ANZ ” to prudently increase volumes in the investor space”

ANZ today released its scheduled APRA APS330 report covering the quarter to 31 December 2018. Credit Quality remains stable with a Provision Charge of $156 million tracking below the FY2018 quarterly average.

The Group loss rate was 10 basis points1 (14 bps 1Q18). Group Common Equity Tier 1 (CET1) was 11.3% at the end of the quarter.Consistent with usual practice, ANZ also released a chart pack to accompany the Pillar 3 disclosure.

The chart pack once again includes an update on Australian housing mortgage flows and credit quality. Australia home loan system growth was 4.2%2 in the 12 months to end December 2018. ANZ’s Australian home loan portfolio grew 1.0% ($2.7 billion) in the same period with the Owner Occupier portfolio up 3.5% ($6.1billion) and the Investor portfolio down 3.8% ($3.2 billion). In the 12 months to the end of January 2019, ANZ’s home loan portfolio grew 0.4%.

ANZ’s home lending growth trends are attributable to lower system growth, ANZ’s preference for Owner Occupier/Principal and Interest lending which drives faster amortisation, together with policy and process changes implemented in the second half of calendar year 2018.

ANZ Chief Executive Officer Shayne Elliott said: “Consumer sentiment has remained generally subdued with uncertainty around regulation and house prices impacting confidence. While we are maintaining our focus on the Owner Occupier segment, we acknowledge we may have been overly conservative in our implementation of some policy and process changes. We are also taking steps to prudently increase volumes in the investor space”.

Switching volumes for those moving from Interest Only to Principal and Interest during the quarter was $6 billion, of which $4 billion was contractual. The total amount of contractual switching scheduled for the reminder of FY19 is $12 billion. Customers choosing to convert ahead of schedule during the first quarter was in line with the quarterly average for FY18 ($2 billion). Total switching in FY18 was $24 billion.

Protect your property portfolio as rates rise on interest-only loans

From The Australian Financial Review.

Any advantages of funding property portfolios with popular interest-only loans are rapidly disappearing as lenders hit the red alert button by raising rates, tighten terms and offer lucrative incentives to pay down debt.

Trend-setting big banks are responding to regulatory pressure by hiking rates on the loans, which are used by 70 per cent of investors, by up to 50 basis points and encouraging switches to principal and interest loans by reducing rates by about 50 basis points.

Other lenders are following the lead by requiring bigger deposits and tougher scrutiny of income.

An investor with a $3.5 million portfolio and 70 per cent loan-to-value ratio will have to find another $1500 a month in repayments, or about $18,800 a year, if interest-only repayments increase by 50 basis points, according to analysis by finder.com, which monitors prices and costs of financial products. Lenders from the big four are already paying higher rates.

The same investor on a principal and interest loan would have to pay an additional $1100 a month, or $13,200 a year, if rates rose by 50 basis points because these loans have become more attractive, says finder.com.

Traditionally loan repayments have been cheaper on interest-only loans — both because repayments don’t include principal and rates have been lower than on principal and interest loans.

Rate blow out

But moves by the big four lenders and their subsidiaries, which provide the vast bulk of loans,are changing this. During the past 12 months, for example, CBA interest-only loans have risen by more than 30 basis points to 5.94 per cent as principal and interest loans have fallen 10 per cent to 5.25 per cent. That’s based on a borrower with a $500,000 loan and 20 per cent deposit.

The average Australian property investor has two properties, says Digital Finance Analytics’ principal Martin North, with the bulk of the remainder having between three and five.

 

North says the “striking observation” about households with large numbers of investment properties is the size of their debt, preference for interest-only loans and smaller number of quality portfolios. Many “serial” investors rely on multiple lenders and rely on rental income to repay interest.

Annual rents are falling in Perth, Brisbane and Darwin by between 1 per cent and 9 per cent, according to SQM Research. They are rising in Hobart by 11 per cent, Melbourne 5 per cent and Sydney 3 per cent.

Investors with high debt and falling income, says North, are the most vulnerable to a rapid interest rate increase or a downturn in property values, which is likely to impact lower-quality properties first.

Warnings of bigger falls

Investors dumping property on to the market will trigger bigger falls, analysts warn. They are also being squeezed by recent federal budget restrictions on travel concessions for inspecting investment properties and cuts to depreciation claims for rental property furniture and fixtures.

Navid Guia has three investment houses, each with an attached granny flat — two in St Marys, 45km west of Sydney’s central business district, and one in Sacramento, in the US, close to his family.

He purchased the two- and three-bedroom Australian properties for between $249,000 and $310,000 during 2011 and 2012. The Sacramento house, which cost $117,000, was added last year.

All the properties are interest-only with a loan to value ratio of between 10 per cent and 20 per cent.

He is protecting his portfolio from rising rates and peaking prices by positive gearing, ie, income from the investments is higher than interest and other expenses.

