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Posted 1 Comment on CMHC under OSFI control…. another kick in the rear to Canadians. Mortgage News

CMHC under OSFI control…. another kick in the rear to Canadians.

CMHC’s MOVE TO OSFI CONTROL WILL BE A KICK IN THE BUTT TO ALL CANADIAN HOMEOWNERS.

Is this what CMHC staff and Canadian homeowners are thinking?….   That’s right, it could be OSFI head, Julie Dickson on one end, and that’s you and I on the receiving end!

You’ve seen the headlines lately….  “OSFI proposes radical changes under Draft Bill B-20” which was up for discussion until May 1st.    But weeks earlier, Julie Dickson, the head of OSFI made a surprise remark at speech in Toronto’s Board of Trade…(some were calling it an ‘oops’, or a ‘slip-up’ ) where she stated that the proposed HELOC changes were a done deal…  this was on April 7th… well before the May 1st discussion deadline…

And more recently, we saw more questionable remarks from OSFI…. this time from Vlasios Melassanakis, Manager of Policy Development.   “Are the banks equipped to handle a 40% drop (what occurred in Toronto market in early 1990’s)? Need to stress test to find out.”    Is Melassanakis for real?   40% drop??  where is he getting that number from??    Absurd..! and unsubstantiated!   That’s my response.

What’s going on here, you might ask??

Mortgage arrears are low, affordability is high, property values have declined or remained flat across the country except a few pockets including GTA…   So why all these drastic changes?

I was contacted for my opinion by some business writers from our national media.   We were trying to read the fine print… to understand what it all this meant…. and why it had to be done so quickly…  Why do we have move CMHC, a Crown corporation that’s been around for over 50 yrs and making $billion profits for Canada…why do we need to move them under OSFI control?

The dust hasn’t settled yet, but here are some of the changes and my thoughts on what seems to be happening.

  • introduce a limit on secured lines of credit to 65% of the value of your home… down from 80%… this move makes no sense…  this will limit your ability to draw on the equity in your home to invest, access cheap money to run a business (the self-employed are an understated segment of the population that will really suffer), pay for your kids education, or just access funds for personal use…   the govt wants to mandate this product for the first time in history…  and by the way, it’s always been harder to qualify for these products than a regular mortgage.
  • re-underwrite your mortgage at renewal... they propose to reapprove your income, credit, get a new property appraisal at time of renewal… regardless if you made all your payments on time…  where’s the logic?  what’s the point?  Would any lender really tell someone their mortgage won’t be renewed even though they paid fine?  Will they ask you to pay down your mortgage if a new appraisal says your house is worth less?
  • they have even suggested they want to change our long running standard underwriting debt servicing ratios… these have been around for over 30 yrs and have served us well… why the change?
  • OSFI is a regulatory body that provides regulation and supervision to 152 Banks, Trust companies and other Lenders.   They are auditors….  Where is their motive to provide access to mortgage money for prospective homeowner?   This move to push CMHC under OSFI is the biggest change in decades and it’s very risky given that Canada is looked upon as a stable country with a stable banking system…  why would the govt make all these changes?  and why now?
  • let’s not forget some of the comments from Minister of Finance Flaherty.. he suggested CMHC may not even be necessary in the future…  a bold statement.

POSSIBLE EFFECTS OF THESE CHANGES

It’s clear these changes will effect us all….. here are some of the early results of the changes:

  • we have already been informed that CMHC has tightened their lending policies… there was an official communique released last month that stated, more applications will get referred to underwriters for full review….
  • several banks have amended or cut their business for self mortgage programs… end result is higher cost to obtain funding… guess that’s good for who?? not the consumer…
  • less access to the equity in your homes will mean less money towards investments… we have  huge segment of our population that borrows to invest in stocks, properties, etc..  they will have less to access now….  resulting in less money in the economy.
  • we may achieve  a lower personal debt level… but will that help the economy?…
  • less money flowing into the economy can’t be a good thing…  if we wanted to slow things, the Bank of Canada would have raised their Target Rate long ago…. instead, it has remained unchanged since Sept 2010.
  • there will be more..

