03/07/2019                                                                                                    RAP/RCha/IRL/16(2019)add

EUROPEAN SOCIAL CHARTER

Reply by the Irish Government to the comments made by

Community Action Network (CAN) and Centre for Housing Law, Rights and Policy Research, NUI Galway

on the

16^th National Report on the implementation of

the European Social Charter

submitted by

THE GOVERNMENT OF IRELAND

Article 7, 8, 16, 17, 19, 27 and 31

for the period 01/01/2014 - 31/12/2017

Report registered by the Secretariat on

3 July 2019

CYCLE 2019

Replying observations of Ireland

On the paper:  ‘Comments on Ireland’s 16^th National Report on Implementation of the European Social Charter’

Submitted to the European Committee of Social Rights by Community Action Network (CAN) and Centre for Housing Law, Rights and Policy Research, NUI Galway (2019)

This contribution is addressed to Article 16 - The right of the family to social, legal and economic protection, pages 1-26.

1. The Government report does not refer to the collective complaint FIDH v. Ireland in which Ireland has been found in violation of Article 16

The omission of reference to the collective complaint International Federation for Human Rights (FIDH) v. Ireland (Complaint No. 110/2014) in the report submitted by the Government last October was not intentional but rather due to a concentration on the thematic areas of the report, but now welcomes the opportunity to address same and to highlight the ongoing work in the area.

It should be noted that while several claims were pursued as part of that case, the findings were that there was no violation of Article E in conjunction with Article 16 of the Charter, which upholds the principle of non-discrimination and that the Committee found that the allegations of discrimination could not be upheld.

It should be further noted that the ECSR found that there was no violation of Article 11 of the Charter and of Article E in conjunction with Article 11 of the Charter. The decision of the Committee that there was no violation of Article 17 of the Charter is also noted, as is the decision that there was no violation in respect of Article 30 which gives effect to the right to protection against poverty and social exclusion.

However, the Committee found that there was a violation of Article 16 in respect of taking sufficient and timely measures to ensure the right to housing of an adequate standard for a number of families in local authority housing and the findings of the Committee were fully acknowledged by Ireland.  The following observations and updates are addressed therefore to the finding in relation to Article 16.

2. The legal framework for the right to housing for families in Ireland is insufficient;

Ireland is very conscious of its obligations under Article 11.1 of the International Covenant on Economic, Social and Cultural Rights in relation to the right of people to an adequate standard of living for themselves and their families, including adequate housing, and under Article 16 of the European Social Charter.  While the Irish Constitution does not contain an express right to housing, there are however, a range of rights and protections in relation to social housing provided for in Irish legislation, including, in relation to social housing:

• the right to apply for and be assessed for social housing support;

• if eligible for social housing support, the right to obtain Housing Assistance Payment or to be placed on a waiting list for social housing: households who decide to avail of Housing Assistance Payment may opt to be placed on a transfer list for social housing;

• the right not to be discriminated against on the basis of gender, marital status, family status, sexual orientation, religion, age, disability, race or membership of the Traveller Community;

• the right of a social tenant in a housing authority dwelling to purchase the dwelling subject to certain conditions;

• the duty of the housing authority to make an assessment of housing need, to make an Allocation Scheme and operate according to it and to have regard to the needs which the scheme is designed to meet;

• rights in relation to the procedure for a Tenancy Warning and eviction; and

• the responsibility on housing authorities through the Housing Act 1988 to provide for the accommodation needs of people who are homeless.

There is also a comprehensive suite of primary and secondary legislation in relation to social housing in Ireland including:

• Housing Act 1966

• Housing (Miscellaneous Provisions) Act 1979

• Housing Act 1984

• Housing Act 1988

• Housing (Miscellaneous Provisions) Act 1992

• Housing (Miscellaneous Provisions) Act 1997,

• Housing (Traveller Accommodation) Act 1998

• Housing (Miscellaneous Provisions) Act 2002

• Housing (Miscellaneous Provisions) Act 2004

• Housing (Miscellaneous Provisions) Act 2009

• Housing (Amendment) Act 2013

• Housing (Miscellaneous Provisions) Act 2014

• Residential Tenancies (Amendment) Act 2015

and numerous associated Regulations.