Guia, 30, who trained as a civil engineer, says: “To me it does not make sense to buy a property and then negatively gear it. I have a cash flow from the rent that can be used for investing and buying other properties.” Negative gearing uses borrowed money for an investment whose losses can be offset against the investor’s income.

Guia says reliable, well-priced rents means he can comfortably absorb recent rate rises.

Lower interest

Other portfolio investors, such as Mario Borg, finance strategist, with Mario Borg Strategic Finance, says: “There are many home owners making interest-only home loan repayments, not realising that they could be paying a much lower interest rate if they choose to make principal and interest repayments.”

Regulators, including the Reserve Bank of Australia, are nervous about the rapid growth in interest-only loans in the absence of clear evidence borrowers have a strategy to repay the principal and have put pressure on lenders to raise rates and toughen terms.

The big fear is that static and falling incomes combined with rising rates, fewer tenants and increased supply of apartments and houses will cause widespread financial stress, which could lead to defaults, weaker consumer confidence and lower economic growth.

Fund managers, whose investment strategies can profit from volatile and falling markets, are warning high levels of personal debt could cause “Australia’s sub-prime crisis”, a reference to the US mortgage crisis that accelerated the slide into the global financial crisis.

Wayne Byres, chairman of the Australian Prudential Regulation Authority, says: “If we are going to put an increasing number of eggs into a single basket, we had better make sure that basket is an unquestionable strong one.”

Pressure on lenders

Byres has imposed an interest-only lending limit of 30 per cent of total new residential mortgage lending and is pressuring lenders to manage tightly new interest-only loans, particularly those with high loan-to-valuation ratios.

Analysts and mortgage brokers expect rates on interest-only loans to continue rapidly rising.

Christopher Foster-Ramsay, of Foster Ramsay Finance, reckons the difference between investor interest-only loans and owner-occupier principal and interest rates will blow out to 100 basis points by the end of the year.

DFA’s North says key market indicators, such as the yield curve, which reflects expectations of future returns, suggests fixed rates will rise by 50 basis points in coming months.

The need for lenders to control loan growth and wanting to deter “risky” loans will add to the pressure because stressed borrowers will have fewer options.

Falling rents or loss of tenants could jeopardise the financial viability of nearly 36,000 property investment portfolios around the country, according to North.

More than one in three portfolios with Sydney property would be at risk, he says, compared with Melbourne where one in four properties could be impacted. These are investors who would not have income or savings to pay for their property investments if rent were to stop, he says.

Investor loans to be ‘hardest hit’ by mortgage repricing

From The Adviser.

Mortgages will bear the brunt of the federal government’s new big bank tax, according to one analyst, who believes rate hikes will not be enough to prompt customers to switch lenders.

The surprise levy in Tuesday’s federal budget has widened the rift between government and the banks. All four majors have now publicly slammed the tax, which aims to raise up to $6.2 billion.

ANZ CEO Shayne Elliott labelled the tax a “regrettable policy” and said it is time for Australia’s leaders to “move on from populist bank bashing” and work together with the banking sector to support the national economy.

In a research note, Morningstar analyst David Ellis said that the increase in funding costs to the four major banks and Macquarie will be passed on to borrowers.

“This tax is on all Australian households, with residential borrowers likely to feel the bulk of the burden,” Mr Ellis said.

Morningstar considered the potential impact of further mortgage repricing on customers, who could flock to smaller banks or non-bank lenders.

“We believe the major banks’ strong competitive positions remain firmly entrenched, and collectively, the targeted banks will see little negative impact from customer migration to smaller competitors,” the analyst said.

He added: “The major banks have a long and successful history in coping with profit headwinds, particularly higher funding costs, and we see no difference this time, despite government threats of increased scrutiny on potential mortgage repricing.

“We expect mortgage rates to bear the brunt of future repricing, with interest rates on investor loans likely to be hardest hit.”

Mr Ellis explained that the pricing power of the majors is “alive and well” despite widespread media coverage to the contrary, and stressed that the big four are in no way “on their proverbial knees”.

Morningstar expects the proposed big bank levy to be passed by both houses of parliament.

Australia’s smaller banks have largely supported the initiative. ME chief executive Jamie McPhee said the levy will further “level the playing field”, which the regionals have been calling for since the Murray Inquiry was established in 2013.

“A level playing field is the best means of fostering competition, and producing good value and innovative products into the future.

“Australia’s borrowers and depositors will be the ultimate beneficiaries from a truly competitive environment.”

Morningstar’s Mr Ellis highlighted that while the tax could potentially be positive for the smaller banks, he does not expect any material change to the current competitive position of the banks.

“The changes could lead to greater competition for retail deposits as the major banks increasingly target the levy-free under $250,000 segment, thereby raising the cost of funds for the smaller banks, which are more reliant on this source of funding,” he said.

