Mortgage Underwriting – Page 9 – Digital Finance Analytics (DFA) Blog

New APRA guidance on lending will hurt home owners when it should be the banks

The Australian Prudential Regulation Authority (APRA) has moved away from its non-prescriptive “principles based” regulatory approach to a one size fits all explicit guidance but it doesn’t appear to be encouraging lenders to be more prudent.

The housing market may be getting away from APRA and the Reserve Bank of Australia (RBA). In late 2015, both regulators voiced concerns about the “horribly low” standards of the mortgage lending sector and the risks to financial stability. Even bankers are getting jittery.

There has also been well-publicised problems with brokers originating dodgy mortgages that lenders have not picked up. In its existing guidance (which has not been changed in the latest version), APRA requires lenders to have all sorts of procedures to catch dodgy mortgage applications from brokers including procedures to verify the accuracy and completeness of provided information.

But APRA has not named and shamed the lenders who failed to catch dodgy mortgage applications, not imposed capital sanctions or reprimanded directors and management. It hasn’t required that lenders change their broker process.

What APRA is asking is that banks slug first time buyers even more. In the new rules, home buyers are now required to prove they can service a 7% mortgage interest rate on a loan to value ratio of less than 90% with less income being taken into account. This is on top of trying to save a deposit that is disappearing every day as house prices boom.

It is going to take a lot more than forgoing a few smashed avocado toasts to make up for the additional burden imposed by APRA.

There are a few important questions raised by APRA’s sudden conversion to pragmatic rather than purely principled regulation.

First, the numbers. Where did the 7% come from? APRA doesn’t disclose this, but in an era of almost zero interest rates, it’s big. And maybe in time, when the RBA announces its changes to interest rates, the 7% may be changed in-line and economists will begin to bet on whether it will go to 6.5% or 7.5%.

In looking at a borrower’s income, APRA notes that it is “prudent practice is to apply discounts of at least 20% on most types of non-salary income”. No explanation also on why this particular percent. It’s also not specific on what “most” means.

If banks are indeed lending imprudently surely the banks themselves should suffer. First by naming and shaming, then if necessary, requiring additional capital buffers, thus driving down dividends – a real market based solution.

APRA is changing the way it regulates

Throughout the turmoil of the global financial crisis and the regulatory mayhem that followed, APRA held fast to its “principles based” approach to regulation:

To be principles-based is to give emphasis to the achievement of sound prudential outcomes in setting regulatory requirements and expectations, without necessarily seeking to specify or prescribe the exact manner in which those outcomes must be achieved

In short, APRA lays out the high-level principles that it will use to supervise the banks and insurance companies that is responsible for, and then will check that those principles are being adhered to. It did not believe in a “one size fits all” approach.

But this week, there appears to have been a back-flip. In a consultation paper for an update to APRA’s guidance on mortgage lending, the regulator has been very specific indeed. It notes:

“Prudent serviceability policies should incorporate a minimum floor assessment interest rate of at least seven per cent.”

This very specific guidance replaces an earlier guidance that was more general. From a regulatory perspective, an important question is why abandon principles-based regulation? If it hasn’t worked in the past, then a rethink of the role and approach of prudential regulation is needed.

This has happened overseas, where the UK Financial Conduct Authority, while retaining 11 principles that firms should adhere to, has become much more intrusive. Unlike our regulators, the authority has even going so far as to impose massive fines for misconduct. It states:

“We also adopt a markets-focused approach to regulation, both in our work as a competition regulator and more broadly to deliver regulation that works with the market to improve consumer outcomes. Interventions at the market level are an effective and powerful way of tackling and mitigating problems across a large number of firms, which in turn benefits a large number of consumers.”

Rather than APRA slipping in such a major change like this latest one into a consultation paper, it might be appropriate to have a transparent debate about such a potentially significant change in prudential regulation in Australia.

Author: Pat McConnell, Honorary Fellow, Macquarie University Applied Finance Centre, Macquarie University

Risks within the housing and residential development markets remain elevated – APRA

APRA Chairman, Wayne Byres in his Opening statement to the Senate Economics Legislation Committee highlighted again the regulators views that there are elevated risks in the housing sector, despite tightening of underwriting rules in the past year. They are looking at additional ways to embed better and sticky lending standards into the banks. Some would say better late than never!