We’ve heard that a review of CMHC by OSFI will be  completed by June… but the results won’t be published… so we can only guess and speculate as to what changes these auditors at OSFI will be proposing….  We’ll be watching and reporting…..Let’s hope they don’t fix something that isn’t broken.

As always, if there is something you need help with, let me know… I’m happy to help.!


Posted Case study

A complete overhaul of Mortgage Lending in Canada?

  FED GOVT KEEPS TALKING ABOUT TIGHTENING MORTGAGE LENDING POLICIES

But why?  Why does the govt believe there is a need for all this change?  That’s the question most industry insiders are asking.  Here are some facts with my thoughts mixed in….  tell me if you see some contradiction between the different branches of the govt or a lack of consistency:

  • Surprise…we don’t have a mortgage default problem… Mortgage arrears in Canada are 0.38% as of January 2012.   In Ontario, the housing hot spot, arrears are only 0.28%.   These figures are very low by anyone’s standards.
  • The average resale price dropped 0.5% nationally.  But resale prices in Toronto, are up around 7.3% in a year-over-year comparison.  But that trend is cooling according to The Canadian Real Estate Association.
  • Inflation isn’t a problem… it’s hovering at 1.9%, well within acceptable levels.
  • Housing affordability hasn’t really changed in 10 yrs according to the RBC housing affordability index and it actually improved in Q4 of 2011 (it’s probably even better this year as interest rates are even lower).
  • Personal household debt is around 153% of income.  That’s a record high number, it’s true, but what are Canadians borrowing for?  Studies tell us it’s not for big screen TVs or trips to Bahamas…  We’re actually investing… in stocks, mutual funds, real estate here and in the U.S.  In fact, we are the biggest foreign buyers in Florida and we are also buying in Phoenix, Arizona in record numbers…. Is buying a second home a bad investment?
  • Did you know that 1/3rd of Personal Debt is non-mortgage debt including high interest credit cards, loans and unsecured lines of credit…. yet, there is little to no regulation for these products…
  • Speaking of credit cards… the arrears rate is just over 1.00%... that’s around triple what mortgage arrears are!  Why isn’t the govt clamping down on these credit products?
  • Record-low interest rates were brought in to stimulate the economy.  Haven’t Canadians played their role to kick-start the economy?  Why does the govt want to punish homeowners now with tougher qualifying rules?  OSFI has even proposed you re-qualify for your mortgage at renewal time!!   How absurd is that?
  • The Bank of Canada wants to raise rates to slow our personal debt growth…   but can’t for fear of slowing the economy…
  • The Federal Minister of Finance, Flaherty, wants to tighten mortgage lending to slow the housing market and reduce the amount of mortgage debt we take on.
  • The housing market accounts for up to 40% of this country’s GDP… all these changes will affect our economy.
  • Business for Self mortgage programs have been eliminated by some banks and other Lenders… making borrowing more expensive for this segment of our population…. by the way, they are paying their mortgages just fine.. there is no evidence suggesting Business for Self borrowers have repayment problems…
  • CMHC opted out of rental property mortgages last year in an attempt to slow real estate investment… so you must come up with 20% down or use equity from other sources for the down payment..

FED GOVT’S LATEST MOVE IS TO PUSH CMHC UNDER OSFI CONTROL

  • OSFI will assume control over CMHC, the country’s national housing agency…. You will have an audit dept overseeing a social program… hmm, I wonder what will happen to CMHC??  The possibilities frighten me and should frighten most Canadians… (more on this later).
  • Minister Flaherty made a comment that maybe the govt should consider selling CMHC…  say goodbye to a business that nets over $1billion a year.. $16billion since 2002.   Here’s an idea…why not split CMHC into 2 business… bulk insurance business and the traditional low down payment business… wouldn’t that keep the Canadian dream of home ownership alive and also satisfy the auditors, like OSFI??
  • OSFI wants to limit Secured Lines of Credit to 65% loan to value from today’s 80% loan to value…  This one makes no sense and has received harsh criticism from Financial Experts…. scares me to think that it’s even gone from thought to paper to print… what other changes were they considering that didn’t make it to print??

