Prudential perspectives on the property market

Wayne Byers APRA  Chairman spoke at  CEDA’s 2017 NSW Property Market Outlook in Sydney  today.  Of note, he explains the reason why the 10% investor speed limit was not reduced, because of the potential impact on commercial propery construction!

My remarks today come, unsurprisingly, from a prudential perspective. Property prices and yields, planning rules, the role of foreign purchasers, supply constraints, and taxation arrangements are all important elements of any discussion on property market conditions, and I’m sure the other speakers today will touch on most of those issues in some shape or form. But I’ll focus on APRA’s key objective when it comes to property: making sure that standards for property lending are prudent, particularly in an environment of heightened risk.

Sound lending standards

Our recent activity in relation to residential and commercial property lending has been directed at ensuring banking institutions maintain sound lending standards. Our ultimate goal is to protect bank depositors – it is, after all, ultimately their money that banks are lending. Basic banking – accepting money from depositors and lending to sound borrowers who have good prospects of repaying their loans – is what it’s all about. Of course, banking is about risk-taking and it is inevitable that not every loan will be fully repaid, but with appropriate lending standards and sufficient diversification, the risk of losses that jeopardise the financial health of a bank – and therefore the security offered to depositors – can be reduced to a significant degree. The banking system is heavily exposed to the inevitable cycles in property markets, and our goal is to seek to make sure the system can readily withstand those cycles without undue stress.

Our mandate goes no further than that. We also have to take many influences on the property market – tax policy, interest rates, planning laws, foreign investment rules – as a given. And there are credit providers beyond APRA’s remit, so a tightening in one credit channel may just see the business flow to other providers anyway. For those reasons, there are clear limits on the influence we have. Property prices are driven by a range of local and global factors that are well beyond our control: whether prices go up or go down, we are, like King Canute, unable to hold back the tide.

Of course, that is not to ignore the fact that one determinant of property market conditions is access to credit. We acknowledge that in influencing the price and availability of credit, we do have an impact on real activity – and this may feed through to asset prices in a range of ways. But I want to emphasise that we are not setting out to control prices. Property prices will go up and they will go down (even for Sydney residential property!). It is not our job to stop them doing either of those things. Rather, our goal is to make sure that whichever way prices are moving at any particular point in time in any particular location, prudentially-regulated lenders are alert to the property cycle and making sound lending decisions. That is the best way to safeguard bank depositors and the stability of the financial system.

Residential property lending

APRA has been ratcheting up the intensity of its supervision of residential property lending over the past five or so years. Initially, this involved some fairly typical supervisory measures:

  • in 2011 and again in 2014, we sought assurances from the Boards of the larger lenders that they were actively monitoring their housing lending portfolios and credit standards;
  • in 2013, we commenced more detailed information collections on a range of housing loan risk metrics;
  • in 2014, we stress-tested around the largest lenders against scenarios involving a significant housing market downturn;
  • also in 2014, we issued a Prudential Practice Guide on sound risk management practices for residential mortgage lending; and
  • we have conducted numerous hypothetical borrower exercises to assess differences in lending standards between lenders, and changes over time.

These steps are typical of the role of a prudential supervisor: focusing on the strength of the governance, risk management and financial resources supporting whatever line of business is being pursued, without being too prescriptive on how that business should be undertaken.

But from the end of 2014, we stepped into some relatively new territory by defining specific lending benchmarks, and making clear that lenders that exceeded those benchmarks risked incurring higher capital requirements to compensate for their higher risk. In particular, we established quantitative benchmarks for investor lending growth (10 per cent), and interest rate buffers within serviceability assessments (the higher of 7 per cent, or 2 per cent over the loan product rate), as a means of reversing a decline in lending standards that competition for growth and market share had generated.

I regard these recent measures as unusual, and not reflective of our preferred modus operandi. We came to the view, however, that the higher-than-normal prescription was warranted in the environment of high house prices, high household debt, low interest rates, low income growth and strong competitive pressures.  In such an environment, it is easy for borrowers to build up debt. Unfortunately, it is much harder to pay that debt back down when the environment changes. So re-establishing a sound foundation in lending standards was a sensible investment.

Since we introduced these measures in late 2014, investor lending has slowed and serviceability assessments have strengthened. But at the same time, housing prices and debt have got higher, official interest rates have fallen further and wage growth remains subdued. So we recently added an additional benchmark on the share of new lending that is occurring on an interest-only basis (30 per cent) to further reduce vulnerabilities in the system.

Each of these measures has been a tactical response to evolving conditions, designed to improve the resilience of bank balance sheets in the face of forces that might otherwise weaken them. We will monitor their effectiveness over time, and can do more or less as need be. We have also flagged that, at a more strategic level, we intend to review capital requirements for mortgage lending as part of our work on establishing ‘unquestionably strong’ capital standards, as recommended by the Financial System Inquiry (FSI).

Looking at the impact so far, I have already noted that our earlier measures have helped slow the growth in investor lending (Chart 1), and lift the quality of new lending. Serviceability tests have strengthened, although as one would expect in a diverse market there are still a range of practices, ranging from the quite conservative to the less so. Lenders subject to APRA’s oversight have increasingly eschewed higher risk business (often by reducing maximum loan-to-valuation ratios (Chart 2)), or charged a higher price for it.

For example, there is now a clear price differential between lending to owner-occupiers on a principal and interest basis, and lending to investors on an interest-only basis (Chart 3). And as a result of our most recent guidance to lenders, we expect some further tightening to occur.

Looked at more broadly, the most important impact has been to reduce the competitive pressure to loosen lending standards as a means of chasing market share. We are not seeking to interfere in the ability of lenders to compete on price, service standards or other aspects of the customer experience. We do, however, want to reduce the unfortunate tendency of lenders, lulled by a long period of buoyant conditions, to compete away basic underwriting standards.

