Howard was not picked by Everton to play against his former club after "a gentleman's agreement" and replacement Iain Turner was responsible for at least one goal in the 4-2 defeat.

Premier League chief executive Richard Scudamore is considering a new rule to make it official that when players go on loan to another club and then sign a permanent deal they cannot play against their original club for the rest of that season.

Manchester United originally tried to insert a clause into the sale of Howard preventing the United States international playing against them but were blocked by the Premier League, who were furious but powerless when it was later revealed Everton had made an unwritten agreement not to pick him.

Scudamore said: "We insisted the clubs could not write the clause into a contract and because there was no contractual position in force, if Everton had wanted to play Howard they could have and were not in breach of our rules.

"We have a very restricted loan system in the Premier League, much more restricted than in other leagues.

"We do have an odd situation that if a player goes on loan our rules say he cannot play against his original club. The moment the move becomes permanent the rules say you cannot stop them playing against their original club.

"Perhaps for situations where it has been a hybrid loan and permanent move, there should be a clause which says he cannot play against his original club for the rest of the season."