The Partnership,
According to the Central Bank of Ireland, the in scope mortgage accounts affected include:
3.2 IN-SCOPE MORTGAGE ACCOUNTS
3.2.1 In the course of the Examination the lender is to review all mortgage accounts in respect of
both Private Dwelling Houses and Buy-to-Let properties:
- that originated on Tracker Interest Rates1;
- that had Tracker Interest Rates applied at any stage during the term of the underlying
mortgage agreements; and/or
- where the underlying mortgage agreements provided for contractual rights to or
options2 for Tracker Interest Rates at any stage during the term of the agreements.
For the avoidance of doubt, this includes all mortgage accounts that have been redeemed, sold or transferred to another entity by the lender, together with mortgage accounts where the customer has lost possession of the secured property for any reason (including by way of voluntary and involuntary sale).
I suppose you can argue that your commercial loan is technically a buy to let property and therefore is within scope of the current examination, after all it is a tracker mortgage loan.