Vanguard’s UK Online Investment Platform Is Credit Negative for Incumbent Players

From Moody’s

Last Tuesday, low-cost fund provider Vanguard (unrated), announced its intention to enter the UK’s direct-to-consumer online investment market. Vanguard’s entry into the UK retail online investment market is credit negative for incumbent online platforms such as Hargreaves Lansdown (unrated) and FIL Ltd.’s (Baa1 stable) Fidelity FundsNetwork because it will likely trigger a price war that costs incumbents their profitability.

Vanguard’s online service, the Vanguardinvestor, lets UK retail investors directly access a wide range of Vanguard’s exchange-traded funds (ETFs) without using a broker or financial advisor. So far, most of Vanguard’s UK business has been sourced from brokerages and financial advisors, which typically require clients to have minimum account balances of at least £100,000. Using Vanguard’s online platform, retail investors will now be able to open an individual savings account with £500 or a monthly investment of £100. And, Vanguardinvestor will charge a flat administrative fee of 0.15% (capped at £375 per year), which is lower than the 0.45% fee that Hargreaves Lansdown, the UK’s largest online provider, charges (see Exhibit 1).

Vanguard will target investors from both the mass and mass-affluent markets – those with savings of £5,000-£50,000. These investors lost access to advice in 2013 with implementation of the UK’s Retail Distribution Review (RDR) and invest directly. In a November 2012 publication, Deloitte estimated that the RDR had created an advice gap population of as many as 5.5 million people.

Gross inflows into stock and share individual savings accounts in 2015-16 totalled £21.1 billion, and this segment has been growing (see Exhibit 2), driven by the tax-free individual savings account allowance increase to £20,000 from £15,240 in April 2017 and new products. In addition to individual savings accounts and defined-contribution pensions, general investment accounts without any tax wrapper are benefiting from investor inflows as people become increasingly aware of their investment options. Vanguard announced plans to launch a self-invested personal pension in the future.

Vanguard’s online service also targets younger investors such as millennials, who are comfortable with online services and are not yet a target for financial advisors or wealth managers. As they evolve in their careers and garner higher incomes, this demographic will be accustomed to low-cost services and investment funds. Vanguard’s online service in the UK is so far limited, but we can see it evolving toward robo-advice as it has in the US with The Vanguard’s Personal Advisor Services.

Incumbent platform providers will likely lower administrative fees and increase services to maintain market share, but this will compress their margins. Given the high and rising costs of running online services, smaller platforms with less price flexibility such as Interactive Investors (unrated) and Nutmeg (unrated) will be most challenged. Cheap online investment services will also accelerate the adoption of low-costs index trackers and ETFs among UK retail investors. Active managers such as Aberdeen, Henderson, Schroders, and FIL Ltd. Will face fee and margin pressure as a result.

In addition, the UK’s Financial Conduct Authority’s upcoming investment platform market study to improve competition between platforms and improve investor outcomes is likely to challenge most platform providers’ prices and Vanguard would be well positioned for any price war. As the best-selling fund manager in 2016 and second-largest asset manager globally, Vanguard has the scale, resources and brand necessary to disrupt the UK retail market, which was £872 billion as of year-end 2015. In the US, where Vanguard provides a similar online-value proposition, platform costs went down.

UK Home Price Growth Eases

According to the UK’s Office for National Statistics, average house prices in the UK have increased by 4.1% in the year to March 2017 (down from 5.6% in the year to February 2017). This continues the general slowdown in the annual growth rate seen since mid-2016.

The average UK house price was £216,000 in March 2017. This is £9,000 higher than in March 2016 and £1,000 lower than last month.

On a regional basis, London continues to be the region with the highest average house price at £472,000, followed by the South East and the East of England, which stand at £312,000 and £277,000 respectively. The lowest average price continues to be in the North East at £122,000.

 The East of England and the East Midlands both showed the highest annual growth, with prices increasing by 6.7% in the year to March 2017. This was followed by the West Midlands at 6.5%. The lowest annual growth was in the North East, where prices decreased by 0.4% over the year, followed by London at 1.5%.

The UK HPI is a joint production by HM Land Registry, Land and Property Services Northern Ireland, Office for National Statistics and Registers of Scotland.

The UK House Price Index, introduced in June 2016, includes all residential properties purchased for market value in the UK. However, as sales only appear in the UK HPI once the purchases have been registered, there can be a delay before transactions feed into the index. As such, caution is advised when interpreting prices changes in the most recent periods as they are liable to be revised.