MY SUMMARY OF IT ALL…

In short, the govt wants to keep the economy stable but they are going to make it harder for you and I to qualify for a mortgage….  Yet, there are no changes coming for the most expensive of debts… Credit cards, loans and unsecured lines of credit rules either don’t exist or will not change…  For some reason, the govt thinks it’s okay to borrow at 7% , 8% for unsecured lines of credit and pay 18% to 20% on credit cards, but please don’t borrow for a home, at 3% and 4%??

If we continue to make it harder for Canadians to get a mortgage, then we will have fewer home sales.. Fewer home sales will affect ALL HOME VALUES and slow the economy.  It’s really that simple…  this affects the biggest asset that most of us will own… our home!

Let’s hope the govt thinks like a carpenter… measure twice and cut once… !

If you’re a homeowner and aren’t sure how these and other changes might affect you, feel free to contact me anytime.   I’d be happy to help.

Posted 2 Comments on OSFI will now oversee CMHC…. lookout Canada…! Mortgage News

OSFI will now oversee CMHC…. lookout Canada…!

Canada’s Minister of Finance, Flaherty, surprised many today by tabling a budget bill with a major legislation change.   The bill would move Canada Mortgage and Housing Corporation (CMHC)  under the control of the Office of the Superintendent of Financial Institutions (OSFI).   This would also give the Minister of Finance even more control over CMHC.  Here’s an article in the Globe and Mail.

So let’s think about the impact of this proposed legislative change…   Over the past 4 years, we have seen numerous changes to CMHC lending policies…

  • Maximum amortization has dropped from 40 to 30 years.
  •  interest-only payment mortgages came and went in 2 years.
  • 100% loan to value or no money down mortgages came and went over a 2 year period….. you must now put at least 5% down payment.
  • rental property mortgages could be had for up to 100% loan to value and are now not being insured at all.
  • Business for self could get mortgages up to 95% for purchases but are now capped at 90% ltv.
  • You could Refinance your mortgage for up to 100% ltv and now it’s capped at 85% ltv.
  • Variable rate borrowers have to qualify at BIG SIX Bank posted 5 yr rate, compared with discounted 5 yr rate or 3 yr fixed rate.  A clear move to force you into the higher 5 yr fixed rate…. supposedly it’s safer to be in a 5 yr fixed rate…(guess the govt has looked at any rate comparison charts for the last 20 yrs).
  • Secured lines of credit could be had for up to 90% ltv CMHC insured, then CMHC pulled out altogether leaving the max at 80% ltv and now OSFI wants to cut them back to 65% ltv (this move has everyone confused and puzzled).

Aren’t all these changes enough?  How much tighter does the govt need to make it?  And all these changes have come prior to Julie Dickson, head of OSFI, being involved….  What scares me and should scare you, is that OSFI has come out and stated they want to cap the amount of equity you can access in your home…. That’s right… OSFI wants to limit your secured line of credit to 65% loan to value.    This proposed change is beyond my understanding.  It’s so out of line that it defies any common sense.  For the first time that I can remember, the govt is telling Lenders and Banks how much they can lend to you for uninsured loans.     If you don’t like this, then stand and up and have your say… write to OSFI and tell them you don’t agree…

I can tell you that within my own base of clients, this will affect a great number of people… the professionals, the business for self, the investor that wants to borrow to invest…  remember, these are everyday people that want to do better but will now be handicapped by your govt because they can’t access the equity in their homes..    It won’t stop them, it will just cost them more to borrow as they seek other, higher interest credit products…. (Banks will win yet again).

If OSFI does gain control over CMHC, then lookout… we can only imagine the possible changes that they are conceiving.

Posted Consumer Debt

Govt to cut Secured lines of credit to 65% loan to value…

Thursday’s speech by OSFI head, Julie Dickson, at the Toronto Board of Trade, indicates it’s a done deal.  Secured lines of Credit will be capped to a maximum 65% of the value of your home.  “…the guideline does set out some firm rules that all institutions will need to adhere to – specifically that home equity lines of credit – or HELOCS – can have a loan to value ratio no greater than 65%….”

