The Money Advice and Budgeting Service has said increasing numbers of older people, who should be almost finished paying their home loans, are now getting into mortgage arrears.
A report by MABS has found that 60% of the agency's mortgaged clients are between the ages of 41 and 65.
It also showed that clients of MABS in such difficulties were more likely to be unemployed, have multiple debts in addition to the mortgage, and be mortgaged to a mainstream lender.
Speaking on RTÉ's Morning Ireland, Michael Culloty, national development officer with MABS, explained why this age group was in trouble.
He said that while you would have thought this group would have had their mortgage paid off by now, they have not because of products that were offered to them in the past.
"They were allowed to borrow on the equity that was in their property; they probably bought a second property; they probably bought to consolidate other loans, to move house. So that's the cohort of people that we're seeing," he said.
He said people are concerned about who they should pay first .
Mr Culloty said because they are in distress, they often give in to those who put most pressure on them, such as credit card loans.
He said these may not actually be the priority debt to pay back.
Mr Culloty said MABS was looking for a protocol from banks that would cover all debt and put priorities in place with a proper approach to unsecured debt.
Up to 230 submissions were received from consumers, industry, representative bodies and other stakeholders for the draft code of conduct on mortgage arrears.
The Central Bank director of consumer protection Bernard Sheridan said it was beginning a process to review and analyse all submissions.
It said that it expects the revised code will be published by the end of May.
Mr Sheridan said a proposal being considered on tracker mortgages only applies to people who are in danger of losing their homes.