Of course, lenders not regulated by APRA will still provide competitive tension in that area and it is likely that some business, particularly in the higher risk categories, will flow to these providers. That is why we also cautioned lenders who provide warehouse facilities to make sure that the business they are funding through these facilities was not growing at a materially faster rate than the lender’s own housing loan portfolio, and that lending standards for loans held within warehouses was not of a materially lower quality than would be consistent with industry-wide sound practices. We don’t want the risks we are seeking to dampen coming onto bank balance sheets through the back door.

Commercial real estate lending

For all of the current focus on residential property lending, it has been cycles in commercial real estate (CRE) that have traditionally been the cause of stress in the banking system. So we are always quite interested in trends and standards in this area of lending. And tighter conditions for residential lending will also impact on lenders’ funding of residential construction portfolios – we need to be alert to the inter-relationships between the two.

Overall, lending for commercial real estate remains a material concentration of the Australian banking system. But while commercial lending exposures of APRA-regulated lenders continue to grow in absolute terms, they have declined relative to the banking system’s capital (partly reflecting the expansion in the system’s capital base). Exposures are now well down from pre-GFC levels as a proportion of capital, albeit much of the reduction was in the immediate post-crisis years and, more recently, the relative position has been fairly steady (Chart 4).

The story has been broadly similar in most sub-portfolios, with the notable exception of land and residential development exposures (Chart 5).

These have grown strongly as the banking industry has funded the significant new construction activity that has been occurring, particularly in the capital cities of Australia’s eastern seaboard. At the end of 2015, these exposures were growing extremely rapidly at just on 30 per cent per annum, but have since slowed significantly as newer projects are now being funded at little more than the rate at which existing projects roll off (Chart 6).

(As an aside, this is one reason why we opted not to reduce the 10 per cent investor lending benchmark for residential lending recently. There is a fairly large pipeline of residential construction to be absorbed over the course of 2017, and there is little to be gained from unduly constricting that at this point in time.)

In response to the generally low interest rate environment, coupled with relatively high price growth in some parts of the commercial market, low capitalisation rates and indications that underwriting standards were under competitive pressure, we undertook a thematic review of commercial property lending over 2016. We looked at the portfolio controls and underwriting standards of a number of larger domestic banks, as well as foreign bank branches which have been picking up market share and growing their commercial real estate lending well above system growth rates.

The review found that major lenders were well aware of the need to monitor commercial property lending closely, and the need to stay attuned to current and prospective market conditions. But the review also found clear evidence of an erosion of standards due to competitive pressures – for example, of lenders justifying a particular underwriting decision not on their own risk appetite and policies, but based on what they understood to be the criteria being applied by a competitor. We were also keen to see genuine scrutiny and challenge that aspirations of growth in commercial property lending were achievable, given the position in the credit cycle, without compromising the quality of lending. This was often being hampered by inadequate data, poor monitoring and incomplete portfolio controls. Lenders have been tasked to improve their capabilities in this regard.

Given the more heterogeneous nature of commercial property lending, it is more difficult to implement the sorts of benchmarks that we have applied to residential lending. But that should not be read to imply we have any less interest in the quality of commercial property lending. Our workplan certainly has further investigation of commercial property lending standards in 2017, and we will keep the need for additional guidance material under consideration.

Concluding remarks

So to sum up, property exposures – both residential and commercial – will remain a key area of focus for APRA for the foreseeable future. Sound lending standards are vital for the stability and safety of the Australian banking system, and given the high proportion of both residential mortgage and commercial property lending in loan portfolios, there will be no let up in the intensity of APRA’s scrutiny in the foreseeable future. But despite the fact the merit of our actions are often assessed based on their expected impact on prices, that is not our goal. Prudence (not prices) is our catch cry: our objective is to make ensure that, whatever the next stage of the property cycle may bring, the balance sheet of the banking system is resilient to it.

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 releases final revised Prudential Practice Guide APG 120 Securitisation

APRA has released the final revised Prudential Practice Guide APG 120 Securitisation (APG 120) in response to feedback from industry submissions.

Whilst the final changes may appear technical, they do provide more latitude to securitisers than originally envisaged.

The final revised APG 120 will have effect from 1 January 2018.

In November 2016, APRA released the final revised Prudential Standard APS 120 Securitisation (APS 120) (effective 1 January 2018). APRA also released for consultation a draft revised APG 120.

APRA received two submissions in response to the draft revised APG 120. APRA’s responses to the key matters raised are set out below.

Derivatives transactions

The final revised APS 120 requires ADI swap providers in securitisation schemes to be senior in the cash flow waterfall. The draft revised APG 120 clarifies that this ranking includes where the ADI is a defaulting party under the swap, and for uncollected break costs.

Comments received

Both submissions commented that requiring ADI swap providers to be senior where the ADI is a defaulting party under the swap, and for uncollected break costs, may increase the overall costs of securitisations and reduce the number of swap counterparties that provide swaps to securitisations.

APRA response

APRA has reconsidered this position and has clarified in the final revised APG 120 that swaps may be treated as senior ranking for regulatory capital purposes where the ADI is a defaulting party under the swap, and for uncollected break costs. APRA recognises that default of an ADI swap provider would not necessarily relate to the performance of the underlying exposures. In the case of uncollected break costs, these amounts are at the discretion of the ADI and therefore certainty of cashflow to the securitisation trust, for these amounts, is not assured.

Shared collateral and trust-back agreements

Under the final revised APS 120, trust-back loans (non-securitised loans) are ineligible for risk weights of less than 100 per cent, unless the ADI has a formal second mortgage in regard to the securitised loans used as collateral.

