As a result of a requirement to apply competition law, it was necessary to value and transfer loans individually. This made the transfer process a relatively lengthy one, which worked against the objective of moving quickly to cleanse balance sheets.
More significantly, an unforeseen consequence was the fact that the average size of the haircut increased over time, as the typical size of haircut on the later tranches proved unexpectedly large. As a result, the final recapitalisation need arising from the NAMA process was greater than the initial indications from the earlier tranches of loan transfers had suggested.