Mortgage Lending Strong in March 2017

APRA have just released their monthly banking statistics for March 2017. Overall lending by the banks (ADI’s) rose $7.1 billion to $1.54 trillion, up 0.47% or 7.5% over the past 12 months, way, way ahead of income growth!

Owner occupied  loans grew by 0.49% to $998 billion and investment loans rose 0.43% to $545 billion. No slow down yet despite the recent regulatory “tightening” and interest rate rises. Investment loans are 35.3% of all book.  Housing debt will continue to climb, a worry in a low income growth environment, and unsustainable.

In fact the rate of lending is ACCELERATING!

Looking at the banks share of loans, the big four remain in relatively similar places.

The four majors grew the fastest whilst the regional banks  lost share.

Looking at the investment loan speed limits, the majors are “comfortably” below the 10% APRA limit. Some smaller players remain above.

So, the current changes to regulatory settings are not sufficient to control loan growth. Perhaps they are relying on tighter underwriting and rising mortgage rates to clip the speed, but remember many investors are negatively geared, so rising mortgage interest costs are actually born by the tax payer! The only thing which will slow the loan growth is if home prices start to fall.

The RBA data comes out shortly, this will give a view of all lending, including the non-bank sector (though partial, and delayed).

 

APRA Reaffirms 10% Investor Loan Growth Cap

Speaking today at the A50 Australian Economic Forum in Sydney, APRA Chairman Wayne Byres reaffirmed the 10% speed limit for investor loans.

Sort of makes sense given the CBA slowing of investor loans we discussed yesterday, but 10% is, in our view too high, given current salary growth and inflation rates. This is what he said:

Let me start with a warm welcome to everyone who has travelled here to be part of this event.  A little over two hundred years ago this beautiful location was seen as an ideal place for a penal colony.  Thankfully, Sydney is no longer regarded as a hardship destination, but as someone who does a reasonable amount of international travel, I know it is still quite some distance from wherever you have journeyed from.  I hope you are finding the travel to be worth it.

A few quick words about APRA. We are Australia’s prudential regulator, responsible for the prudential oversight of deposit-taking institutions; life, general, and private health insurers; and most of Australia’s superannuation assets. All up, we have coverage of just under $6 trillion in assets, which represents around 3-and-a-half times Australian GDP.

That broad coverage of the financial sector means we inevitably have a large agenda of issues on our plate, but we also have the relative luxury of working with a financial system that is fundamentally sound. To the extent we are grappling with current issues and policy questions, they don’t reflect an impaired system that needs urgent remedial attention, but rather a desire to make the system stronger and more resilient while it is in good shape to do so.

Our mission is to achieve safety within a stable, open, efficient and competitive financial system. We don’t pursue a safety-at-all-costs strategy. But it is also pretty clear the Australian financial system has benefited over the long run from operating with fairly conservative policy and financial settings.

To give you an example, the headline capital ratios of the major  Australian banks might seem low relative to international peers – collectively, they have a CET1 ratio of a touch over 9-and-a-half per cent, whereas a more normal expectation in this day and age might be something comfortably in double digits. But the Australian ratios reflect a set of conservative policy decisions that produce a lower headline capital ratio, but give us a much greater level of confidence in the financial health of the banking system.

One result of that approach is that, even though the major Australian banks are either just inside, or just outside, the top 50 banks in the world when ranked by asset size, they are amongst the small number who have retained AA credit ratings, and we have one bank in the top 10, and the remainder in or around the top 20, when ranked by market capitalisation. Clearly, investors – both debt and equity – understand their underlying quality, and the Australian community gets great benefit from the market access that provides.

The Financial System Inquiry held a couple of years ago endorsed our approach, as did the Government in its response to the Inquiry’s recommendations.

So with that background, let me turn to a few of the important issues on our plate.

The main policy item we have on our agenda in 2017 is the first recommendation of the Financial System Inquiry: that we should set capital standards so that the capital ratios of our deposit-takers are ‘unquestionably strong.’ We have been doing quite a bit of thinking on this issue, but had held off taking action until the international work in Basel on the bank capital regime had been completed.
Unfortunately, the timetable for that Basel work now seems less certain, so it would be remiss of us to wait any longer.

We will have more to say in the coming months about how we propose to give effect to the concept of unquestionably strong, but in the meantime the banking industry has been assiduously building its capital strength in anticipation. Looking through the effects of policy changes, the major banks have added in the order of 150 basis points to their CET1 ratios over the past couple of years. Assuming the industry continues to steadily build its capital, we expect it will be well placed to respond to future policy changes in an orderly manner.

If capital for the banking system is our main policy item, then housing is our main supervisory focus. I know there is always a great deal of interest in the Australian housing market, so it is probably something I should say a few words about.