Our supervisory work on housing lending standards continues. Given the environment of heightened risks, our objective has been to reinforce sound lending standards, particularly in relation to the manner in which lenders assess the capacity of borrowers to service their loans. Over the past year, we believe the industry has appreciably improved its lending standards. But risks within the housing and residential development markets remain elevated. We are therefore giving thought to how best to have improved standards firmly embedded into industry practice, such that they are not eroded away again over time.

He also discussed the risk culture information paper which we featured yesterday.

Earlier this week, APRA published an information paper on risk culture – a topic that we have given greater attention to over the past few years. The paper focusses, amongst other things, on how Boards of regulated institutions have gone about the task of assessing the risk culture within their organisations, given the introduction of specific prudential requirements in this area from January 2015. Assessing risk culture is no easy task. But, as the global financial crisis showed, if an organisation has a poor attitude to risk-taking and risk management, it can ultimately threaten an institution’s financial viability. So one of our key messages is the need for continued investment of time and attention by senior leaders on this issue.Just as regulated institutions will refine and improve their own practices, we will continue to refine our approach and methodologies for making assessments of risk culture within regulated institutions. We will also, in particular, be looking more closely at the influence of remuneration arrangements on that culture.

As the Committee knows well, there have been some serious allegations of inappropriate and unfair treatment of life insurance claimants by The Colonial Mutual Life Assurance Society Limited, trading as CommInsure. While ASIC has been dealing with the specific customer cases, APRA takes an interest in what these cases tell us about the strength of an institution’s governance, risk management and risk culture.Our work with CommInsure has targeted two main issues. First, APRA has engaged with the Board and senior management of CommInsure to gain assurance over the robustness and completeness of the independent reviews commissioned to investigate the allegations, and ensure to stakeholder and community expectations are considered through this process. We have also met with the whistleblower who brought the issues to light, and are considering whether the whistleblowing provisions in the Life Insurance Act designed to prevent the identification and victimisation of whistleblowers have been adhered to.

Earlier this year, APRA also wrote to the Boards of all active life insurers, as well as to a selection of superannuation trustees, seeking information on the effectiveness of their governance and oversight mechanisms for matters such as claims handling, benefit definitions, rejected claims and customer complaints. Based on the responses received, we issued a report last week identifying areas in which insurers and trustees can improve their management of life insurance claims.

APRA and ASIC have been working closely on all of these matters, which remain ongoing.

Canada Mortgage Rules a Step Toward Cooling Home Prices

Fitch Ratings says new Canadian Department of Finance mortgage rules to reduce speculation in residential real estate are a step toward cooling the housing market in major cities including Toronto and Vancouver. The new rules could result in improved credit quality in certain residential covered bond programs.

The rules include applying an interest rate stress test for all insured mortgages starting on October 17; previously, this was only required for homebuyers with a down payment of less than 20% of the home purchase price or for mortgages of less than five years. Tightened mortgage insurance eligibility requirements for “low-ratio” mortgages – mortgages for less than 80% of a home’s purchase price – will also be applied from Nov. 30. The government has also proposed to no longer exempt non-residents from paying capital gains taxes on income from selling a property.

Fitch believes that the new measures may temper the housing market, especially in cities that are significantly overvalued. According to a Fitch study published earlier this year, home prices across Canada are estimated to be about 25% above their sustainable value with major regional variations.

The income tax rule change in particular should reduce housing demand from foreigners. In Vancouver, this will reinforce the effects of the 15% tax on foreign home purchases put in place by the British Columbia government in August. Data from the Real Estate Board of Greater Vancouver indicate that average sale prices of detached houses have already dropped by roughly 16%, led by higher priced properties.

The new mortgage insurance guidelines could improve portfolio credit quality in the Canadian registered covered bond programs. While insured mortgage loans are prohibited from securing this subsector of the covered bond market, changes to insured mortgage loan underwriting requirements could influence non-insured mortgage loan underwriting requirements. Any tightening of non-insured mortgage loan underwriting requirements would further help to cool the housing market and also help to address the concern of heightened borrower leverage.