British prime minister calls snap general election

British Prime Minister Theresa May has called a snap general election for 8 June.

She made the announcement in Downing Street after a cabinet meeting.

With a Commons working majority of just 17, and a healthy opinion poll lead over Labour, senior Tories have suggested Mrs May should go to the country in order to strengthen her parliamentary position.

Such a move would also give a mandate both for her leadership and her negotiating position on Brexit before talks with the European Union start in earnest.

Justifying the decision, Mrs May said: “The country is coming together but Westminster is not.”

She said the government has a right plan for negotiating with European Union.

She said they need unity in Westminster, but instead there is division.

From RTE.

The current 5-year fixed term should run to 2020, and will require a 2/3’s vote in Parliament to progress. This may cause significant heartburn in Labour circles in Britain!

The FT Index fell on the news.

 

 

London Housing Market Takes A Bath

At the end of 2016 we reported that the formerly invincible London home market had suffered its biggest crack in years, when home prices plunged the most in six years according to Rightmove via Zero Hedge.

Asking prices in London dropped 4.3% in December with inner London down 6%.  Meanwhile, the most exclusive neighborhoods, like Kensington and Chelsea, recorded even sharper declines at nearly 10% as home buyers migrated to cheaper areas of the city.

While it was unclear what was the catalyst: whether post-Brexit nerves, China’s crackdown on capital outflows, the ongoing depressed commodity market, or reduced migrations by wealthy Russian and Arab oligarchs, what is obvious is that the slump has continued, and according to the Royal Institution of Chartered Surveyors, its price balance for the city fell to the lowest since February 2009 last month, plunging to minus 49, which means that a greater percentage of agents reported drops in March.

Still, as Bloomberg reports, more respondents than not still expect prices in London to rise over the next year, the report showed. they may be disappointed.

Speaking to Bloomberg, Samuel Tombs at Pantheon Macroeconomics said that the London measure tends to represent the prime market rather than the city as a whole. The slump in the gauge tallies with other reports of sellers in central London having to cut prices to close deals.  Nationally, the RICS price index stayed at 22 in March, though the expectations for both values and sales over the next year weakened. New buyer inquiries and sales were stagnant, with the most expensive properties among the worst performers, according to report.

While buyers – especially those relying on mortgages – remain largely locked out of the market because of high prices, nervousness about Brexit and the U.K. outlook, price downside according to realtors may be “limited because of the continued shortage in the supply of property to buy, with estate agents’ listings reportedly at a record low.”

Which is odd because a cursory check reveals not only that there is a glut of high end properties, many of which have been on the market as long as a year, but that despite huge discounts as high as 40%, nothing is moving, and just this one listing service has no less than 124 pages of properties – at 15 properties per page – with price declines in Kensington and Chelsea alone, up from “only” 53 pages when we last looked at the same website back in December.

“High end sale properties in central London remain under pressure, while the wider residential market continues to be underpinned by a lack of stock,” said Simon Rubinsohn, RICS chief economist. “For the time being it is hard to see any major impetus for change in the market, something also being reflected in the flat trend in transaction levels.”

Britain’s housing market is in poor health, but it’s not just a shortage – here’s why

From The UK Conversation.

The UK’s housing market is in critical condition. The symptoms are stark: demand in several regions far outstrips supply, prices relative to earnings in many major cities are beyond the reach of most people, home ownership is increasingly unobtainable, the homeless population is growing and low-income households are too often having to settle for substandard homes.

Yet so far, an exact diagnosis has proved elusive and, as a result, effective treatment has not been administered. The problem is that the housing sector is often described in shorthand – the housing market, “affordable” housing, the neighbourhood, or council housing, to name just four such ways of talking about housing. Each is quite different and even just looking at any one masks more than it illuminates – there is considerable variation in the quality and attractiveness of council housing, for instance.

Housing is a complex, interdependent system, with many components of different types and scales. Its function isn’t isolated from its environment – the operation of the housing system is closely connected to the land market and planning mechanismsas well as the construction and development industries. And housing exists across a range of jurisdictions and tenures, each accompanied by different laws, rights and obligations.

Living history

The mind behind Right to Buy. Nationaal Archief/Wikimedia Commons, CC BY

The housing system has also been moulded by history. For one thing, much of the UK’s housing stock is with us as part of a long-established and enduring built environment. It has also been shaped by extensive and overlapping sets of more or less effective government interventions over time: from the garden city movement, to post-war slum clearance, Margaret Thatcher’s Right to Buy and many others. These policies are situated amid shifts and changes in cultural beliefs about housing, aspirations and material constraints.