It should not be surprising we have been paying particular attention to the quality of housing portfolios for some time – and particularly the quality of new lending – given housing represents the largest asset class on the banking industry’s balance sheet.

We have lifted our supervisory intensity in a number of ways – collecting more data from lenders, putting the matter on the agenda of Boards, establishing stronger lending standards that will serve to mitigate some of the risks from the current environment, and seeking in particular to moderate the rapid growth in lending to investors. These efforts are often tagged ‘macroprudential’, but in an environment of historically low interest rates, high household debt, relatively subdued wage growth, and strong competitive pressures, we see our role – in simple terms, seeking to make sure lenders continue to make sound loans to borrowers who can afford to pay them back – as really pretty basic bank supervision.

And just to be clear about it, we are not predicting whether house prices will go up or down or sideways (as the Governor of the Reserve Bank said last night, they are doing all these things in different parts of the country), but simply seeking to make sure that bank balance sheets are well equipped to handle whatever scenarios eventuate.

As things stand today, our recent efforts have generated a moderation in investor lending, which was accelerating at double digit rates of growth but has now come back into single figures. We can also be more confident in the quality of mortgage lending decisions today relative to a few years ago.

We are not complacent, however, as recent months have seen a pick-up in the rate of new lending to investors. That pick-up in itself is not necessarily surprising – with so much construction activity being completed and the resulting settlement of purchases, some pick-up in the rate of growth might be expected. But, at least for the time being, the benchmarks that we communicated – including the 10 per cent benchmark for annual growth in investor lending – remain in place and lenders that choose to operate beyond these benchmarks are under no illusions that supervisory intervention, probably in the form of higher capital requirements, is a possible consequence. If that is encouraging them to direct their competitive instincts elsewhere, then that’s probably a good thing for the system as a whole.

I have focussed very much on banking in my remarks thus far, so before my time is up I thought I would also comment on an issue that is relevant right across the financial system: the need to continue investment in existing technology platforms while at the same time putting money into new technology which may well replace it. This conundrum exists for all firms we supervise, and the issue is going to rise in importance as time goes by.

The Australian financial sector is, on the whole, pretty quick to adapt new technology as it emerges. And we have some important new infrastructure currently being built, like the New Payments Platform that will facilitate payments 24/7. But we also face the challenge that, like many parts of the world, large parts of financial firms’ core operating platforms are still based on technology that is increasingly dated, and not as integrated as it needs to be.

Particularly with the rise of fintech and potential disruptors, the temptation in the current environment is to devote a larger proportion of any investment budget to shiny new toys at the front end that excite the customer, and perhaps defer a bit of maintenance on the back office functions that make sure the customers’ transactions actually get processed and recorded correctly. As a supervisor, we are very keen to see investment in new technology by financial firms, because we think it offers considerable benefit to the soundness, efficiency and competitiveness of the financial system. The important thing for us is to make sure investment budgets are expanding to accommodate that, and it is not simply funded by a diversion of resources from other essential tasks.

I’ll conclude here and give the floor to my other panellists. I will, of course, be happy to take any questions you might have once they have had a chance to make their remarks.

UK Regulators Worry About 17% Housing Investment Loans

The latest Financial Stability report released by the Bank of England provides insights into the UK mortgage market, and some of the concerns the regulators are addressing. Of note is the information on “Buy-to-Let” loans, or Investment Mortgage Loans. Most striking is the strong concerns expressed about the rise to 17% of all loans being for this purpose. In Australia, by comparison, 35% of housing loans are for investment purposes. We also look at household debt ratios and countercyclical buffers.

Buy-to-let mortgage lending has driven mortgage lending growth in recent years.  Seventeen per cent of the stock of total secured lending is now accounted for by buy-to-let mortgages, and the gross flow of buy-to-let lending in 2015 was close to its pre-crisis peak.

The PRA conducted a review of underwriting standards in the buy-to-let mortgage market between November 2015 and March 2016. It reviewed the lending plans of the top 31 lenders in the industry, who account for over 90% of total buy-to-let lending. A number of lenders planned to increase their gross buy-to-let lending significantly, with overall planned lending in the region of £50 billion.

UK-BuytoLetGiven competition in the sector, this strong growth profile raises the risk that firms could relax their underwriting standards in order to achieve their plans. The review further highlighted that some lenders were already applying underwriting standards that were somewhat weaker than those prevailing in the market as a whole.

The draft Supervisory Statement aims: to ensure that buy-to-let lenders adhere to a set of minimum expectations around underwriting standards; and, to prevent a marked loosening in underwriting standards. It also clarifies the regulatory capital treatment of certain buy-to-let exposures.