With regard to Article 31 of the European Social Charter (Revised), the right to housing is being considered by the relevant forum in the Irish context. The Eighth Report of the Convention on the Constitution (2014) recommended that the State should progressively realise economic, social and cultural rights, including the right to housing, subject to maximum available resources, by inserting such a right into the Irish Constitution. The Convention’s recommendation raises substantial questions, including for example, the suitability or otherwise of the Constitution as a vehicle for providing for detailed rights in this area, the possible cost, and the fact that there is already power by legislation to confer rights and determine expenditure via primary and secondary legislation and an elected and accountable Government and Oireachtas (legislature). For these reasons the issue of the right to housing was referred, for further consideration, to the appropriate Oireachtas Committee, the Joint Committee on Finance, Public Expenditure and Reform, and Taoiseach, in October 2017.  It should be noted that the absence of a right to housing in the Constitution does not delay the implementation of our national housing plan, Rebuilding Ireland: An Action Plan for Housing and Homelessness, and the delivery of housing (see under Point 7 below). Accordingly, it is considered appropriate to continue with the process of Oireachtas committee engagement and coming to a determination of the next step regarding the matter of the inclusion of such rights in the Constitution.

The matter of ratifying Article 31 of the Revised European Social Charter will be considered further after the Joint Committee has considered the matter.

3. The Government report does not provide national statistics on the conditions of local authority housing stock;
   
   

Local authorities are responsible, in the first instance, for the management and maintenance of their own housing stock under the Housing Acts, including responsive and planned maintenance and the identification of housing in need of upgrade, regeneration or adaptation. Increasing numbers of local authorities have undertaken stock condition surveys.  The City and County Management Association (CCMA), on behalf of local authorities, is driving a shared approach to the planned maintenance of social housing, including stock condition surveys, building on the work that several local authorities have already launched in that regard and there is on-going dialogue between the CCMA and the Department of Housing, Planning and Local Government (DHPLG) in order to advance reform in the area.  

Rebuilding Ireland committed all local authorities to adopt a preventative maintenance approach to housing stock management, including consistent standards and the adoption of a common national re-letting performance standard.  In this regard the Department introduced regulations SI 17 of 2017 which came into effect on 1 July 2017 which updated the minimum standards regulations for rental accommodation which local authorities are required to adhere to.

4. Local authority housing tenants continue to live with inadequate housing standards, which are often lower than the legally defined standards for rented housing;

The Department introduced regulations (SI 17 of 2017) which came into effect on 1 July 2017 which updated the minimum standards regulations for rental accommodation which local authorities are required to adhere to.  Local authorities operate a responsive repairs arrangement and also complaints procedures, which allows tenants to have repairs carried out to social homes or to raise complaints if dissatisfied with the service provided.

In addition to funding by the local authorities themselves in their own housing stock, the exchequer/Department provides funding across a number of programmes to support the local authority work to maintain and improve their social housing stock but, in all cases, it is the local authorities that identify priority. The very significant investment currently being made in Regeneration projects such as Dolphin House, which was specifically referenced in the complaint regarding social housing conditions in Ireland made to the European Committee of Social Rights, is a key element of the Irish Government’s commitment to these issues.  In the case of Dolphin House, 2018 saw the full refurbishment of 63 of the existing apartments alongside the construction of 37 newly built social homes for the residents of the area, with over €25 million in investment. The regeneration programme there will continue into 2019 and beyond. An update on the other estates referenced, will be provided for the next report.

Over the lifetime of Rebuilding Ireland, some €211 million is being made available under the National Regeneration Programme to support the direct delivery of over 1,000 new, high quality social homes in the regeneration areas. Together with providing a significant number of new homes, and upgrading of existing homes in the areas, the regeneration projects seek to also address causes of disadvantage in these communities through support for a programme of physical, social and economic regeneration. Equally, the continued work of local authorities in undertaking stock condition surveys, their responsive and planned maintenance programmes, as well as important programmes such as the Energy Retrofitting and Voids Programmes, also address the issues raised with the European Committee of Social Rights.

The Energy Retrofitting programme has seen over 68,000 social houses and apartments being retrofitted to date, through some €128m of investment.  The programme aims to improve energy efficiency and comfort levels in social houses and addresses issues around fuel poverty. The Department also funds a voids programme, which provides exchequer funding to support local authorities in remediating vacant homes, as distinct from local authorities own refurbishment works; with a strong emphasis on Insulation Retrofitting. The exchequer funding provided by the Department is additional to the investment that local authorities provide themselves towards such work and the authorities contribute additional investment.  Since 2014, exchequer investment of some €145.5m has been provided to local authorities to refurbish / upgrade almost 11,000 social homes.

