made up of within those categories.

Mr. Gabriel Makhlouf

The type of wealth?

The type of wealth, yes. It does that for the overall figure. The article states that for a particular year there is a certain amount of property wealth, business assets, deposits, other financial assets, and this much debt or whatever.

It would be useful, however, to see that breakdown applied to-----

Mr. Gabriel Makhlouf

The deciles.

Exactly. It is relevant to some debates being had.

Mr. Gabriel Makhlouf

If we can do that, we will.

It would be helpful. That information may be already in the hands of the people who wrote the article.

Mr. Vasileios Madouros

We will take that away, and if that is feasible we will do it. There might be issues with some surveys and, once they are broken down into particular bits, how small the sample size becomes and how reliable it is. We will take that away. If it is possible, we can-----

Yes. Directly related to that, the article stated that it is now becoming easier to understand and scrutinise this information because of distributional wealth accounts. There were Central Bank and European Central Bank sources. I did not quite understand what distributional wealth accounts were, why that made it easier or where they get this information. Any further notes or information on where they are getting all this stuff from or what exactly a distributional wealth account is would be very interesting and helpful.

I call Deputy Durkan.

I thank our visitors for the useful information they have given us and assure them of a steady stream of communications from the Members of the Houses who have been dealing with these situations with a lot of frustration for a long number of years. It should be remembered we have had situations in which financial houses have appeared on the doorsteps of widows when they came home from work to put the pressure on them. Now there is a continuation of that in that where the loans were sold on, receivership is used regularly to intimidate the customer further, and the bank or the receiver now appears almost daily to harass anybody living in the house at the time. I am therefore glad to hear the witnesses say they have instruments to deal with that kind of situation.

The last point I will make has been raised by the Chairman, namely. politically exposed people. I do not know where the politically exposed politicians are. I know this legislation emerged in Italy, where a politician was facilitating money laundering. To do that, the person has to be in a position where there is a considerable cash flow. Cash flow is the secret. We know where those people operate and how they operate, but I cannot for the life of me understand how they expect politicians to be used in a cash flow situation because we are very strictly - and correctly - monitored as to what we can and cannot do, as is the entire family.

It was all done in Conway's pub at the top of O'Connell Street, was it not?

I do not know whether or not it was, but there are a lot of other pubs around the place. The cash flow is the issue. I am surprised that the regulatory institutions have not zoomed in on them to the same extent. All our salaries are paid by the State and accounted for - they have to be accounted for - and the Revenue Commissioners have been very quick to tell us when suddenly we get money and to ask where it has come from. They do that, and rightly so. The point about it is that I resent the harassment we have to go through in our own office, with members of staff and so on having to account for themselves and various allegations, while it is pretended we have information. If you have information, let us have ye, but it is another thing to be guilty by association or something like that. There is a way to deal with that too.

I thank the witnesses for their appearance and for their frank exchange on the many issues we have. We went on a bit longer than usual, but it is our first day back and we are full of enthusiasm. That will wane over time.

Ms Derville Rowland

We have been back five weeks.

Ms Derville Rowland

We are still enthusiastic.

The joint committee adjourned at 5.05 p.m. until 1.30 p.m. on Wednesday, 27 October 2023.
Top
Share