Comments received

Both submissions reiterated that the requirement for an ADI to obtain a formal second mortgage in these circumstances is operationally burdensome and impractical. Both submissions asserted that trust-back agreements are structured to legally operate so as to afford equivalent rights to a formal second mortgage.

APRA response

In light of industry comments, including the operational burden of obtaining formal second mortgages and that shared collateral agreements can be constructed to legally operate so as to afford equivalent rights, APRA has clarified in the final revised APG 120 that, subject to certain conditions, a shared collateral agreement may be considered equivalent to a formal second mortgage for the purposes of APS 120 only.

Warehouse arrangements

The draft revised APG 120 provides some flexibility for originating ADIs to agree a new funding rate to extend a warehouse funding line, provided no other terms and conditions of the securitisation are amended.

Comments received

Both submissions commented that additional flexibility to change the terms and conditions of a warehouse, including credit enhancement and subordination levels and pool parameters, should be permitted for both capital relief and funding-only warehouses.

Both submissions also requested that existing warehouses ineligible for regulatory capital relief should be permitted to be amended prior to 1 January 2018 to minimise increases in regulatory capital requirements under the final revised APS 120. In the absence of this flexibility, the originating ADI may incur substantially higher funding costs.

APRA response

With the exception of self-securitisations, the final revised APS 120 prohibits an ADI from increasing a first loss position or providing a credit enhancement after the inception of a transaction. APRA considers additional flexibility to change the terms and conditions of a warehouse contrary to this requirement.

However, for existing warehouses ineligible for regulatory capital relief, APRA is prepared as a transitional measure to allow ADIs some flexibility to restructure the terms and conditions of these securitisations, provided this occurs by 1 January 2018. APRA supervisors will be in contact with ADIs with respect to any plans to utilise these transitional arrangements.

Basel III Status Update – Where Australia Stands

The Basel Committee on Banking Supervision has today issued the Twelfth progress report on adoption of the Basel regulatory frameworkThis included a status summary for Australian Banks and shows that there are substantial steps to be taken to complete the current implementation, yet alone responding to the APRA-led proposals for further capital reform, which we expect to be the result of a discussion paper expected later in the year.

The complexity of the Basel capital frameworks continues to grow.

This report sets out the adoption status of Basel III standards for each BCBS member jurisdiction as of end-March 2017. It updates the Committee’s previous progress reports which have been published on a semiannual basis since October 2011 under the Committee’s Regulatory Consistency Assessment Programme (RCAP).

The report shows that:

  • all 27 member jurisdictions have final risk-based capital rules, LCR regulations and capital conservation buffers in force;
  • 26 member jurisdictions have issued final rules for the countercyclical capital buffers;
  • 25 have issued final or draft rules for domestic systemically important banks (D-SIBs) frameworks and, with regards to the global systemically important banks (G-SIBs) framework, all members that are home jurisdictions to G-SIBs have final rules in force;
  • 20 have issued final or draft rules for margin requirements for non-centrally cleared derivatives.

Further, while some members have reported challenges in implementing the following standards for which the implementation dates have now passed, the report shows that:

  • 21 member jurisdictions have issued final or draft rules of the revised Pillar 3 framework;
  • 19 have issued final or draft rules of the SA-CCR and capital requirements for equity investments in funds;
  • 17 have issued final or draft rules of capital requirements for CCP exposures.

Member jurisdictions are now turning to the implementation of other Basel III standards, including those on TLAC holdings, the market risk framework, the leverage ratio and the net stable funding ratio.

The Basel III framework builds on and enhances the regulatory framework set out under Basel II and Basel 2.5. The attached table is designed to monitor the adoption progress of all Basel III standards, which will come into effect by 2019. The monitoring table no longer includes the reporting columns for Basel II and 2.5, nor those Basel III standards that have been implemented by all BCBS members (definition of capital, capital conservation buffer and liquidity coverage ratio).

