COMPENSATION: 12. Payment of Compensation In circumstances where impacted customers have suffered detriment, the payment of compensation is necessary to adequately make amends for lenders’ failures and to ensure that all detriment sustained by customers are remedied. The Central Bank acknowledges that lenders will not be in a position to make customer specific awards of compensation upfront as they will not know the specific circumstances of all impacted customers. Accordingly the Central Bank suggests that lenders divide impacted customers into cohorts depending upon the impacts of the lenders’ failures and award levels of compensation to customers based on the cohort that they fall into. For example, customers could fall into the following broad cohorts:
(a) impacted customers that have never been in arrears;
(b) impacted customers that are currently, or were previously, in arrears;
(c) impacted customers that entered into, or are in the process of entering into, a restructuring arrangement regarding their mortgage accounts;
(d) impacted customers that are currently, or were previously, engaged in legal proceedings with lenders as a result of going into arrears in relation to their mortgages; and/or
(e) impacted customers that have lost ownership of their mortgaged properties including