OK, I have studied the CCMA in more detail and it does not do as I thought it did.
I always assumed that it prohibited lenders from charging higher mortgage rates to loans which were in arrears, and by implication, those which had been restructured.
But there is no such prohibition.
As no lender upped the rates for borrowers in arrears, I had assume that this was what it meant and never had to study it.
But it's clear now that the CCMA does not stop Pepper from what it is doing, charging customers higher rates because their mortgages were restructured.
Having said that, the fact that the CCMA does not prohibit it, does not mean that it's ok to do it. I still think that it's wrong and I will continue to try to challenge it with the Central Bank, the government, and ultimately the Ombudsman.
Brendan