  • The following aspects of the risk-based capital standards are still being implemented:
    o Countercyclical buffer: The countercyclical buffer is phased in parallel to the capital conservation buffer between 1 January 2016 and year-end 2018, becoming fully effective on 1 January 2019.
    o TLAC holdings: The TLAC holdings standard was issued by the Committee in October 2016. It applies to all banks and describes the prudential treatment for holdings of instruments that comprise TLAC for the issuing G-SIB. The standard will take effect from 1 January 2019.
    o Minimum capital requirements for market risk: In January, the Committee issued the revised minimum capital requirements for market risk, which will come into effect on 1 January 2019.
    o Capital requirements for equity investment in funds: In December 2013, the Committee issued the final standard for the treatment of banks’ investments in the equity of funds that are held in the banking book, which took effect from 1 January 2017.
    o SA-CCR: In March 2014, the Committee issued the final standard on SA-CCR, which took effect on 1 January 2017. It replaced both the Current Exposure Method (CEM) and the Standardised Method (SM) in the capital adequacy framework, while the IMM (Internal Model Method) shortcut method is eliminated from the framework.
    o Securitisation framework: The Committee issued revisions to the securitisation framework in December 2014 and July 2016 to strengthen the capital standards for securitisation exposures held in the banking book, which will come into effect in January 2018.
    o Margin requirements for non-centrally cleared derivatives: In September 2013, the Committee issued the final framework for margin requirements for non-centrally cleared derivatives. Subsequently, in March 2015, the Committee published a revised version. Relative to the 2013 framework, the revised version changes the beginning of the phase-in period for collecting and posting initial margin on non-centrally cleared trades from 1 December 2015 to 1 September 2016. The full phase-in schedule has been adjusted to reflect this nine-month change in implementation. The revisions also institute a six-month phase-in of the requirement to exchange variation margin, beginning 1 September 2016.
    o Capital requirements for bank exposures to central counterparties: In April 2014, the Committee issued the final standard for the capital treatment of bank exposures to central counterparties. These came into effect on 1 January 2017.
  • Basel III leverage ratio: In January 2014, the Basel Committee issued the Basel III leverage ratio framework and disclosure requirements. Implementation of the leverage ratio requirements began with bank-level reporting to national supervisors until 1 January 2015, while public disclosure started on 1 January 2015. The Committee will carefully monitor the impact of these disclosure requirements. Any final adjustments to the definition and calibration of the leverage ratio will be made by 2017, with a view to migrating to a Pillar 1 (minimum capital requirements) treatment on 1 January 2018 based on appropriate review and calibration.
  • Monitoring tools for intraday liquidity management: This standard was developed in consultation with the Committee on Payment and Settlement Systems to enable banking supervisors to better monitor a bank’s management of intraday liquidity risk and its ability to meet payment and settlement obligations on a timely basis. The reporting of the monitoring tools commenced on a monthly basis from 1 January 2015 to coincide with the implementation of the LCR reporting requirements.
  • Basel III net stable funding ratio (NSFR): In October 2014, the Basel Committee issued the final standard for the NSFR. In line with the timeline specified in the 2010 publication of the liquidity risk framework, the NSFR will become a minimum standard by 1 January 2018.
  • G-SIB framework: In July 2013, the Committee published an updated framework for the assessment methodology and higher loss absorbency requirements for G-SIBs. The requirements came into effect on 1 January 2016 and become fully effective on 1 January 2019. National jurisdictions agreed to implement the official regulations/legislation that establish the reporting and disclosure requirements by 1 January 2014.
  • D-SIB framework: In October 2012, the Committee issued a set of principles on the assessment methodology and the higher loss absorbency requirement for domestic systemically important banks (D-SIBs). Given that the D-SIB framework complements the G-SIB framework, the Committee believes it would be appropriate if banks identified as D-SIBs by their national authorities were required to comply with the principles in line with the phase-in arrangements for the G-SIB framework, ie from January 2016.
  • Pillar 3 disclosure requirements: In January 2015, the Basel Committee issued the final standard for revised Pillar 3 disclosure requirements, which took effect from end-2016 (ie. banks are required to publish their first Pillar 3 report under the revised framework concurrently with their year-end 2016 financial report). The standard supersedes the existing Pillar 3 disclosure requirements first issued as part of the Basel II framework in 2004 and the Basel 2.5 revisions and enhancements introduced in 2009.
  • Large exposures framework: In April 2014, the Committee issued the final standard that sets out a supervisory framework for measuring and controlling large exposures, which will take effect from 1 January 2019.
  • Interest rate risk in the banking book: In April 2016, the Committee issued the final standard for Interest Rate Risk in the Banking Book (IRRBB), which is expected to be implemented by 2018.

APRA releases consultation package on revisions to large exposures

Last week, APRA released a consultation draft aimed at reducing “contagion risk”. Banks would be required to limit their exposures to unrelated counterparties to 25 per cent of Tier 1 Capital and 15 per cent of Tier 1 Capital to exposures to a bank designated as a global systemically important bank. This would bring Australian banks into line with Basel recommendations.

The Australian Prudential Regulation Authority (APRA) has today released for consultation a discussion paper setting out proposed revisions to its prudential framework on large exposures for authorised deposit-taking institutions (ADIs).

APRA’s large exposure framework aims to limit the impact of losses when a counterparty defaults, and restrict contagion risk from spreading across the financial system.

The proposed revisions are intended to strengthen the supervisory framework for large exposures, reduce system-wide contagion risk and maintain an alignment to the Basel Committee on Banking Supervision’s large exposures standards.

The consultation package released today includes a draft revised Prudential Standard APS 221 Large Exposures (APS 221), as well as associated reporting standards, reporting forms and reporting form instructions.

The discussion paper proposes revisions to large exposure requirements, including that:

  • the limit to an unrelated ADI and their subsidiaries be reduced from 50 per cent of Total Capital to 25 per cent of Tier 1 Capital;
  • a new limit of 15 per cent of Tier 1 Capital be applied to exposures to a bank designated as a global systemically important bank, and to exposures between banks designated by APRA as domestic systemically important banks; and
  • new criteria apply to identifying a group of connected counterparties and measuring large exposure values.

APRA invites written submissions on the proposals in the discussion paper by Wednesday 5 July 2017.

APRA expects to release a response paper and its final revised APS 221 and associated reporting package in the second half of 2017.

APRA’s intention is that the revised large exposure requirements will come into effect from 1 January 2019, in line with the internationally-agreed timetable.

Why The Gap Between Bank Serviceability And Real Life?

Following the recent coverage of our mortgage stress analysis (light it seems is now dawning on regulators, industry commentators and others that household debt is a real and growing issue), one question we get asked is – yes, but surely the banks have guidelines on affordability and serviceability, minimum assumed rate 2%+ above current rates, or 7%+?

So surely, households should have buffers as rates rise?

This is a great question, with a long history attached to it. A couple of years ago the regulators got a shock when them looked at bank practice, and started putting out more specific expectations on lending standards. Back in 2015, Wayne Byres made this point in a speech on lending standards.  At its core was the observation that borrowers appeared to be able to get very different loan amounts from a selection of lenders, using the same base financial profile.

One significant factor behind differences in serviceability assessments, particularly for owner occupiers, was how ADIs measured the borrower’s living expenses (Chart 2a and 2b). As a regulator, it is hard to understand the rationale for large differences in what should be a relatively objective, and extremely critical, metric.4

Chart 2a: Minimum living expense assumptions shows percentage of owner-occupier borrower pre-tax salary income between 20%-35%
Chart 2b: Minimum living expense assumptions shows percentage of investor borrower pre-tax salary income between 0%-25%

Of major concern were a few ADIs who opted to make their credit assessment based on a lower level of living expenses than that declared by the borrower. That is obviously a practice that should not continue, and ADIs should be making reasonable inquiries about a borrower’s living expenses. In fact, best practice (and intuition) would be to apply minimum living expense assumptions that increase with borrower incomes; this was a practice adopted by only a minority of ADIs in our survey.