At its March meeting, the FPC welcomed and supported the draft Supervisory Statement. The Supervisory Statement reflects microprudential objectives, aiming to reduce the risk that buy-to-let lenders make losses that can threaten their safety and soundness. From a macroprudential perspective, policies that prevent a slippage in buy-to-let underwriting standards should also reduce the threat of buy-to-let lending amplifying wider housing market risks. The FPC discussed that, although the 200 basis points increase in buy-to-let mortgage rates was lower than the interest rate stress applied to owner-occupied lending under the FPC’s June 2014 Recommendation, lenders tended to assess affordability for buy-to-let mortgages using interest cover ratios of at least 125%. In addition, loan-to-value ratios at origination in excess of 75% were less common in buy-to-let mortgages than in owner-occupied mortgages. Buy-to-let loans therefore typically started with a larger equity cushion for lenders, which reduced the associated credit risk in the first few years of the loan given that these loans were typically non-amortising. The FPC considered that no action beyond this was warranted for macroprudential purposes at that time. It will continue to monitor developments and potential threats to financial stability from the buy-to-let mortgage market closely, and stands ready to take action.

Another piece of data in the report is the household indebtedness. Worth comparing this with the RBA chart we highlighted yesterday, where the ratio in Australia is north of 175%.

UK-DebtMore broadly, The Stability Report highlighted the risks to the UK economy, especially around Brexit. The webcast is worth listening to.

Of note is that fact that the regulators reduced the UK countercyclical capital buffer rate from 0.5% to 0% of banks’ UK exposures
with immediate effect, reflecting heightened risk and the wish to encourage banks to lend.  Australia already has a zero percent buffer.

The FPC is reducing the UK countercyclical capital buffer rate from 0.5% to 0% of banks’ UK exposures with immediate effect. Absent any material change in the outlook, and given the need to give banks the clarity necessary to facilitate their capital planning, the FPC expects to maintain a 0% UK countercyclical capital buffer rate until at least June 2017. This action reinforces the FPC’s view that all elements of the substantial capital and liquidity buffers that have been built up by banks are able to be drawn on, as necessary, to allow them to cushion shocks and maintain the provision of financial services to the real economy, including the supply of credit and support for market functioning.

It will reduce regulatory capital buffers by £5.7 billion. For a banking sector that, in aggregate, targets a leverage ratio of 4%, this raises their capacity for lending to UK households and businesses by up to £150 billion.

In March, the FPC had begun to supplement regulatory capital buffers with the UK countercyclical capital buffer. This reflected its assessment that the risks the system could face were growing and additional capital was needed that could be released quickly in the event of an adverse shock.

At that time, the FPC judged that risks associated with domestic credit were no longer subdued, as they had been in the period following the financial crisis, and global risks were heightened. The Committee raised the UK countercyclical capital buffer rate to 0.5% and signalled its expectation that it would increase it further, to 1%, if the risk level remained unchanged. As set out in this Report, a number of economic and financial risks are materialising. The FPC strongly expects that banks will continue to support the real economy, by drawing on buffers as necessary.

Consistent with the FPC’s leverage ratio framework, the countercyclical leverage ratio buffer rate will also fall.

The Committee’s decision in March to raise the UK countercyclical capital buffer rate to 0.5% was due to take effect formally from 29 March 2017. However, as the Committee explained in March, there is an overlap between the risks captured by existing PRA supervisory capital buffers and a positive UK countercyclical capital buffer rate of 0.5%. The PRA Board concluded in March 2016 that, to ensure there is no duplication in capital required to cover the same risks, existing PRA supervisory buffers of PRA-regulated firms should be reduced, as far as possible, to reflect a UK countercyclical capital buffer rate of 0.5%, when such a rate came into effect.

The FPC has therefore accompanied its decision to reduce the UK countercyclical capital buffer rate with a Recommendation to the PRA that it bring forward this planned reduction in PRA supervisory capital buffers.

Recommendation: The FPC recommends to the PRA that, where existing PRA supervisory buffers of PRA-regulated firms reflect risks that would be captured by a UK countercyclical capital buffer rate, it reduce those buffers, as far as possible and as soon as practicable, by an amount of capital which is equivalent to the effect of a UK countercyclical capital buffer rate of 0.5%.

The PRA Board has agreed to implement this Recommendation. This means that three quarters of banks, accounting for 90% of the stock of UK economy lending, will, with immediate effect, have greater flexibility to maintain their supply of credit to the real economy. Other banks will no longer see their regulatory capital buffers increase over the next nine months, increasing their capacity to lend to UK households and businesses too.

Consistent with this, the FPC supports the expectation of the PRA Board that firms do not increase dividends and other distributions as a result of this action.

Bank of England Consults On Tighter Lending Standards For Buy-To-Let

The Bank of England has released a consultation paper which seeks views on a supervisory statement which sets out the Prudential Regulation Authority’s (PRA’s) proposals regarding its expectations of minimum standards that firms should meet when underwriting buy-to-let mortgage contracts. The proposals also include clarification regarding application of the small and medium enterprises (SME) supporting factor on buy-to-let mortgages. Of note is a minimum interest rate floor of 5.5% to be used for testing repayment capacity, and tighter rules on affordability testing.