Canadian Banks To Hold More Mortgage Loan Risk

Moody’s says Canada’s Department of Finance announced that it will launch a consultation process with market participants this fall on lender risk sharing, a policy that would require mortgage lenders to absorb a portion of loan losses on insured mortgages that default. Currently, banks are able to transfer virtually all of the risk of insured mortgages to mortgage insurers, and indirectly to taxpayers through a government guarantee.

Any changes to the provisions of mortgage insurance to impose risk sharing on mortgage lenders would be credit negative for Canada’s six large banks, which account for approximately 72% of mortgage lending in the country, because it would reduce their asset quality and risk-adjusted profitability. The six banks are The Toronto-Dominion Bank, Bank of Montreal, Bank of Nova Scotia, Canadian Imperial Bank of Commerce, Royal Bank of Canada and National Bank of Canada.

The details of the Department of Finance’s plan have yet to be released, and it may be some time before they emerge. Possible approaches include imposing first-loss deductibles on banks, whereby the lender would be responsible for an initial portion of the loss, with the insurer only bearing losses beyond that deductible amount. Another option would be to divide losses between the lender and insurer on a pro rata basis, or to charge the lender a fee for a defaulted mortgage. In any case, the concept of the lender retaining some risk on insured mortgages will support stability in the housing market in Canada by encouraging prudent underwriting standards.

Canadian banks’ high asset quality is largely the result of their significant holdings of government-insured residential mortgages, uninsured mortgages, securities, cash and deposits with financial institutions, which comprise about half the aggregate system’s balance sheet. Canadian mortgage portfolios and home equity lines of credit have performed well historically, owing to the high use (approximately 50%) of government backed mortgage insurance, and conservative underwriting practices. Government-supported insured mortgages make up 12% of total assets. This insurance is primarily sold either directly to the borrower, who is legally required under Canada’s Bank Act to obtain insurance if the loan-to-value of the mortgage exceeds 80%, or is held by the lenders themselves on a portfolio basis as a liquidity and capital management tool.

Canadian banks currently make a solid margin on insured mortgages for which they bear no risk and have no regulatory capital requirements. Under any risk-sharing arrangement, depending on the degree of loss shared and any offsetting concession on insurance premiums paid, profitability on a significant asset class will change. On balance, we expect that risk-adjusted profitability will decline, although a detailed analysis at this point is not possible.

Lending changes make property more attractive for SME owners

From Australian Broker.

Lending changes by Australia’s major banks could soon result in a surge of property purchases by small and medium-sized enterprise (SME) owners.

Westpac this week announced they would increase their loan to value ratio (LVR) from 80% to 90% of a property’s value self-employed borrowers after the Commonwealth Bank announced similar changes earlier this year.

The last 12 months have also seen Westpac, CBA and St. George announce they would only require one year of financial records as income verification for self-employed borrowers. Previously they had required two years of financial records and tax returns.

Joel Wyld, director of mortgage broker Peasy, said the lending changes indicate lenders’ perceptions of SME borrowers are evolving.

“In the past banks have viewed the SME demographic as risky despite many owners coming from strong corporate or trades backgrounds with a long successful working history in addition to strong equity in various investment classes,” Wyld said.

“In the past, many SME owners have had to settle for low doc loans for a two year period which has deterred them from purchasing property,” he said.

While some of the lending changes have been in force for some time, Wyld said a large number of SME owners are unaware of the more lenient lending criteria and with more than two million SME owners across Australia it could provide brokers with an excellent opportunity to extend their client base.

“The time is now ripe for SME owners to capitalise on the new lending rules to secure either a dream home or business premises,” he said.

“The number one piece of advice given to SME owners when applying for a property loan is to ensure financials are up-to-date. Inaccuracies in financial records and book keeping will delay the settlement process and could ultimately determine if the loan application is accepted or declined.”

Wyld said there has also been a growing trend towards establishing property trusts and partnerships using property as vehicle for SME owners, though he said while those structures have a place in the market, brokers need to be careful when assessing income of a business if multiple owners are involved and should recommend those involved seek legal advice.