In 2014, the RBA made this statement in their Financial Stability Report.

Although aggregate bank lending to these higher-risk segments has not increased, it is noteworthy that a number of banks are currently expanding their new housing lending at a relatively fast pace in certain borrower, loan and geographic segments. There are also indications that some lenders are using less conservative serviceability assessments when determining the amount they will lend to selected borrowers. In addition to the general risks associated with rapid loan growth, banks should be mindful that faster-growing loan segments may pose higher risks than average, especially if they are increasing their lending to marginal borrowers or building up concentrated exposures to borrowers posing correlated risks. As noted above, the investor segment is one area where some banks are growing their lending at a relatively strong pace. Even though banks’ lending to investors has historically performed broadly in line with their lending to owner-occupiers, it cannot be assumed that this will always be the case. Furthermore, strong investor lending may contribute to a build-up in risk in banks’ mortgage portfolios by funding additional speculative demand that  increases the chance of a sharp housing market downturn in the future.”

“A build-up in investor activity may also imply a changing risk profile in lenders’ mortgage exposures. Because the tax deductibility of interest expenses on investment property reduces an investor’s incentive to pay down loans more quickly than required, investor housing loans tend to amortise  more slowly than owner-occupier loans. They are also more likely to be taken out on interest-only terms. While these factors increase the chance of investors experiencing negative equity, and thus generating loan losses for lenders if they default, the lower share of investors than owner-occupiers who have high initial loan-to-valuation ratios (LVRs; that is an LVR of 90 per cent or higher) potentially offsets this. Indeed, the performance of investor housing loans has historically been in line with that of owner-occupier housing loans.

The trouble is that the basis on which banks have been assessing available income has been too optimistic. This is because they are based their calculations on historic mortgage book performance, when incomes were rising strongly, and loan losses were very low.

But we are now in a new normal. We have flat incomes. We have rising costs. We have underemployment. We have low growth. But costs of living are rising (and higher for many than the ABS CPI figure would suggest).  Affordability is not what it was. Lenders need to adjust, hard to do when home prices are so high.

Combined, many households are stretched, and the prospect of rising interest rates in these conditions are making things harder.

In addition, households have been willing to gear up with the prospect of future capital growth, so reach for the largest mortgage they can get. Perhaps sometimes they exaggerate their incomes, and understate their costs. This is true we think for households with larger incomes, and lifestyles. Some of these are now under pressure.

So, the root cause of the gap between theoretical affordability and real life is a serious one. Banks often set and forget loans, so do not revisit households finances unless there is a reset or a crisis.  But for many, available incomes are falling (and bracket creep is not helping).  Ongoing financial health-checks might be in order.

ASIC is rightly looking at this issue anew, but we fear the horse may have already bolted. APRA will tighten capital. Both will put upward pressure on mortgage rates, and test affordability further. This is a paradigm shift.

Australia’s Limits on Interest-Only Mortgages Will Curb Riskier Lending

Moody’s says last Friday, the Australian Prudential Regulation Authority (APRA) announced new measures to restrict growth in riskier mortgage loans, including limiting the origination of interest-only mortgages, particularly those with high loan-to-value (LTV) ratios. On Monday, the Australian Securities Investments Commission (ASIC) announced that it will closely monitor lenders and mortgage brokers to ensure they are not inappropriately recommending more expensive interest-only loans to borrowers.

The new measures are credit positive for Australian banks, residential mortgage-backed securities (RMBS) and covered bonds because they will curb growth in riskier mortgage loans amid rising house prices and high household indebtedness. The measures include limiting the flow of new interest-only mortgages by banks to 30% of total new residential mortgage lending. Banks also will be required to have internal limits on the volume of interest-only lending at LTV ratios of more than 80% and ensure that there is strong justification for any interest-only loan with an LTV of 90% or more.

Interest-only loans accounted for 38% of total housing loan approvals in December 2016 and for more than 30% of total housing-loan approvals every month since June 2009 (see Exhibit 1). Housing investment loans, which are often interest-only loans, accounted for 35% of total housing loan approvals as of December 2016. In the RMBS sector, interest-only loans account for 35% of the mortgages backing the deals we rate.

We expect banks to raise interest rates on interest-only loans to reduce growth in this segment and support their net interest margin from ongoing price competition for lower-risk loans and stable deposits. When APRA introduced limits on housing investment loans in December 2014, banks responded by raising interest rates on such loans. In addition to the new limits on interest-only loans, APRA instructed banks to ensure that growth in housing investment loans remains “comfortably” below the 10% limit introduced in December 2014. APRA advised that banks will no longer have leeway to exceed this growth speed limit and that any breach will immediately prompt a review of the offending bank’s capital requirements. This contrasts with APRA’s original guidance, under which the 10% cap was not a hard limit.

APRA also announced that it would monitor the warehouse facilities that banks use to fund non-bank lenders. APRA does not regulate non-bank lenders, but monitoring the warehouse facilities will effectively allow the regulator to influence non-banks’ mortgage underwriting standards and promote the overall stability of the financial system. Non-bank lenders have increased housing investment lending since the introduction of the 10% limit on such loans (see Exhibit 1).

Although the APRA’s and ASIC’s measures add a layer of protection against a house price correction for banks, RMBS and covered bonds, it remains to be seen how effective these measures will be amid moderating house price appreciation, particularly when low interest rates continue to support housing demand. As Exhibit 2 shows, house prices have continued to rise, despite previous measures to slow the housing market.

