My submission to CCPC on ptsb acquisition of Ulster Bank mortgages

[Brendan Burgess]

The CCPC is conducting a Phase 1 investigation into this proposed acquisition.
They would like submissions from interested parties before 4th January i.e. Tuesday.

Ulster Bank customers - CCPC invites submission on takeover of your mortgage by ptsb

The Competition Commission was notified yesterday of the proposed takeover of Ulster Bank mortgages by ptsb. https://www.ccpc.ie/business/mergers-acquisitions/merger-notifications/m-21-076-ptsb-certain-assets-of-ulster-bank/ The Commission is now doing a Preliminary Investigation and invites...

www.askaboutmoney.com

I would encourage Ulster Bank mortgage holders to make submissions as you are going to pay a lot more for your mortgage if it's acquired by ptsb without any conditions being imposed by the CCPC.


Update: I attach my final submission - thanks to SPC100 and Hollow Knight for their comments and suggestions on the draft.

Brendan

 

[PolkaDot]

No comments on the submission, but just wanted to say fair play to you Brendan for all the work you put into it.

 

[HollowKnight]

Hi Brendan,

Thanks for this excellent document.

I have some minor suggestions (formatting issues mostly).

You switch back and forth between Calibri and Times New Roman - the font should be standard throughout the whole document.

You label your fourth table 'Table 1' - you should label each table.

You label 'Table 1' source as a date in the future, which is fine if that is the day you plan to submit.

That's all I had.

Great work.

 

[Brendan Burgess]

You switch back and forth between Calibri and Times New Roman - the font should be standard throughout the whole document.

You label your fourth table 'Table 1' - you should label each table.

You label 'Table 1' source as a date in the future, which is fine if that is the day you plan to submit.

Hollow Knight

Very helpful. All fixed now.
Yes, I intend to submit tomorrow which is the deadline.

I have replaced the attachment in the first post with the updated draft. If you are at a loose end today, you might have another "proofing" look at it.

Thanks again.

Brendan

 

[HollowKnight]

Hollow Knight

Very helpful. All fixed now.
Yes, I intend to submit tomorrow which is the deadline.

I have replaced the attachment in the first post with the updated draft. If you are at a loose end today, you might have another "proofing" look at it.

Thanks again.

Brendan

I've gone over it again. Mostly to help with layout, correct the odd grammatical error, etc.

In writing documents like this, it's important to introduce the long version of a term before the abbreviation. There are many in the document and I think I caught them all but maybe you'd go through it once again. I did contract permanent tsb to ptsb and Ulster Bank to UB quite a few times but not every time.

I've re-attached it here. Hopefully you find it helpful.

 

[Brendan Burgess]

HK

That is great. Much appreciated.

I suppose I assumed that the CCPC - Sorry Competition and Consumer Protection Commission - would understand the abbreviations. But you are right. Spell it out just in case.

Brendan

 

[Interest%]

Hi, i have just read it. Some very valid points, Especially Re. Same Rates for existing customers as new customers. Heres hoping non flexible ptsb will bend.
Thanks for championing this.

 

[HollowKnight]

HK

That is great. Much appreciated.

I suppose I assumed that the CCPC - Sorry Competition and Consumer Protection Commission - would understand the abbreviations. But you are right. Spell it out just in case.

Brendan

It is very likely that they would understand the abbreviations, however it's best not to assume.

 

[Brendan Burgess]

Hi HK

It looks much better after your improved layout.

I have made some small further edits and submitted it.

The final version is now attached to the first post.

Brendan

 

[Brendan Burgess]

Some good coverage of the submission in today's papers.

