We should probably pose the question, ‘Why haven’t the Central Bank dealt with any complaints about abuses of the Code of Conduct on Mortgage Arrears?’.

The answer is the blog topic. The Central Bank are a regulator, not a receiver of and adjudicator of complaints.

The Central Bank do have a sanction regime, but it is mainly regarding that of regulation from the perspective of qualifying for regulation, for complaints about the CCMA the most appropriate authority is the Financial Services Ombudsman.

And they have been dealing with mortgage complaints for quite some time, they even have a category for it in their reports.

Not only that, their own chairperson notes (see page 11) that mortgage related complaints were a massive 50% of the complaints received! And in many cases the complaints are partially substantiated and a lower number fully substantiated.

In general complaints are down, complaints received for 2014 were 4,477, a decrease overall of 42% year on year.

This is encouraging as it means more complaints are being dealt with prior to being elevated to the FSO for adjudication.

What is slightly misleading (but not un-typical of commentary in Ireland) is where people start complaining that the Central Bank who don’t oversee said complaints ‘aren’t doing anything about it’, it would be akin to complaining that the department of social protection are not stopping crime.