APRA’s and ASIC’s latest measures and interest rate increases by banks on interest-only loans will slow demand for housing, but we continue to expect house prices in Australia to rise amid low interest rates. Although low interest rates will continue to support borrowers’ capacity to service their debt, rising house prices, in combination with high household leverage and low wage growth, remain risks for banks, RMBS and covered bonds.

APRA Looking At Capital Ratios For Mortgages

Wayne Byres speech “Fortis Fortuna Adiuvat: Fortune Favours the strong”, as Chairman of APRA, at the AFR Banking & Wealth Summit, makes two significant points.

First, there are elevated risks in the residential lending sector (even after the recent tactical announcements on interest only loans). Banks remain  highly leveraged businesses.

Second, despite the delays from Basel, APRA will consult this year on potential changes to the capital ratios, reflecting the Australian Banks’ focus on mortgage lending and the need to be “unquestionably strong”.

A further indication that mortgage costs will continue to rise!

In the past few days, there has been a great deal of attention given to our recent announcement on additional measures to strengthen one particular part of the financial system: the residential mortgage lending market. These measures build on the steps we have taken over the past two years to bolster loan underwriting practices and moderate investor lending, in an environment that we considered to be one of heightened risk.

Those measures had a positive impact (Chart 1), but at the same time the risk environment certainly hasn’t moderated:

  • house prices remain high;
  • household income growth remains subdued;
  • the already high ratio of household debt to income has got higher;
  • the already low official cash rate has got lower (although not all of this reduction has flowed to borrowers, particularly investors; and
  • competitive pressures haven’t diminished.

It’s important to be clear that our goal in implementing the additional measures we announced on Friday is not to determine house prices. Housing prices are not within the control, nor the mandate, of the prudential regulator. Nor, as the Reserve Bank Governor said last night, can prudential measures address underlying supply-demand issues within the housing market. Rather, our role in the current environment is to promote a higher-than-normal degree of prudence – definitely by lenders and, ideally, also borrowers – in both credit decisions and balance sheet strength. On this occasion, we have focussed on interest-only lending to complement our earlier measures. Although there are perfectly legitimate reasons why individual borrowers might prefer an interest-only loan, in aggregate the level of interest-only lending creates additional vulnerabilities and we came to the view some additional moderation in this area was warranted.

We chose not to lower the investor lending growth benchmark at this point in time, given the need to accommodate the increasing supply of housing in the construction pipeline. However, limitations on the volume of new interest-only lending will impact investors more acutely than owner-occupiers, given that around two-thirds of lending to investors is on an interest-only basis. Furthermore, although the 12-month annual growth rate for investor lending is currently below the 10 per cent benchmark, the run rate in more recent months has been closer to (if not a little above) 10 per cent on an annualised basis. Therefore, even with the benchmark unchanged, lenders are still likely to have to tighten their lending practices and slow lending from that in recent months to ensure they remain comfortably below the desired level.

This latest step is a tactical response to current market conditions – we can and will do more (or less) as conditions evolve. We also developing a more strategic response that recognises that, in the Australian banking system, housing lending risks and capital adequacy are far from independent issues.

The banking system certainly has higher capital adequacy ratios than it used to. But overall leverage has not materially declined. The proportion of equity that is funding banking system assets has improved only modestly, from a touch under 6 per cent a decade ago to just on 6½ per cent at the end of 2016. Notwithstanding the extra capital that new regulation has required, banking remains a highly leveraged business.

Unquestionably strong

One way to think about our objective in establishing ‘unquestionably strong’ capital requirements is that we should be able to assert, with credibility, that the banking system can withstand reasonably foreseeable adversity and continue to provide its core function of financial intermediation for the Australian community.

Unfortunately, there is no universal measure of financial strength that provides a clear cut answer to that test. So we need to be able to look at this question through multiple lenses. In thinking about the concept of ‘unquestionably strong’, there are three basic ways to do that:

  • relative measures: the FSI adopted a relative approach in suggesting that unquestionably strong regulatory capital ratios would be positioned in the top quartile of international peers. We have said on a number of occasions that we do not intend to tie ourselves mechanically to some particular percentile, but top quartile positioning is a useful sense check which we can certainly use to guide our policy-making.
  • alternative measures: regulators do not have exclusive domain over measures of financial strength. There are a range of alternative measures, such as those used by rating agencies, which can be used to benchmark Australian banks. Again, we do not intend to tie ourselves too closely to these measures, but it would be difficult to argue the banking system is unquestionably strong if alternative measures of capital strength, particularly those that are influential in investment decision-making, were to suggest something to the contrary.
  • absolute measures: relative and alternative measures are useful guides, but the real test for a bank to claim it is unquestionably strong is whether it can comfortably survive extreme but plausible adversity. So stress testing, which doesn’t rely on relativities with other banks, or competing measures of strength, provides another useful guide for us.
    Using multiple measures will provide useful insights on the banking system’s strength, but unfortunately will be unlikely to give us a single ‘right’ answer. At best it will provide a range for possible calibration which would reasonably meet our objective that, whichever lens you look through, we can credibly claim to have capital standards that produce an unquestionably strong banking system. We will still need to exercise judgement, taking account of other dimensions of risk within the system – both quantitative (such as liquidity and funding) and qualitative (such as risk management and risk culture within banks, and the strengths of the statutory framework and crisis management powers on which the stability of the system is built). Inevitably, some will argue the calibration should be higher, and others think it too high, but at the very least our logic and rationale should be transparent, and we can readily explain how our decisions are consistent with the FSI’s intent.

As things stand today, our plan is to issue an information paper around the middle of the year, which will set out how we view the banking system through the various lenses that I have just mentioned, the extent of further strengthening required, and the timeframe over which that can be achieved in an orderly manner.