Firms should assess all buy-to-let mortgage contracts from the perspective of whether the borrower will be able to pay the sums due. The underwriting standards set out in this supervisory statement should form minimum standards, regardless of whether the borrower is an individual or a company.

To avoid existing borrowers being adversely affected when re-mortgaging, the expectations do not apply to buy-to-let remortgages where there is no additional borrowing beyond the amount currently outstanding under the existing buy-to-let contract to the firm or to a different firm. In determining the amount currently outstanding, new arrangement fees, professional fees and administration costs should be excluded.

Any reduction in buy-to-let activity and lower buy-to-let mortgage stock will lead to a reduction in short-term revenues for lenders and mortgage brokers. While affected firms may be able to recover some of the reduction in revenues by lending to owner-occupiers or other business activities in the economy, we think some more affected firms may find it difficult to recover lost revenues. Some buy-to-let investors could see an impact on their ability to obtain a buy-to-let mortgage and/or the profitability of their lending activities due to higher deposit requirements. However, affected investors may be able to find returns in other investment opportunities.

Affordability testing

Affordability tools constrain the value of the loan that a firm can extend for a given income and can reduce the probability of default on the loan particularly in an environment of rising interest rates. At higher levels of indebtedness, borrowers are more likely to encounter payment difficulties in the face of shocks to income and interest rates.

Rental income is an important factor when determining the ability of buy-to-let landlords to service their debt. Accordingly, a widespread market practice in the buy-to-let lending market is to use the mortgage’s interest coverage ratio (ICR) in assessing affordability. In addition to rental income, some borrowers use personal income to support their ability to service their debt.

The PRA is therefore proposing that all firms use an affordability test when assessing a buy-to-let mortgage contract in the form of either an ICR test; and/or an income affordability test, where firms take account of the borrower’s personal income to support the mortgage payment.

The PRA is seeking to establish a standard set of variables that should be reflected within the ICR test and the income affordability test. To ensure that firms are being prudent in their affordability assessment, the PRA is proposing that firms, among other things, give consideration to: all costs associated with renting out the property where the landlord is responsible for payment; any tax liability associated with the property; and where personal income is being used to support the rent, the borrower’s income tax, national insurance payments, credit commitments, committed expenditure, essential expenditure and living costs.

As affordability constrains the value of the loan a firm can extend, the PRA is not at this time proposing supervisory guidance with respect to specific loan-to-value (LTV) standards. However, the PRA does expect firms to have appropriate controls in place to monitor, manage and mitigate the risks of higher LTV lending.

Interest rate affordability stress test

The buy-to-let market is characterised by floating, or relatively short-term fixed mortgage rates typically on an interest-only basis. These attributes heighten the sensitivity of buy-to-let lending to changes in interest rates, which increase debt service costs.

Consequently, the PRA proposes that, when assessing affordability in respect of a potential buy-to-let borrower, firms should take account of likely future interest rate increases. In particular, the PRA proposes that the firm should consider the likely future interest rates over a minimum period of five years from the expected start of the term of the buy-to-let mortgage contract, unless the interest rate is fixed for a period of five years or more from that time, or for the duration of the buy-to-let mortgage contract if less than five years. In coming to a view of likely future interest rates, the PRA would expect firms to have regard to: market expectations; a minimum increase of 2 percentage points in buy-to-let mortgage interest rates; and any prevailing Financial Policy Committee (FPC) recommendation and/or direction on the appropriate interest rate stress tests for buy-to-let lending.

Even if the interest rate determined above indicates that the borrower’s interest rate will be less than 5.5% during the first 5 years of the buy-to-let mortgage contract, the firm should assume a minimum borrower interest rate of 5.5%.

Portfolio landlords

The PRA is seeking to establish a standard definition of what constitutes a ‘Portfolio landlord’. Under this proposal, a landlord would be considered to be a Portfolio landlord where they have four or more mortgaged buy-to-let properties across all lenders in aggregate. Data gathered by the PRA shows that there is an increase in observed arrears rates of landlords with buy-to-let portfolios of four or more mortgaged properties.

The PRA is expecting that firms conducting lending to Portfolio landlords do so according to a specialist underwriting process that accounts for the complex nature of the borrower and their portfolio of properties.

Risk management

The PRA is proposing that firms have robust risk management, systems and controls in place specifically tailored to their buy-to-let portfolios. These should include risk appetite statements governing how core risks will be identified, mitigated and managed and monitoring of portfolio concentrations and high risk segments.