Housing systems are affected by economic change and income growth at local and regional levels – as well as interest rates, regulation of mortgage lending, housing taxes and other policies that privilege one set of housing arrangements over another. Demography – encompassing trends in migration, household size and ageing – also contributes to the shape and size of housing demand.

Yet these relationships run both ways. Housing is such a critical consideration for political and economic decisions that the state of the sector directly affects the economy and demography of the UK, as well as being affected by them. In a housing bust, for instance, falling incomes can reduce demand and house prices. But if house prices continue to fall, this can also reduce consumption and spending, as people feel worse off.

Unpicking the threads

When you think about housing as a system, it becomes clear that the “housing crisis” is actually a collection of symptoms from several chronic, overlapping problems. The UK housing market has experienced decades of privileged taxation treatment. Consecutive governments have been obsessed with boosting rates of home ownership. Meanwhile, the development industry’s business model is based on lifting land value, with planning permission from local authorities, which results in the construction of more expensive properties. And there has been long-term under-investment in social and affordable housing, combined with an over-reliance on welfare benefits to offset rising rents.

We know that the housing system is dominated by the existing stock, so it stands to reason that it will take a long time to untangle and address these issues, which have built up over the decades. That is, assuming that political consensus is strong enough to allow coherent long-term policy to move forward in step. This is a fair definition of a “wicked” problem.

To build consensus and tackle these issues, housing policy and practice need to be based on evidence, which is grounded in this systemic point of view. The evidence will need to be nuanced, according to the great variety in the sector across the UK: after all, housing is largely devolved, and significant differences between the situations and approaches in Scotland, Northern Ireland, England and Wales are already apparent. For instance, there is no Right to Buy in Scotland – instead, a new private tenancy law will produce longer-term tenancies that may yet encourage more families into the rented sector.

To this end, the University of Glasgow, together with eight other UK universities and four non-academic partners, is embarking on an ambitious programme: the UK Collaborative Centre for Housing Evidence (CaCHE). Our aim is to put evidence and analysis back at the heart of this complex social and economic problem. This research will provide the ammunition to influence and transform housing policy and practice through better problem diagnosis, policy evaluation and appraisal of new opportunities, in order to generate improved housing outcomes for all.

You’ve got to fight! For your right! … to fair banking

From The UK Conversation.

British governments have been trying to improve financial inclusion for the best part of 20 years. The goal is to make it easier for people on lower incomes to get banking services, but this simple-sounding target brings with it a host of problems.

A House of Lords committee will shortly publish the latest report on this issue, but the genesis of financial inclusion policy can be traced back to the late 1990s as part of the Labour government’s social exclusion agenda. The scope and reach of this strategy has since expanded beyond a focus on access to products and now seeks to improve people’s financial literacy to help them make their own responsible decisions around financial services.

The goal of increasing the availability of basic banking has become a tool for tackling poverty and deprivation worldwide, among governments in the global north and global south and among key institutions. In 2014, the World Bank produced what it described as the world’s most comprehensive financial exclusion database based on interviews with 150,000 people in more than 140 countries.

Retaliation? mobiledisco/Flickr, CC BY-NC-ND

Muddy waters

However, broad and enthusiastic acceptance of such policy efforts has prompted doubts about the simplistic narrative of inclusion and exclusion. This way of thinking does not capture the complexities of the links between the use of financial services and poverty, life chances and socio-economic mobility. It also ignores the sliding scale of financial inclusion, from the marginally included – who rely on basic bank accounts – through to the super-included with access to a full array of affordable financial services.

You can see the complexity and contradictions clearly in innovations such as subprime products and high-cost payday lenders. They have made it increasingly difficult to draw a clear distinction between the included and the excluded. Mis-selling scandals and concerns over high charges have also shown us that financial inclusion is no guarantee of protection from exploitative practices.

Even the pursuit of better financial education offers a mixed picture. Critics have raised concerns that this shifts the focus away from structural discrimination and towards the individual failings of “irresponsible and irrational” consumers. There is a grave risk that we will fail to tackle the root causes of financial exclusion, around insecure income and work, if policy follows this route.

In the midst of this focus on customers, the government’s role has been reduced to supporting those education programmes and cajoling mainstream banks, building societies and insurers into being more inclusive.