Beyond establishing the aggregate level of capital, we will need to follow that up with consultation on how the regulatory framework should allocate that capital across the different types of risk exposure. Some of those changes will flow from the inevitable direction of the work in Basel that I referred to earlier: this will include, for example, greater limitations on the use of internal credit risk models, and the inevitable removal of operational risk models. These changes will primarily impact the larger banks.

But, coming back to my starting point, probably the biggest issue we will need to resolve in ensuring capital is appropriately allocated is whether and how we adjust the risk weights for housing-related exposures. Our announcement last week reflected a tactical response to current conditions in the housing market. We will continue to refine these sorts of measures as long as they are needed. But a longer term and more strategic response will involve a review, during the course of our work on ‘unquestionably strong’, of the relative and absolute capital requirements for housing exposures. That should not be taken to imply that there will be a dramatic increase in capital requirements for housing lending: APRA has always imposed capital requirements for housing exposures that are well above international minimum standards, so we do not start with glaring deficiencies. By anyone’s standard, however, we have a banking system that has a notable concentration in housing. It is therefore important we give that issue particular attention as we think about how to put the concept of ‘unquestionably strong’ into practice.


APRA’s housing intervention could suck billions out of the consumer economy

From Business Insider.

Despite the impression you might get from policy wrangling like we’ve seen in recent weeks over corporate tax rates, or complex arguments about the levels of growth that other policy adjustments can deliver, or the daily updates you’ll see on commodity prices, at the heart of the Australian economy there is one single force that is more important than any other. Consumers. People like you and me.

Our daily decisions to buy and sell things — the billions transactions we make every year — are by far the biggest component of economic activity. Look:

Source: JP Morgan
This broad bucket of “consumption” accounts for almost a trillion dollars of economic activity in Australia every year.

It’s why economists conduct expensive research on consumer confidence and why numbers like we’ve seen today, with the ANZ-Roy consumer confidence index slipping below its long-run average, are concerning.

If consumers enter a sustained period of uncertainty and feeling negative about the future, they’ll pull back their spending and the growth of this vast pool of economic activity will slow down.

There are tentative signs that a consumer retreat might be underway, for example in the negative growth in retail spending we saw in February. Car sales have also been looking a little weak.

The consumer confidence data out today shows a deterioration in how people are thinking about the future on a range of fronts, from the economic outlook to their own household finances. Here’s the chart showing people’s view on the medium-term economic outlook.

Source: ANZ

As David Scutt points out here, this is unusual given that surging properties like we’ve seen in the major cities would typically be linked with a “wealth effect”, whereby people feel better about their prospects because their house is worth more.

And this is where APRA, the banking regulator, comes in.

APRA last month introduced another range of measures to try and put the brakes on speculative activity in the housing market, chiefly by limiting the flow of new interest-only lending to 30% of new mortgage loans. The intervention has injected fresh vigour to the already intense national conversation about how expensive housing has become, particularly in the major cities.

This isn’t just about housing affordability. It comes after clear warnings from the RBA about risks to financial stability, noting last month that “recent data continued to suggest that there had been a build-up of risks associated with the housing market”.

It added that “borrowing for housing by investors had picked up over recent months and growth in household debt had been faster than that in household income”. These comments are part of a pattern of a steadily increasing focus on financial stability under the RBA governorship of Phil Lowe.

Housing can get expensive but that’s a problem you can live with. The same can’t be said of serious financial stability risks, hence the policy intervention.

It’s possible that all this talk in recent weeks has provoked Australians to reassess their prospects and come to grips with the fact that the debt taken on in getting into the property market will need to be repaid.

Feed this back into the prime importance of household consumption continuing to grow in the overall domestic picture, and you have a concerning picture.

And there’s more to come. Morgan Stanley analysts say APRA’s intervention could directly strip billions of dollars out of household consumption as banks move to reprice mortgages and investor loans that were previously interest-only roll over into much more costly principle-and-interest repayments.

In a research note the bank’s Australian equity strategy team, led by Chris Nicol, offered this calculation (emphasis added):

While this looks to be a cautious further step by APRA, we note that it comes alongside a material repricing of investor mortgages and will potentially be followed by higher risk weights. The market may also underestimate the degree to which Australian mortgage payments ‘step-up’ when rolling from IO-phase to P&I (at least +30% and often +50-70%, depending on tenors and headline rate). At an aggregate level, we calculate that a 10ppt fall in the share of IO mortgages to the new cap would reduce household free cash flow by around A$3bn (0.26% of income), with the average 14bp of mortgage hikes over the past fortnight absorbing another A$2bn (0.15%). This increases the burden on a consumer seeing no income growth (average wages were -0.5% in 2016), and we again reiterate our caution on the growth outlook, while seeing the market as too hawkish on the prospect of RBA hikes over the next 18 months.

That’s $3 billion sucked out of other parts of the consumer economy on top of the $2 billion already chipped out of households’ disposable income thanks to mortgage price increases by the banks last month.

As the saying goes, a billion here, a billion there, and sooner or later it starts to add up to real money.

In an environment where the retail industry – the biggest employment sector in the country after healthcare – is looking weak and inflation is staying low partly because consumers aren’t spending as freely as perhaps they would be if they weren’t loaded up with debt – all of this adds up to another prospective drag on the consumer outlook which is so central to economic growth.

The Interest-Only Loan Debt Trap II

Last October we wrote a series of posts on the risks related to interest only loans. Given recent developments, and the belated focus from APRA and ASIC, we revisit the topic today.

Here is a plot from the APRA data showing the relative movement of investor loans and interest only loans. Yes, there is a correlation! The ABC’s Phil Lasker used this chart in the TV News on Friday.

Lenders will need to throttle back new interest only loans. But this raises an important question. What happens when existing IO loans are refinanced?

Less than half of current borrowers have complete plans as to how to repay the principle amount.

