Hi Brendan
By "experience to date", I am really just referring to the Central Bank's loan level data and posts (or the lack of posts!) on here regarding the application of the rules in specific individual circumstances.
It seems to me that the evidence to date shows that the rules are actually having a limited impact on FTBs, at least at a national level. However, I do think a modest increase in the 90% LTV ceiling (from, say, €220k to €250k) might be appropriate to address any undue dislocation of demand from urban to surrounding rural areas.
Where the rules really seem to bite is for a relatively small cohort of borrowers in properties that are unsuitable for their current requirements, that are not in NE but do not have the 20% deposit required to purchase a more suitable property. My suggestion of a tiered LTV approach, that is common to FTBs and SSBs, is largely intended to address that issue.
To bring some balance to these changes, my suggestion is that higher value loans should carry a higher collateral requirement as lenders potentially face higher losses in absolute terms on these loans.
I actually don't have a particular problem with the current rules but, if they are to be recalibrated, I think a tiered LTV approach that is common to all home loan borrowers would be a better approach.