I'm not disputing the factual position – I really couldn't have any clearer on that point.
If I take out a loan to purchase a premises from which I intend to operate my business that is clearly not a BTL (buy to let) loan. I'm not buying the property with a view to letting it to anybody.
No, I didn't. I really couldn't have been clearer on that point -Yes you did!
For the avoidance of any doubt, I am not disputing that as a matter of fact that commercial mortgages are being treated as being in scope.
So the answer to Dan's original question is that loans secured on non-residential property are out of scope. Right?CBI have clarified that commercial loans (whether mortgage or not) are in scope where the loan is secured against a home
That is my understanding. Unless CBI have changed their mind since the letter dated 22 Dec 2015.So the answer to Dan's original question is that loans secured on non-residential property are out of scope. Right?
No, I didn't. I really couldn't have been clearer on that point -
No Ides, I didn't. However, I would like to thank you for the unsolicited tax advice - very helpful I must say.Yes you did
No Ides, I didn't. However, I would like to thank you for the unsolicited tax advice - very helpful I must say.
So, after all that we still seem to have contradictory views as to whether loans secured on non-residential property are in scope. Hopefully Dan will clarify the matter with the Central Bank and report back to us.
CBI have clarified that commercial loans (whether mortgage or not) are in scope where the loan is secured against a home. That brings a lot of small business loans into scope. It may also bring cross-collateralised into scope.
I appreciate that flatly contradicts what Ides is saying but there it is.
Not necessarily - a commercial loan could be secured against a residential property and would therefore be in scope.It also contradicts what Jim Stafford is saying?
Hi Sarenco,
It also contradicts what Jim Stafford is saying?
It's extraordinary that there is still such confusion. It's also extraordinary if non-residential properties are excluded - as in, why would the Central Bank not wish to protect the Consumer - all Consumers (as per their definition)?
In advance of writing to the Central Bank, I've been doing a bit of research. When I complimented RedOnion earlier, it was out of gratitude for providing the link to the Finance Committee link which I was in the middle of reading. My understanding of this is that the Governor said that commercial mortgages should be included!! The caveat is that he did not use those precise words but that certainly was my understanding of what he was saying.
Curious and curiouser.
Sorry a bit rushed - need to head out....