Key elements included banks setting out clear plans on how they were going to address NPLs. Portfolio specific NPL strategies, for example, Mortgage Arrears Resolution Strategies (MARS) were required from the main lenders. Banks’ boards were required to approve these strategies encompassing the fair treatment of customers and ensuring adequate capabilities to deal with each customer.
Consumer protection measures such as the Code of Conduct on Mortgage Arrears and enhanced SME protections ran alongside and were interlinked with the prudential measures. We assessed each lender’s strategy and plans, and reverted with firm-specific feedback, follow up actions and timelines in early 2012.