The buy-to-let market is dominated by lending originated through intermediaries. There is some concern that firms with weaker underwriting standards may be adversely selected which could result in a concentration of a particular risk on individual firms’ balance sheets. Consequently, the PRA expects firms to have appropriate oversight and monitoring capabilities with respect to their intermediary business.

The SME supporting factor in relation to buy-to-let mortgages

The PRA proposes to enhance the transparency and consistency of the PRA’s regulatory approach by clarifying the PRA’s expectations in relation to application of the SME supporting factor on buy-to-let mortgages.

Under Article 501 of the CRR the SME supporting factor is used to reduce by approximately 24% the capital requirements on loans to SMEs on qualifying retail, corporate and real estate exposures. The PRA does not consider that buy-to-let borrowing falls within the objective of the SME supporting factor described in Article 501 CRR. The PRA proposes to clarify in the supervisory statement that it expects firms to consider the intended purpose of a loan before applying the SME supporting factor. The SME supporting factor should not be applied where the purpose of the borrowing is to support buy-to-let business. The PRA would expect firms to comply with the spirit and intent of this statement.

BIS Capital Proposals Revised Again, LVR’s and Investment Loans Significantly Impacted

The second consultative document on Revisions to the Standardised Approach for credit risk has been released for discussion.

There are a number of significant changes to residential property risk calculations . These guidelines will eventually become part of “Basel III/IV”, and will apply to banks not using their internal assessments (which are also being reviewed separately).

First, risk will be assessed by loan to value ratios, with higher LVR’s having higher risk weights. Second, investment property will have a separate a higher set of LVR related risk-weights. Third, debt servicing ratios will not directly be used for risk weights, but will still figure in the underwriting assessments.

There are also tweaks to loans to SME’s.

These proposals differ in several ways from an initial set of proposals published by the Committee in December 2014. That earlier proposal set out an approach that removed all references to external credit ratings and assigned risk weights based on a limited number of alternative risk drivers. Respondents to the first consultative document expressed concerns, suggesting that the complete removal of references to ratings was unnecessary and undesirable. The Committee has decided to reintroduce the use of ratings, in a non-mechanistic manner, for exposures to banks and corporates. The revised proposal also includes alternative approaches for jurisdictions that do not allow the use of external ratings for regulatory purposes.

The proposed risk weighting of real estate loans has also been modified, with the loan-to-value ratio as the main risk driver. The Committee has decided not to use a debt service coverage ratio as a risk driver given the challenges of defining and calibrating a global measure that can be consistently applied across jurisdictions. The Committee instead proposes requiring the assessment of a borrower’s ability to pay as a key underwriting criterion. It also proposes to categorise all exposures related to real estate, including specialised lending exposures, under the same asset class, and apply higher risk weights to real estate exposures where repayment is materially dependent on the cash flows generated by the property securing the exposure.

This consultative document also includes proposals for exposures to multilateral development banks, retail and defaulted exposures, and off-balance sheet items.The credit risk standardised approach treatment for sovereigns, central banks and public sector entities are not within the scope of these proposals. The Committee is considering these exposures as part of a broader and holistic review of sovereign-related risks.

Comments on the proposals should be made by Friday 11 March 2016.

Looking in more detail at the property-related proposals, the following risk weights will be applied to loans against real property:

  • which are finished properties
  • covered by a legal mortgage
  • with a valid claim over the property in case of default
  • where the borrower has proven ability to repay – including defined DSR’s
  • with a prudent valuation (and in a falling market, a revised valuation), to derive a valid LVR
  • all documentation held

If all criteria a met the following risk weights are proposed.

BIS-Dec-12-01For residential real estate exposures to individuals with an LTV ratio higher than 100% the risk weight applied will be 75%. For residential real estate exposures to SMEs with an LTV ratio higher than 100% the risk weight applied will be 85%. If criteria are not met, then 150% will apply.

Turning to investment property, where cash flow from the property is the primary source of income to service the loan

BIS-Sec-12-02Commercial property will have different ratios, based on counter party risk weight.

BIS-Dec-12-03 But again, those properties serviced by cash flow have higher weightings.

BIS-Dec-15-04Development projects will be rated at 150%.

Bearing in mind that residential property today has a standard weight of 35%, it is clear that more capital will be required for high LVR and investment loans. As a result, if these proposals were to be adopted, then borrowers can expect to pay more for investment loans, and higher LVR loans.

It will also increase the burden of compliance on banks, and this will  likely increase underwriting costs. Finally, whilst ongoing data on DSR will not be required, there is still a need to market-to-market in a falling market to ensure the LVR’s are up to date. This means, that if property valuations fall significantly, higher risk weights will start to apply, the further they fall, the larger the risk weights.

Finally, it continues the divergence between the relative risks of investment and owner occupied loans, the former demanding more capital, thus increasing the differential pricing of investment loans.

