The representative body of all the main Irish banks has said the proposed 20% cash deposit for homebuyers is not necessary or appropriate and would exclude many first-time buyers.
In its submission to the Central Bank on the suggested new rules, the Banking and Payments Federation says it has significant concerns about the proposal.
It adds that there is no evidence of a credit driven bubble in property prices.
The BFPI says the new deposit rule could also lead to housing supply issues by hurting demand, especially for new developments.
On a suggestion by the head of the Central Bank and others that mortgage insurance might play a role, the federation says it does not believe that it offers a solution to the issues the Central Bank is seeking to address.
The BFPI does not take issue with the proposed loan limit of 3.5 times income, however.