Vested interests. The Square Mile in London. Michael Garnett/Flickr, CC BY-NC

Given the central role that financial services play in shaping everyday lives, a hands-off approach from the state is inadequate. It fails to address the injustices produced by a grossly inequitable financial system. Our recent research examined how the idea of financial citizenship might offer a route to improvements. In particular, we looked at the idea of basic financial citizenship rights and the role that might be played by UK credit unions, the organisations which, supported by government, seek to bring financial services to those on low incomes.

The idea of establishing rights was put forward by geographers Andrew Leyshon and Nigel Thrift in response to the growing lack of access to mainstream financial services. The goal would be to recognise the significance of the financial system to everyday life and set in stone the right and ability of people to participate fully in the economy.

That sounds like a laudable aspiration, but what could a politics of financial citizenship entail in practice?

Drawing on the work of political economist Craig Berry and researcher Chris Arthur, we argue that the policy debate should move on to establish a set of universal financial rights, to which the citizens of a highly financialised society such as the UK are entitled regardless of their personal or economic situation.

  1. The right to participate fully in political decision-making regarding the role and regulation of the financial system. This would entail, for example, the democratisation of money supply and of the work of regulators. Ordinary people would have to be able to meaningfully engage in debates about the social usefulness of the financial system.
  2. The right to a critical financial citizenship education. Financial education needs to go beyond the simple provision of knowledge and skills to understand how the financial system is currently configured. It should provide citizens with the tools to be able to think critically about money and debt, as well as the capability to effect meaningful change of the financial system.
  3. The right to essential financial services that are appropriate and affordable such as a transactional bank account, savings and insurance.
  4. The right to a comprehensive state safety net of financial welfare provision. This could include a real living wage to prevent a reliance on debt to meet basic needs and could go all the way through to the provision of guarantees on the returns that can be expected from private pension schemes.

Establishing this set of rights would be a major step towards enhancing the financial security and life chances of households and communities. The weight of responsibility would shift from individuals and back on to financial institutions, regulators, government and employers to provide basic financial needs. As one example, just as people in the UK are given a national insurance number when they turn 16, so the government and the banks could automatically provide a basic bank account to everyone at the age of 18.

The UK credit union movement does make efforts towards these goals, but it cannot fully mobilise financial citizenship rights largely due to its limited scale and regulatory and operational limitations. For the rights to work, they will need the support of the state, of financial institutions, regulators and employers. That would enable the country to build something less flimsy than the loose structure we have right now, which piles blame onto the consumer and relies on voluntary industry measures to pick up the slack.

Brexit: Now Comes the Hard Part

According to James McCormack Global Head of Sovereigns at Fitch Ratings, nearly nine months after the UK voted in a referendum to leave the EU, the British government will soon provide notice to the European Council of its intention to withdraw under Article 50 of the EU Treaty, marking the beginning of exit negotiations. As contentious as the last year has been, first in debates on the merits of Brexit leading up to the referendum, and more recently amid criticisms of the government’s negotiating priorities and strategy, the period ahead promises to be even more combative.

Being the first country to leave the EU, the UK has no pre-established path to follow, and will forge ahead knowing only that Article 50 stipulates a two-year period to negotiate and ratify an agreement on the terms of exit, unless Member States unanimously agree an extension. There are five primary challenges facing the UK that are identifiable from the outset.

Timing is Tight, and the Exit Bill Looms

Most fundamentally, the UK will not be in full control of the negotiating agenda, and specifically the order in which issues will be addressed. Prime Minister May has said that a comprehensive free trade agreement with the EU is one of the government’s objectives, and that a smooth and orderly Brexit means having it in place by the end of the negotiating period. Most observers agree that two years is a short time to negotiate a free trade deal, but the actual time available to do so could prove even shorter, as some European leaders have suggested that the UK’s post-exit trade arrangements can only be negotiated once the most important terms of its exit have been agreed, which could take several months.

This may simply be an early negotiating tactic, but if less time is available, it becomes more likely a transition agreement would be needed to avoid what the prime minister has called “a disruptive cliff edge”. However, such an agreement would also take time to negotiate, and, once in place, it could reduce the urgency of reaching a final agreement, possibly drawing out negotiations well beyond two years.

The second major challenge faced by the UK will be settling the financial terms of its EU departure, or its “exit bill”, which EU leaders have indicated will be among the issues they seek to resolve up front. The main elements to be discussed will be future EU spending commitments agreed when the UK was a member state and EU officials’ pensions, and a figure of EUR60 billion has been bandied among European leaders. The amount will certainly be disputed by the UK, but it will have a strong incentive to agree to terms quickly and move on to more contentious and important issues, even though the concept of post-membership payments to the EU will be portrayed by some in the UK as an early and unnecessary concession.