PTSB move to take over Ulster Bank mortgages should have ‘conditions’ attached, says consumer advocate

The takeover by Permanent TSB of Ulster Bank mortgages should have conditions attached to it to stop homeowners losing out, a leading consumer advocate said.

www.independent.ie

'Tell PTSB to end cashback mortgages' before go-ahead to take €7.6bn loans from Ulster Bank

The CCPC is involved in an unprecedented activity into Irish banks after both Ulster, the No 3 general lender, and KBC, a significant mortgage bank, announced plans to exit Ireland

www.irishexaminer.com

CCPC urged to impose conditions on PTSB purchase of Ulster Bank loan book

Consumer advocate warns Ulster Bank customers may become ‘prisoners’ of PTSB

www.irishtimes.com

 

[Freelance]

Charlie Weston also has it in the Indo (paywalled)

https://www.independent.ie/business...attached-says-consumer-advocate-41227602.html

 

[Brendan Burgess]

Thanks Freelance

I had missed that one in my search.

Brendan

 

[Interest%]

Some good coverage of the submission in today's papers.

PTSB move to take over Ulster Bank mortgages should have ‘conditions’ attached, says consumer advocate

The takeover by Permanent TSB of Ulster Bank mortgages should have conditions attached to it to stop homeowners losing out, a leading consumer advocate said.

www.independent.ie

'Tell PTSB to end cashback mortgages' before go-ahead to take €7.6bn loans from Ulster Bank

The CCPC is involved in an unprecedented activity into Irish banks after both Ulster, the No 3 general lender, and KBC, a significant mortgage bank, announced plans to exit Ireland

www.irishexaminer.com

CCPC urged to impose conditions on PTSB purchase of Ulster Bank loan book

Consumer advocate warns Ulster Bank customers may become ‘prisoners’ of PTSB

www.irishtimes.com

Hi Brendan.
When will we know the outcome.
Thanks

 

[Brendan Burgess]

And Goodbody Stockbrokers have picked it up as well

Download Document

Our own observations are that: i) there is precedent for single lender dual pricing
strategies in the Irish market; and ii) importantly, both the ptsb acquisition of
Ulster Bank loans and the BIRG acquisition of KBC Bank Ireland loan assets appear
to have been presented to the market on the presumption that rate increases will
not be imposed for borrowers. For example, ptsb’s RNS of 17th December 2021 in
relation to the Ulster Bank deal noted that the bank expects incremental gross
interest income of c.€180m (excluding discount unwind) in 2023 which will reduce
over time, while gross interest income on the portfolio for FY21 is expected to be
€225m. Furthermore, BIRG’s RNS of 22nd October 2021 in relation to the KBC Bank
Ireland deal notes that BIRG expects incremental NII of c.€160m in 2023 which
will reduce over time, while the income from the assets being acquired is estimated
at c.€240m in FY20. We expect to learn that the CCPC will elect to launch a Phase 2
review of the ptsb / Ulster Bank deal later this month (BIRG’s acquisition of KBC
Bank Ireland loans is already subject to a Phase 2 review) and it remains to be
seen whether conditionality will be applied in the case of both deals.

 

[MrEarl]

The Journal also gave it a mention, in their "Morning Memo", that goes out by email. Also linked back to the Indo article.

 

[Interest%]

When is the outcome cpcc investigation. And do ptsb have to act on it.

 

[HollowKnight]

Not one of them commented on the formatting of the document!

 

[Brendan Burgess]

When is the outcome cpcc investigation. And do ptsb have to act on it.

The CPCC has enormous power.

They can approve the acquisition without any conditions.
They can veto the acquisition outright.

And the third option, which is the most likely, they can approve the acquisition but impose some conditions.

Brendan

 

[Gordon Gekko]

The CPCC has enormous power.

They can approve the acquisition without any conditions.
They can veto the acquisition outright.

And the third option, which is the most likely, they can approve the acquisition but impose some conditions.

Brendan

Hi Brendan,

Do they have the power to impose the conditions that we want them to impose though?

Or will they do a Pontius Pilate on it and claim that those issues are not within their remit?

My fear is that they’re restricted to higher level issues such as total market share rather than the prospect of individual customers being shafted.

Thanks for your work helping HollowKnight to put the submission together.

Gordon