Specifically with regard to Dublin City Council, (DCC), the local authority is building upon its experience of regenerating housing/apartment complexes to examining options to address issues arising with older apartment complexes (those over 40 years old, of which there are over 6,000 apartments). DCC is seeking to deliver housing-led area renewal and estate redevelopment at increased sustainable densities and build upon established principles of community-based, tenant-led approaches to estate regeneration, ownership and management. 

DCC as the largest local authority, adheres to the Housing (Standards of Rented Houses) Regulations July 2017. To work to these standards, DCC has been carrying out condition surveys on their properties since May 2018. These surveys provide DCC with information on the condition of their existing housing stock. In light of these surveys and as part of the Council’s continuous planned maintenance works, they have undertaken the following:

• Energy Efficiency Works: The work involves upgrading properties with external wall insulation and other measures - 326 social homes were completed in 2018.
• Boiler Replacement Programme: This is the replacement of old inefficient boilers with 1,172 replaced in 2018 and the programme is continuing.
• Better Energy Communities/SEAI: This entails the upgrading of residential and communal buildings with measures such as external wall insulation, heating etc.
• Vacant Units: The number of vacant social homes refurbished and upgraded since 2015, to date in 2019, is 4,001.
• Maintenance Works/Roof Repairs: In 2015, DCC commenced a programme to address social homes with roofs in most need of repair. Since then, the authority has replaced roofs on 17 apartment complexes, covering 1,449 social apartments.
• Regulatory Building Standards – DCC has completed work on over 4,000 social homes to date where intervention was needed to bring them up to current standards.  .
• Condensation Works: DCC has commenced a programme of works since 2018, to provide improve ventilation, reduce relative humidity, and alleviate dampness and condensation issues in social homes.  Works to 600 social homes were completed in 2018, while over 400 have been completed to date in 2019.
• Windows/Doors: Since 2018, DCC has completed the replacement of doors/windows in 750 social homes.

The Capital works programme for DCC housing stock is significant and will continue over the next 5-10 years.  The improvement works will provide accommodation for the tenants of the City Council that meets the requirements of modern living standards.

5. The Government has not fulfilled its obligation in providing adequate management and maintenance of local authority housing;

See response under point 3. above.

6. There are ineffective complaint mechanism and legal remedies for families living in local authority housing;

Local authorities are independent statutory bodies with democratically elected councils and their own management system. The day-to-day management of each local authority is vested in a full time chief executive. The chief executive is accountable to the elected council, not the Minister, in the discharge of these functions. 

The role of the Minister and the Department in relation to local authorities is primarily to ensure an appropriate framework of policy and legislation in relation to the local government system, including its structures, human resourcing and financing. Neither the Minister nor Department has a role in relation to the day-to-day decisions of local authorities save in a limited number of matters where there may be specific statutory provision for Ministerial approval within the Department’s particular areas of responsibility.   

With regard to complaints that arise regarding housing conditions, generally, local authorities have a multi-stage procedure for dealing with customer complaints. The first involves discussing the complaint at the point of service; this is usually the quickest and most efficient way to address matters that have arisen. If someone is unhappy with the outcome of this first stage, a formal complaint can be made under the Council’s Complaints and Appeals Procedure, details of which can be found on the website of the local authorities.

Having engaged in the relevant local authority’s Complaints and Appeals Procedure, if a person continues to consider the response from the local authority to be unsatisfactory, the matter may be pursued further through the Office of the Ombudsman. One of the functions of the Office of the Ombudsman is to investigate complaints that arise when members of the public have tried to access local government services and an unsatisfactory response to complaints has issued.

7.         State published statistics on homelessness show a growing number of homeless families and children clearly in conflict with the obligations under Art 16 to ensure an adequate supply of housing for families

In 2016, the Irish Government published Rebuilding Ireland, an action driven plan to accelerate housing supply in Ireland in order to address the evident under-supply of housing that had emerged. The plan includes a range of measures to address the needs of homeless people and families in emergency accommodation, accelerate the provision of social housing, deliver more housing generally, utilise vacant homes and improve the rental sector.

As evidence of its commitment to tackling these issues and to support the roll out of the ambitious Rebuilding Ireland Action Plan, over €6 billion is being provided by the Government over the lifetime of the Plan. This funding will: 

• support an increase in the overall supply of new homes to 25,000 per annum by 2020;
• deliver an additional 50,000 social housing homes in the period to 2021; and
• meet the housing needs of an additional 87,000 households through the Housing Assistance Payment (HAP) scheme and the Rental Accommodation Scheme.