Scotland and Other Internal Divisions

The three remaining challenges are domestic, and centre on Scotland, the lack of a unified national position on Brexit and the need to manage expectations.

The Scottish Parliament’s Culture, Tourism, Europe and External Relations Committee has published a report calling for “a bespoke solution that reflects Scotland’s majority vote to remain in the single market”. It would greatly complicate both the negotiations with the EU as well as border and logistics issues if such a bespoke arrangement were in place post Brexit. The lingering risk of a second independence referendum raises the stakes in how the UK government deals with any Scottish requests, and will require policymakers’ careful attention when government resources will already be stretched.

Beyond Scotland, it has been made clear in a variety of forums that the UK is not entering Brexit negotiations with unified views of the most desirable outcomes. In considering future UK trade arrangements, for example, Parliament’s International Trade Committee recently recommended joining the European Free Trade Area, and there are sure to be a raft of other proposals put forward on this issue alone from public and private sector groups. In the midst of negotiations, open debates within the UK can expose domestic political pressure points that could be strategically exploited by the European side. It may be of some comfort that the EU will be subject to similar internal disagreements, but the upshot of this is likely to be delays in formulating negotiating positions — an unfavourable outcome for the UK.

The final UK challenge as negotiations begin is managing expectations and uncertainties. Prime Minister May promised “no running commentary”, but there will be leaks, as with any negotiation. Progress will not be linear, in the sense that the UK and EU will appear alternatively to be closer to achieving their objectives, and financial markets may react accordingly. Domestic opponents of the UK government are likely to be quick to attribute any economic underperformance or market turbulence to shortcomings in the government’s approach to negotiations. The biggest associated risk is that the balance of public opinion shifts to a decidedly more negative view of Brexit, lending support to ideas already circulating on either a greater role for Parliament in approving the final negotiated agreement or another opportunity for the electorate to formally express its view.

UK Faces Debt Challenge Despite Short-Term Growth Boost

Reducing public debt remains a long-term challenge for the UK despite the upbeat news on the near-term outlook for growth and borrowing in yesterday’s Budget, Fitch Ratings says. This challenge is reflected in the Negative Outlook on the UK’s ‘AA’ sovereign rating.

The Office for Budget Responsibility (OBR) has raised its growth forecast for this year to 2% from 1.4% in the Autumn Statement. But downward revisions for the following two years leave the level of both real and nominal GDP by 2019 broadly unchanged from November. The OBR expects real GDP growth to be around 2% beyond 2019.

We have also revised our near-term UK growth forecasts higher in our most recent Global Economic Outlook to reflect the resilience of the economy in 2H16 following the Brexit vote. But we still forecast lower growth than the OBR this year (1.5%) and next (1.3%), with the difference mainly due to our forecast for weaker investment, due to the uncertainties about UK trade relations after Brexit.

Discretionary fiscal measures in the budget were very small, reflecting the government’s intention to move its main fiscal policy event to the autumn. Higher spending on social care and schools over the next three years is offset by changes in dividend taxation and social contributions for the self-employed. The overall impact is deficit-increasing in FY17/18 and FY18/19, and deficit-reducing thereafter – but the changes are minimal (around 0.1% of GDP in FY17/18, for example).

Currently we assume that the government debt to GDP ratio will peak in 2018, but that would still leave the UK with one of the highest public debt ratios among highly rated (‘AAA’ and ‘AA’) sovereigns. The OBR’s latest projections underscore this view. The OBR estimates that in the current financial year government borrowing will be GBP16.4bn (0.8% of GDP) lower than previously expected, due to higher-than-expected tax receipts and some underspending by government departments. But it expects the positive impact of such one-off factors and timing effects to unwind over the next three financial years.

The government’s plans imply a consolidation of around 1.6% of GDP until the end of the current parliament. Official projections point to the public deficit in structural terms falling to 0.9% of GDP by FY20/21 – below the government’s target of under 2%. But they also indicate that additional tightening is likely to be needed to meet the government’s overall objective of balancing the budget as early as possible in the next parliament.

Furthermore, the OBR expects that general government gross debt as a share of GDP will remain broadly at its current level over the next two financial years, and only start declining in FY19/20. This underlines the scale of the challenge of putting the debt ratio on a downward path.

Proposed UK Bank Capital Changes Are Credit Negative

From Moody’s.