The Committee notes that the SA is a global minimum standard and that it is not possible to take into account all national characteristics in a simple approach. As such, national supervisors should require a more conservative treatment if they consider it necessary to reflect jurisdictional specificities. Furthermore, the SA is a methodology for calculating minimum risk-based capital requirements and should in no way be seen as a substitute for prudent risk management by banks.

Now, some will argue that in Australia, this will not impact the market much, as the major banks use their own internal models, however, as these are under review (with the intent of closing the gap somewhat with the standard methods used by the smaller players) expect the standard models to inform potential changes in the IRB set. Also, it is not clear yet whether banks who use lenders mortgage insurance for loans above 80% will be protected from the higher capital bands, though we suspect they may not. Non-bank lenders may well benefit as they are not caught by the rules, although capital market pricing may well change, and impact them at a second order level. We will be interested to see how local regulators handle the situation where an investment loan is partly serviced by income from rentals, and partly from direct income, which rules should apply – how will “materially dependent” be interpreted?

 

ADI Data July 2015 – Investment Loans Grow Again – However…

APRA released their monthly banking stats for ADI’s to end July 2015 today. Looking in detail at the data, we start with home loans. Total ADI loan portfolios grew in the month by 0.4% to $1.37 trillion. The RBA data, already discussed gave a total growth of 0.6% to $1.48 trillion, so this suggests the non-banking sector is growing faster than ADIs. There are lags in the non-bank data streams, so we need to watch future trends carefully.  Investment lending grew more than 11% in the past 12 months.

Looking at the mix between owner occupied and investment home lending, we see that owner occupied loans were static, ($827,905, compared with $827,700 in July), whilst investment loans grew (from $827,905 to $827,700 million) with a rise of $5,799 million, or 1.1%. However, we think the data is corrupted by further restatements of loans as they are reclassified between owner occupied and investment categories.

Looking at the lender data, we start with the all important year on year portfolio movements. Depending on how you calculate this (sum of each month movement, last 3 month annualised, etc) you can make the number move around. We have adopted a simple approach. We sum the portfolio movement each month for 12 months. This gives a market growth average for the year of 11.46%. We also see that many banks – including some of the majors, are still well above the speed limit of 10%. Regulatory pressure does not seem to be having much impact, despite the rhetoric, and repricing. Our thesis appears proven.

MBSJuly2014InvPortfolioMovementsFor completeness, we show the same picture for owner occupied loans – though there is of course no formal speed limit as we think currently competitive action is focussed here.

MBSJuly2014OOPortfolioJulyTurning to the portfolio movements, we see a significant swing at Westpac – we suspect a restatement of loans – but have not found any announcements on this so far. Logically, a $3bn lift in investment lending is too significant to be normal market behaviour, in our opinion. We have factored in the restatements at NAB and ANZ.

MBSJuly2014HomeLenidngMovementsThe relative market share analysis shows that Westpac has the largest investment portfolio, whilst CBA has the largest owner occupied loan portfolio.

MBSJuly2014HomeLendingSharesIt is also worth looking at the relative percentage splits between owner occupied and investment loans by bank. Westpac and Bank of Queensland have the largest relative proportions, so are under more pressure from the 10% question.

MBSJuly2014HomeLendingSplitsIn the credit card portfolio, total balances were up 1% from $40.4 billion to $40.8 billion. We see small movements in relative share, with CBA loosing a little whilst Westpac and Citigroup grew share slightly.

MBSJuly2015CardsFinally, on deposits, we see three of the majors growing their portfolio, with NAB showing the largest inflow.  Total balances grew from $1.83 billion to 1.86 billion, of 1.27%.

MBSJuly2015DepositMovementsRelative deposit share changed just slightly as a result.

MBSJuly2015DepostShares

NAB Ups Value of Investment Loans Held

NAB has announced a reclassification of household data provided previously as part of its regulatory reporting obligations. The reclassification, similar to the recent ANZ announcement, has no impact on customers and does not alter risk weighted assets, regulatory capital, cash earnings, balance sheet or risk appetite. The announcement was released to the ASX, not via the NAB web site or media releases.

The data being restated covers the period from July 2014 to June 2015. The main movements are:

  • Restatement of owner occupied housing from $165.4bn to 126.5bn
  • Restatement of investment housing from $66.6bn to $93bn
  • Restatement of non-housing from $11.5bn to $23.7bn

We have run an update to our APRA loan model which shows that the market for investment loans grew at a revised 11.16% (compared with the APRA 10% “speed limit”) and we estimate that NAB grew its investment portfolio by 13.79%, well above the hurdle.

NAB-Adjusted-Investment-LoansThese reporting adjustments make us question the accuracy of the reporting processes. We would observe that as a result of the banks adjustments the value of investment loans are higher, but the growth trajectory is similar to previously calculated, provided the one-off adjustments are run back through the full year.