In relation to tackling homelessness and the provision of social housing, housing budgets have been increasing year on year. As reflected below, the housing budget for 2019 is just under €2.4 billion. This is the highest level of funding ever provided for housing purposes in any given year in Ireland.

The 2019 budget set a target of 10,000 new social homes to be delivered in 2019 and allocated €310m for delivery of Affordable Homes through the Serviced Sites Fund.

Table: Housing Expenditure 2016 – 2018 and Budget for 2019

 

In relation to the delivery of social housing supports for households, it should be noted that over the three-year period 2016 – 2018, over 72,000 households had their social housing needs met under the Rebuilding Ireland Action Plan. It is estimated that by the end of 2019, this number will have increased to over 100,000 households.

 

In 2018 alone:

• 27,103 new households that had their housing need met under Rebuilding Ireland;
• 8,422 new homes were brought into the active social housing stock through build, acquisitions, voids and leasing programmes, 7% ahead of the target for the year;
• Looking at the new build element of delivery, this increased by 185% in 2018 compared to 2017 and the number was eight times greater than the number built in 2015, the year before Rebuilding Ireland;
• Construction figures from December 2018 show almost 5,000 new social housing homes being built across 291 sites. These are being added to on a weekly basis; and
• All of this was facilitated in 2018 by over €2 billion of investment of taxpayers’ money, up 47% on 2017.

The commitment under Rebuilding Ireland is to add some 50,000 homes to the social housing stock through Build, Acquisition and Leasing Programmes and, in addition, to provide a further 87,000 flexible housing supports through the Housing Assistance Payment (HAP) and Rental Accommodation Scheme (RAS) between 2016 and 2021.

This contribution is addressed to Article 16, - The right of the family to social, legal and economic protection, pages 27-29 of the paper, setting out findings of “Insufficient legal protection for persons threatened by eviction.”

The section does not reference a number of legislative protections which have been put in place in recent years.

The Land and Conveyancing Law Reform 2013 contain two provisions which are intended to strengthen protection for borrowers with arrears. Firstly, it provides that in any future repossession proceedings in respect of a borrower’s principal private residence, the court may adjourn proceedings so that a proposal for a Personal Insolvency Arrangement (PIA) under the Personal Insolvency Act 2012 may be fully explored as an alternative to repossession. This will mean in effect that lending institutions cannot in future proceed to the repossession stage without engaging in good faith in the alternative measures provided for in the Personal Insolvency Act 2012 where a borrower makes a proposal in this regard. 

Secondly, section 3 of the Act provides that repossession actions in relation to a principal private residence where the mortgage was created prior to 1 December 2009 must be commenced in the Circuit Court. This will lead to a reduction in costs for parties. It puts such mortgages on the same footing as similar mortgages created after 1 December 2009; under the Land and Conveyancing Law Reform Act 2009 repossession proceedings in respect of housing loan mortgages must be commenced in the Circuit Court.

The Land and Conveyancing Law Reform (Amendment) Bill 2019 which is before the Dáil, having already passed through the Seanad, will provide further protections for those in mortgage arrears.  The Bill provides that the court must take into account a number of matters when considering the making or refusal of a possession order.  These matters are:

(a) Whether the making of the order would be proportionate in all the circumstances    of the case;  

(b) The circumstances of the borrower and his or her dependents (if any);

(c)  Whether the lender has made a statement to the borrower of the terms on which it   would be prepared to settle the matter in such a way that the borrower and his or her dependents could remain in their principal private residence;

(d) Details of any proposal put forward by or on behalf of the borrower either to enable him or her, and any dependents, to remain in the principal private residence or to secure alternative accommodation; and

(e) The conduct of the parties in any attempt to find a resolution to the borrower’s mortgage arrears difficulties.

When enacted, the Bill will provide a clear checklist of factors that a court must take into account when deciding whether to grant a possession order to a lending institution in respect of a borrower’s principal private residence.

This contribution is addressed to Article 16 - The right of the family to social, legal and economic protection, pages 29-30 of the paper, setting out findings of a survey conducted by CAN in 2018 entitled ‘House Hold: Life in Mortgage Distress’, and referring to the Abhaile Scheme.