Last Friday, the UK’s Prudential Regulation Authority (PRA) proposed a more flexible approach to determining Pillar 2A capital requirements for banks calculating risk-weighted assets (RWAs) according to the standardised approach. The PRA’s proposal aims to use Pillar 2A to reduce some of the variation between standardised risk weights and internal models outputs for similar risks, remove future duplication between IFRS 9 provisions for expected loss and the standardised approach, create incentives for smaller lenders to move away from higher risk mortgage lending and facilitate greater competition among UK banks.

We expect that the proposed changes will reduce the capital requirements for small banks and building societies, freeing up capital for further growth. However, in an already competitive market, with many smaller firms growing faster than the market, increased competition will negatively pressure margins and reduce profitability for all banks, a credit negative.

The proposal more closely aligns the RWAs calculated with the standardised approach and the internal ratings-based approach by allowing lenders the PRA deems adequately governed and well managed to benefit from lower Pillar 2A capital requirements if their loan portfolio is considered low risk. Disincentives would be created for higher-risk lending for which standardised risk weights are often equal to or lower than the upper band of the PRA’s internal ratings-based benchmarks. The PRA’s proposal follows the Competition Market Authority’s report recommending greater competition in the UK retail banking.

The proposal also seeks to address the potential for an effective double counting of expected loss that these firms may incur with the adoption of IFRS 9 on 1 January 2018, which would not have applied to lenders using the internal ratings-based approach.

We expect that the UK banks and building societies that we rate and which use the standardised approach will largely receive reduced Pillar 2A requirements under this proposal because of their focus on residential mortgages with limited high loan-to-value (LTV) exposures. These banks’ low-LTV and residential mortgage focus, as shown in Exhibit 1, means that they are likely to benefit from capital relief without significant incentives to change lending practices. However, all of these institutions have achieved material growth in their mortgage books over the past few years, targeting increases in volume to offset increasing margin pressure. We view negatively further incentives to foster growth for these firms through a relaxation of Pillar 2A capital requirements because doing so will weaken the affected banks’ stress capital resilience. Exhibit 2 shows banks’ reported common equity Tier1 capital ratios. We note that most of the affected banks we rate are already expanding their lending faster than the market, with annual growth of around 10% (excluding Yorkshire Building Society) in 2016, compared with 4% market growth.

We expect the PRA’s proposal to contribute to already-strong competition in the UK mortgage market, adding negative pressure to net interest margins, and negatively affecting the profitability of the banks we rate.

Affected firms are also likely to benefit from a lower minimum requirement for own funds and eligible liabilities (MREL) as a result of these proposals because of a reduction in the combined Pillar 1 and Pillar 2A capital requirements, reducing the loss-absorption capacity for creditors in the event of their failure. A subset of these firms, which have total assets in excess of £15-£25 billion, are likely to see the greatest MREL relief because they are subject to the strictest form of the requirements.

UK Confirms Loan To Income Mortgage Lending Rules

The Prudential Regulation Authority (PRA) has set out the final rules for the Loan to Income (LTI) flow limit to operate on a four-quarter rolling basis.

This applies to banks, building societies, friendly societies, industrial and provident societies, credit unions, PRA-designated investment firms, and overseas banks in relation to their UK branch activities and the UK subsidiaries of the above mentioned firms.

In June 2014 the Financial Policy Committee (FPC) issued a recommendation  to the PRA and the Financial Conduct Authority (FCA) advising that they should ‘ensure that mortgage lenders do not extend more than 15% of their total number of new residential mortgages at loan to income ratios at or greater than 4.5’.

The PRA proposed amending the PRA’s rules to change the current fixed quarterly limit into a four-quarter rolling limit. The limit would still need to be complied with and monitored at the end of every quarter, but the relevant flows of loans for compliance with the limit would now be those during a rolling period of four quarters in total, instead of one quarter as currently applied. These four quarters refer to the immediate quarter under consideration and the three quarters preceding it.

The PRA is now finalising the amendment to the Part proposed in CP44/16. The change is implemented with immediate effect, so that the loan to income (LTI) flow limit is applied on a four-quarter rolling basis from the current quarter onwards. This means that starting from Q1 2017 the PRA would monitor the LTI flow limit on a four-quarter rolling basis, which for Q1 2017 will be incorporating data on flows from Q2 2016, Q3 2016, Q4 2016 and Q1 2017. It is important to note that compliance under a fixed quarterly limit (which was the expectation before this change was introduced) automatically implies compliance with the limit under a four-quarter rolling basis.