The 20% is too blunt

44brendan

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I have moved these from the other thread, as they were not directly relevant. Brendan

This proposal of 80% LTV is being put forward as a panacea to cover the potential for a further house pricing bubble and to avoid prospective home owners becoming over-borrowed. In my view it is an extremely blunt instrument and to a large extent will serve only a minimal contribution towards the above objectives. My commentary as a long standing banking credit analyst with in-depth experience of both the recent crisis and the mid 80's crisis is as follows:
1. LTV limits have no direct relationship with repayment capacity. The primary safeguard in making a lending decision is ability to repay. This is based on a full analysis of income/outgoings and specifically sustainability of income source. Repayments are generally stressed at a 2/3% margin to account for increases in interest rates. This must be specific to clients as income multiples etc are not appropriate.
2. Having a 20% deposit does not relate to affordability unless it is based on a savings record over a term. However even in such a scenario a savings record can give a distorted result. If my partner and I are 2 single people living with parents who contribute nothing to rent/food etc then we will have a good capacity tio build up a lump sum to meet a 20% deposit over time. However if we don't have generous parents we may be living in a rented property and the same funds are being used to meet our rent and other expenses. In scerario A we will be regarded as good mortgage applicants. However in scenario B we will not meet the requirements. In both scenarios our net incomes are likely to be the same after purchasing the property.
3. I accept that MII is not without risk. However in the US and some other countries it has tended to work, provided proper regulation is applied to the underwriting company. Remember that MII will only cover a 10% reduction in property price in the event that the market falls. neither MII nor 80% LTV would have made much difference to the market drop that was encountered from 2008. The core issues were related to loan affordability and a >50% drop in market value. What would have worked far more appropriately was a higher level of due dilegence applied to individual repayment capacity. A housing bubble on its own, could have been managed without the disasterous consequences we have seen. However a housing bubble, coupled with a global economic slump and consequent loss of jobs/income resulted in the debt Tsunami we have experienced.
We are now closing stable doors after horses have bolted. Yes I agree that we have new horses to look after and banks need to be properly regulated to ensure they apply a proper level of diligence to all new lending. However, LTV limits will not achieve this and as an end result will continue to reward those with generous parents etc and punish those who are caught up in the high rental market with no equivalent ability to save for a 20% deposit. Lets not be myopic in our approach to this issue and start thinking about affordable lending rather than security ratios!!!
 
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Brendan 44.

Like your comments.



Rather than using a blunt 20% on its own. Would it be possible/sensible to put in (rules) somewhat as follows.

1. Affordability at sanction date to be retained by lender.
If should problems arise in Mortgage ,and before any (heavy) legal action can be taken by lender , that a 3rd party can review the account.
Should it be shown to the 3rd parties satisfaction that the lender was (careless) then the lender cannot follow borrower for shortfall.

I don,t see us as having new{horses} in Banks.What I see are somewhat chastised lenders who are cautious today.
But {horses} are {horses} ,so they will gallop if they get a chance!

I see an issue over Regulation. Our Central Bank has not crowned itself in glory.A lot of Regulatory staff are Bankers, so with the best will in world they have acquired some poor habits.

Diligence in Banks ,will again in time be watered down to suit lending.
Again who does the diligence? I do not think the large Accountancy firms have shown themselves capable.

Regulatory layers and diligence layers tend to become self affirming.

I am not a fan of another Quango ,but maybe we need one, but on a Statutory footing.

Hope we get the balance right.
 
This proposal of 80% LTV is being put forward as a panacea to cover the potential for a further house pricing bubble and to avoid prospective home owners becoming over-borrowed. In my view it is an extremely blunt instrument and to a large extent will serve only a minimal contribution towards the above objectives.

I'm not sure that is really a fair reflection of the Central Bank's objectives. According to the consultation paper, the primary objective of the Central Bank in introducing the proposed LTV/LTI limits is to increase the resilience of the banking and household sectors to financial shocks. Dampening the pro-cyclical dynamics between property lending and housing prices is very much of secondary importance.

I find it difficult to see how the proposals would not help address the Central Bank's primary objective, although I certainly agree that it is no substitute for proper underwriting of individual loans.

I personally don't have a strong view on the Central Bank's proposals but, on balance, I'm inclined to think they are positive.
 
This proposal of 80% LTV is being put forward as a panacea to cover the potential for a further house pricing bubble

Not by the people who wrote the report. They acknowledge that a future housing bubble still might occur, they want to reduce the effect that it might have by these measures.

The banks will still have their underwriting requirements too. These measures will just remind the banks if they think of loosening their lending requirements.

And remember, the 20% deposit applies to 85% of loans given, not all of them. This is something that is rarely reported.


Steven
www.bluewaterfp.ie
 
S Barrett/Sarenco - To be fair I agree that a 20% deposit requirement is likely to dampen prices in the FTB market only. Would generally not be a restriction to trade ups'.
However unintended consequences of this will be an exclusion of renters who have no substantial savings capacity but would have the repayment capacity to meet a mortgage payment. 85% restriction does at face value give banks some scope. However as I mentioned previously in another post, my fear is that due to difficulties in allowing exceptions to this limit and measuring same, banks will make the 80% LTV a Policy limit and the number of exceptions approved is likely to be well below the 15% threshold.
GerryC - I like your Socialist type approach towards making the bank responsible if they breach due diligence rules. It's definitely one that would work. However, it would require new Government legislation in order to enforce it and I don't see this happening unless we head completely Left after the next election in our Government.
Nice and all as that may sound, I'll be first in the queue for a one way ticket out of here if it occurs!!
My point is that Brendan B's post is very focussed on unaffordable lending and LTV limits have no impact on affordability.
 
44brendan.
I don,t want to lose you before the Revolution!

I find it strange that a view to make Banks as accountable as other Professional Bodies is even construed as Socialist.
They appear to have monopolised the {Untouchable} ?

To make someone accountable is good Capitalist Business sense.
Maybe now I am a Tea-Party member!

Have a good weekend.
 
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