Abhaile (the name means ‘Home’, in Irish) is a Government Scheme, established in 2016 to provide homeowners in serious mortgage arrears on their homes with free access to independent expert financial and legal advice and help. The objective is to help the homeowner to identify and put in place the best solutions to resolve their mortgage and other debts sustainably, enabling them wherever possible to remain in their homes. 

Abhaile is one of the Government initiatives included in Pillar 1 of ‘Rebuilding Ireland 2016-2021’, the Government of Ireland Action Plan on Housing and Homelessness, which is mentioned in Ireland’s 16^th National Report on Implementation of the European Social Charter, dated October 2018.

Replying observations

• The Government agree with the paper’s comments on the importance of providing support to homeowners who are living with unsustainable mortgage arrears on their homes, and on the distress and shame experienced by many homeowners in this situation.
• The Government has on many occasions – including in its Programme for Government (May 2016) and in the 16^th National Report -  underlined the priority that it affords to providing such support, with a view to putting in place sustainable and fair solutions which enable people to remain in their homes. Abhaile is one of the Government initiatives seeking to provide such support.
• The main criticism of Abhaile made in the paper (p. 29-30) is that Abhaile is not centred on providing full legal aid for households in mortgage arrears to contest repossession proceedings.
• However, these comments miss the point.
• In these cases, the borrower is generally in very substantial arrears of repayments due under their home mortgage. This being the case, they will generally have no substantive legal defence to repossession proceedings brought by the mortgage lender. In such cases, supporting procedural or technical challenges to repossession proceedings is not a sustainable solution for the borrower. Even if the current proceedings are struck out on a procedural or technical ground, the lender can simply issue new repossession proceedings, as the borrower is still in significant arrears of payment on their home mortgage.
• The main focus of Abhaile is, instead, on solving the borrower’s substantive problem in a sustainable way, by resolving the arrears themselves.
• Abhaile provides the borrower with free, independent expert financial advice and negotiating help to get a solution to home mortgage arrears into place, in a way tailored to the borrower’s individual situation. The solution may be negotiated and agreed with the creditors - or if need be, imposed by a court using the ‘court review’ power under s. 115A of the Personal Insolvency Acts. This allows the court, at the borrower’s request, to review creditors’ refusal of a solution to home mortgage arrears put forward by a borrower, and to impose the borrower’s solution on the creditors, if the court considers it overall fair and reasonable to all parties. Abhaile includes providing full legal aid to a borrower for such application.  
• In addition, Abhaile offers unrepresented borrowers independent legal advice from a solicitor on any legal questions arising regarding resolving their home mortgage arrears or any repossession proceedings issued against them. (These are the ‘vouchers’ mentioned in the paper for one or two free consultations with a solicitor, but those are just one (supporting) element of the range of advice and assistance available under Abhaile,)
• Abhaile also offers duty solicitor and court mentor services to help unrepresented borrowers in repossession proceedings before the courts. These supports are not full legal aid, but it should be recalled that the courts in any event have a statutory obligation to take the initiative to adjourn home repossession proceedings for at least three months to allow the borrower to explore options for restructuring their home mortgage arrears – even without a request from the borrower.
• For a borrower who has a substantive legal defence to repossession proceedings, civil legal aid is available, subject to the normal conditions. All Abhaile solicitors are trained to advice borrowers of this option.
• Very detailed and comprehensive information on all aspects of Abhaile is published in Abhaile’s second Annual Report (January 2019) [1].
• Finally we would note that the paper’s criticism of Abhaile refers to a 2018 survey  report by CAN (cited at footnote 43 on p. 29 of the paper.)  Some questions arise as to the research methodology used. The survey appears to be based on a very small number of respondents (maximum 169: the number varies between questions). The report indicates that only 70 of these respondents had actually contacted Abhaile (or the State Money Advice and Budgeting Service (MABS), which acts as the main access point to the Scheme). The report also indicates (on page 14) that only 13 respondents to the CAN survey had actually requested a solicitor through MABS/Abhaile. It is not clear how respondents were selected to ensure representativeness, and it is worth noting that high proportions of those responding to the survey expressed a generalised distrust of solicitors or of government-backed help – see pages 11 and 13 of the survey report.
• It seems surprising that the CAN 2018 survey report forms very wide generalised conclusions about Abhaile, based on such tiny samples of borrowers who had actually used the Abhaile service. This contrasts with the thousands of borrowers who have taken up financial advice and help, or legal advice and help, or both, under Abhaile (please see Appendix I below for background information and detailed figures.)

