. in that regard, the examination has exposed a clear lack of a consumer - centred culture in lenders. the culture of these institutions flows from the top, it is therefore a matter for boards, and senior management, in the first instance, to set a positive culture within a financial services firm that places the best interests of consumers first. where they fail to do so, regulators such as ourselves must have an effective toolkit with which we can intervene, and the tracker examination is one such example of how, as a systemic regulator, we are driving results for consumers in cases where lenders failed them. 3 / 6 bis central bankers'speeches we are conducting a separate assessment of the current behaviour and culture within banks, which will be completed in mid - year and provided to the minister. the findings from those assessments will further inform our ongoing supervisory work aimed at ensuring that, at a systemic level, consumers are treated fairly in their dealings with financial services firms and that their best interests are protected. non - performing loans npls cause considerable distress to borrowers, while also putting at risk the prudential soundness of banks with excessive npl burdens. over the last decade, the central bank took intrusive policy actions to ensure the framework for appropriate restructures was put in place. this, in addition to changes in the legal system, has meant that mortgage npl reduction has been primarily achieved through the restructuring of loans, rather than loss of ownership. protection of consumers in arrears continues to be a key central bank priority in dealing with non - performing loans. the code of conduct on mortgage arrears ( ccma ), in particular, has played a critical role in ensuring that borrowers are protected. this is evident in the data, with almost 120, 000 restructured primary dwelling home ( pdh ) mortgages as of q3 2017, and 87 percent of the accounts involved meeting the terms of the restructuring arrangement, showing the willingness and ability of both borrowers and lenders to address mortgage arrears in many cases. since q3 2009, there was loss of ownership in 8, 195 cases : 5, 473 properties were surrendered voluntarily and 2, 722 were repossessed through court order. the ccma requires a lender to make every reasonable effort to come to a restructuring arrangement with borrowers. without this key element of the code, the number of properties lost would have been considerably higher. elevated levels of npls on bank balance

sheets pose a substantial financial stability risk. for example, uncertainty around the adequacy of provision levels against these loans may also lead to uncertainty about the true levels of bank capital available to support future lending. it is important that this legacy risk is addressed : otherwise, the capacity of both banks and debtors to weather adverse developments may be questioned in the event of a future downturn. the stock of npls has declined considerably since its peak. however, while cre and sme lending represented the majority of banking npls at the height of the crisis, residential mortgages now account for close to two thirds of the remaining npl balances. the central bank ’ s approach to mortgage arrears resolution is focused on ensuring the fair treatment of borrowers through a strong consumer protection framework and ensuring that lenders have appropriate arrears resolution strategies and operations in place. the domestic irish banks have used a mixture of options, including sustainable loan restructuring, portfolio sale, voluntary sale of properties and progressing cases through the legal system. regarding the resolution of the roughly 28, 000 pdh mortgage cases in arrears of over two years, it continues to be our view that borrower - lender engagement is essential. first and foremost, sustainable restructurings which keep borrowers in their homes are desirable. however, where a restructuring arrangement is not achieved, the insolvency service of ireland helps borrowers who are struggling to repay their debt and offers advice in reaching debt solutions with creditors. for non - engaging borrowers, resolution through the legal system is the most probable outcome. non - bank entities ( regulated retail credit firms and unregulated loan owners ) held 7 percent of pdh loans and 11 percent of buy - to - let ( btl ) mortgage accounts as at the end of 2017. within this aggregate category, unregulated loan owners hold 2 percent of pdh mortgages and 5 percent of btl mortgages. however, the unregulated loan owners hold a disproportionately high share of accounts in arrears with 50 percent of their pdh mortgages in arrears over 90 days. the number of btl accounts in arrears over 90 days for unregulated loan owners was 75 percent at the end of december 2017. non - bank entities repossessed 148 pdhs during 2017, or 4 / 6 bis central bankers'speeches 10 percent of all repossessions in the year. the rep