Interest-only loans may seem like a convenient way to reduce monthly repayments, (and keep the interest charges as high as possible as a tax hedge), but at some time the chickens have to come home to roost, and the capital amount will need to be repaid.

Many loans are set on an interest-only basis for a set 5 year term, at which point the lender is required to reassess the loan and to determine whether it should be rolled on the same basis. Indeed the recent APRA guidelines contained some explicit guidance:

For interest-only loans, APRA expects ADIs to assess the ability of the borrower to meet future repayments on a principal and interest basis for the specific term over which the principal and interest repayments apply, excluding the interest-only period

This is important because the number of interest-only loans is rising again. Here is APRA data showing that about one quarter of all loans on the books of the banks are interest-only, and that recently, after a fall, the number of new interest-only loans is on the rise – around 35% – from a peak of 40% in mid 2015. There is a strong correlation between interest-only and investment mortgages, so they tend to grow together. Worth reading the recent ASIC commentary on broker originated interest-only loans.

But what is happening at the coal face? To find out we included some specific questions in our household survey, and today we present the results.

We were surprised to find that around 83% of existing interest-only loan holders expect to roll their loan to another interest-only loan, and to keep doing so.  More concerning, only around 44% of borrowing households had an explicit discussion with the lender (or broker) at their last loan draw down or reset about how they plan to repay the capital amount outstanding.  Some of these loans are a few years old.

Around 57% said they knew the capital would have to be repaid (we assume the rest were just expecting to roll the loan again) and 26% had no firm plans as to how to repay whereas 39% had an explicit plan to repay.

Many were expecting to close the loan out from the sale of the property (thanks to capital appreciation) at some point, from the sale of another property, or from another source, including an inheritance.

Thus we conclude there is a potential trap waiting for those with interest-only loans. They need a clear plan to repay, at some point. It also highlights that the quality of the conversation between borrower and lender is not up to scratch.

We think some borrowers on an interest-only loan may get a rude shock, when next they try to roll their interest-only loan. If they do not have a clear repayment plan, they may not get a new loan. There is a debt trap laid for the unwary and the APRA guidelines have made this more likely.

Back in 2014, we wrote about the interest only situation in the UK.

So, now lets look at the UK experience. There are 11.3 million mortgages in the UK, with loans worth over £1.2 trillion. At the end of 2013 there were an estimated 2.2 million pure interest-only loans outstanding, and a further 620,000 part interest-only, part repayment mortgages outstanding on lenders’ books. Compared to 2012 this represents a fall of around 300,000 pure interest-only mortgages (down 12%), and around 90,000 part-and-part mortgages (down 13%).

According to the Council for Mortgage Lenders, at the peak of their popularity in the late 1980s, interest-only mortgages accounted for more than 80% of all loans taken out. This year, however, lenders are likely to advance only around 40,000 new interest-only loans for residential house purchase, less than 10% of the total.

Among first-time buyers, the decline in interest-only borrowing has been particularly pronounced. CML data shows that only 2% are taking out interest-only mortgages, with 98% opting for repayment loans. Interest-only accounts for a higher proportion of new borrowing by existing owner-occupiers who are moving (10%) and those remortgaging (13%).

Most new interest-only borrowing is in the buy-to-let market (aka investment mortgage), where this option remains the norm for very good reasons. Fixed-rate interest-only mortgages minimise costs for landlords and are more likely to produce a profitable margin. Interest-only mortgages also enable landlords to meet lenders’ requirements that their rental income produces an average minimum cover of 125% of their borrowing costs.

A couple of years back, there were concerns in the UK that interest only loans may be a problem, and alongside regulatory commentary, CML produced an “interest-only toolkit” designed to help mortgage lenders to work with their interest only mortgage customers, especially those loans due for repayment before 2020.

The regulators reached the conclusion that 90% of interest-only mortgage holders have a repayment strategy in place. Lenders made a commitment with the regulator (the Financial Conduct Authority) to contact interest-only loan holders and ask about their repayment plans.  The CML via it lender members found that Lenders have been using a variety of contact strategies. In addition to reminders and mailings requesting the customer’s written response (including questionnaire responses), telephone calls, face-to-face meetings and even home visits are also used by some lenders. Overall, around 30% of customers contacted have so far responded.

Among those borrowers who have responded, around four out of five already had a clear plan. Among those who did not, the survey found that the solutions and approaches lenders are offering typically include term extensions, permanent conversions to capital and interest, and overpayments.

There has also been a positive set of changes in the loan-to-value profile of outstanding interest-only mortgages. Two-thirds of outstanding interest-only mortgages have loan-to-value (LTV) ratios of less than 75% – and the vast majority of these are not due to mature until after 2020.

The chart shows that a large number of loans would have moved into a lower LTV band as a result of house price inflation alone. However, it also shows that borrowers are taking additional action to reduce their mortgage balances, as the effect of house price inflation alone would not have resulted in the improvements in outstanding LTVs that have been seen over the past year. Indeed, the number of loans in every LTV band below 75% would have seen an increase on the basis of house price inflation alone (as loans moved down from higher LTV bands) – but, in fact, every band saw a decrease.

Changes in interest-only loans outstanding, September 2012-December 2013, by LTV

01.05.14-changes-in-interest-only-loans-outstanding-by-ltvUnder the new mortgage regulations now in force in the UK, lenders may offer interest only loans, but only if a borrower has a credible repayment plan, at the time of application.

So some points to ponder.

1. How many interest only loans in Australia have a credible repayment strategy? To what extent is this considered by borrowers and lenders at the time of application?

2. Will rising house prices be the solution to interest-only loan repayment?

3. Are the review processes (on average each 5 years in Australia, even if the loan term is 25/30 years) sufficiently robust to identify potential issues?

4. Does Negative Gearing lead to a greater dependence on interest-only loans?