II. Article 31-The right to housing

See response under pages 1-4 above: the matter of ratifying Article 31 of the Revised European Social Charter will be considered further after the Joint Committee has considered the question of including economic, social and cultural rights in the Irish Constitution.

The issue of reports concerning the non-accepted provisions is being clarified.

Appendix I

Abhaile, launched in October 2016, is a Government funded mortgage arrears resolution service, directed to assisting homeowners who are at risk of losing their homes due to mortgage arrears. Abhaile gives these heavily indebted borrowers free access to panels of qualified and regulated financial or legal professionals, who then provide individualised advice and assistance to the borrowers to identify and put in place solutions to their home mortgage arrears, with priority to assisting them to stay in their homes.

The data published in Abhaile’s second Annual Report (January 2019)[2] indicates that Abhaile is reaching its key target group (of distressed borrowers in mortgage arrears equivalent to over 720 days’ missed repayments) and is helping them to achieve sustainable solutions to their arrears. Take up of the Abhaile scheme has been high, especially amongst those in very long term arrears.

Key successes include:

•           Take-up: Up to 20 May 2019, Abhaile has provided 12,268 vouchers for borrowers to access free financial advice and help from a Personal Insolvency Practitioner or Accountant. Abhaile also provided 3,426 vouchers for borrowers to access free legal advice from a solicitor in that period. Up to June 2018,  free Dedicated Mortgage Arrears Advisers, working with the State’s free Money Advice and Budgeting Service around the country, had provided financial advice and help under Abhaile to a further 4,960 borrowers to resolve their home mortgage arrears.

•           Target group: Over 70% of the borrowers who received financial advice from a Personal Insolvency Practitioner under Abhaile were in mortgage arrears equivalent to more than 720 days’ repayments (the priority Abhaile target group).

•           Outcomes: As of July 2018, Abhaile had over 3,300 solutions in place, or on trial, for insolvent borrowers who were at risk of losing their home due to mortgage arrears. (Over 30% of the 11,695 borrowers who obtained Abhaile financial advice either had a solution in place or on trial at this point, or will have within one year of taking up advice.) The vast majority of these solutions enable the borrower to remain in their homes. (95% of Personal Insolvency Arrangements[3]: 86% of the informal solutions achieved by Dedicated Mortgage Arrears Advisers.)

•           A further 53% of borrowers who engaged with Abhaile financial advice (6,148 borrowers) did not yet have a solution in place (July 2018), but were still in their homes and were working with their Abhaile financial adviser to get a solution into place.

Support at Court:

•           Personal Insolvency Court Reviews: If a homeowner’s creditors refuse a proposal for a Personal Insolvency Arrangement which includes resolving their home mortgage arrears, the homeowner may ask the Court to review this refusal under Section 115A of the Personal Insolvency Act 2012. [4] As of 20 May 2019, the Legal Aid Board had granted full legal aid under Abhaile to a total of 1,490 borrowers to seek a personal insolvency court review.

•           Abhaile also provides support at court, if the borrower is facing repossession proceedings. The borrower’s engagement with Abhaile is widely taken into account by the courts, which will normally adjourn repossession proceedings to facilitate a borrower trying to resolve the arrears with Abhaile help. The Court is required by law, under the Courts and Civil Law Miscellaneous Provisions Act 2013, to intervene to grant at least one adjournment of three months – even without any request from the borrower - to allow the borrower to explore whether a Personal Insolvency Arrangement could assist them.

·         Abhaile has provided paralegal Court Mentors to provide information and advice to unrepresented borrowers, and Abhaile duty solicitors to provide legal advice and help, at virtually all Circuit Court Repossession lists (County Registrar lists) across Ireland since September 2016. Up to July 2018, the duty solicitors had provided legal assistance at court to 4,788 borrowers facing repossession proceedings against their homes, and the court mentors have helped 7,191 such borrowers since September 2015.

The cohort of home mortgage accounts with the deepest arrears (equivalent to more than 720 days’ repayments outstanding) has fallen consistently since its greatest extent. It peaked in mid-2015, when it stood at 38,043 accounts, and numbered 34,980 accounts by end June 2016, the beginning of Abhaile Year One. By the end of December 2018, in the middle of Abhaile Year Three, these deepest-arrears home mortgage accounts had reduced to 27,551 – a fall of over 10,000 accounts, or 28%, since peak.