23 See Report on Mortgage Arrears 2016 Central Bank of Ireland 13  12  Central Bank of Ireland - RESTRICTED  24  Unregulated loan owners account for c.3% of the outstanding value of Irish mortgage loans. This comprises € billion of PDH loans (2% of the PDH market) and € billion of BTL loans (8% of the BTL market).
25 Figures derived from analysis of legal proceeding issued for loans in arrears as at 31 December 2017 by statistics division of the Central Bank. 26 See http://ec.europa.eu/finance/docs/policy/180314-proposal-directive-non-performing-loans_en.pdf 27  28  See Donnery 2018 “When is the right time?