WE’RE MAKING SOME CHANGES…. I MEAN, WE ARE PROPOSING SOME CHANGES…

It was only a few weeks ago that OSFI issued a Draft B-20 guideline, a guideline that is filled with radical changes to mortgage lending rules and policies.    It was supposed to be up for discussion, with a May 1st deadline…. So much for discussion…. it appears the decision was made already according to Ms. Dickson’s speech today…. here’s a copy of that speech… April 5 2012 remarks by Julie Dickson.

90%, 80% AND NOW 65%???… WHEN DOES IT END?

Remember 2007?  It was just a few years ago that CMHC was offering 100% loan to value, interest only payment mortgages.  Back then it was good to borrow at these levels…. And HELOC’s could be had for up to 90% LTV.  Over the past few years, the govt has tightened up mortgage rules in an attempt to reduce access to credit.    Mortgages were amortized for 40 years, then cut back to 35 and now 30 years..  But now the govt believes they need to step in again and limit access to your equity by reducing the Loan to Value limit to just 65%….   I looked back to some historical lending policies and couldn’t find a time when the govt ever imposed a limit of just 65%.   It is unheard of! And it’s going to have a big effect.

SO WHAT’S THE PROBLEM?

OSFI is finding a solution to a problem that doesn’t exist.   I don’t think they realize that Banks have pushed borrowers into lines of credit for years now, as a way of providing easier access to the equity in their homes.    Canadians aren’t buying new TVs or new cars or other luxury items… they are using the equity to improve their net worth by buying investments.   Why is this a bad thing?   Are our defaults up?  NO!  Then what is the problem….?

WHO WILL THIS AFFECT AND HOW?

If you are a self-employed person and ever tried to get a business loan from the Bank, then you know how difficult it can be to get an approval… but even if you do, the repayment terms and interest costs could be a hard stop.   End result is that business idea could remain just that… an idea that never got launched.   One of the more popular alternatives was to access cheap money by borrowing, against the equity in your home.  Mortgages can be great but if you need to borrow, repay and borrow again, then a mortgage can have costly registration fees and penalties.  But through a HELOC,  the repayment terms are great and it’s also a much lower rate of interest than any business credit facility.

Borrowing to invest isn’t anything new.  A HELOC allows you to access YOUR equity at preferred rates.   How about buying a second home or a rental property?  You could use the equity in your home to help with the purchase and HELOCs give a separate accounting which makes reporting to Revcan much easier.

How about borrowing for your child’s education?   Are we going to force Canadians to refinance their mortgages in order access cheap money?   I’m sure the BIG SIX Banks will love to see you break your mortgage and pay their infamous penalties.

END RESULT

Get ready, because you are about to see us pushed into higher interest, unsecured lines of credit (oh yeah, there wasn’t any mention of reviewing these lending policies… that’s because NONE exist!).

Which debt would you pay last…. a mortgage, a secured line of credit or a credit card or unsecured line of credit?    Obviously, it’s the unsecured debts would be last on our list… we will always pay for the roof over our heads…. which is why the defaults are still very low and within very acceptable levels.

We are going to see many Canadians discouraged from investing.. they won’t want to go through the trouble of borrowing with a mortgage…  Congratulations OSFI, you’ve made borrowing more expensive….you’ve made investing for our future tougher than it has to be.

The WINNERS… the BANK…. The LOSERS… you and me, the average Canadian…!

Posted 2 Comments on OSFI’s latest proposals will affect every mortgage and line of credit.. Consumer Debt

OSFI’s latest proposals will affect every mortgage and line of credit..

Earlier this week we saw a draft guidelines proposed by Brock Kruger from  The Office of the Superintendent of Financial Institutions.  Yes, more tightening of mortgage and secured real estate lending……  To put this in plain language, the proposal will affect almost everyone… it will change how mortgages and secured lines of credit are offered….. in shorty, I think this plan is trying put out a fire that doesn’t exist.  There is no need for the changes.

Draft B-20 just goes too far…..   they target mortgages but also Home Equity Lines of Credit (HELOC).    Most of the media coverage on this has been somewhat neutral.. but finally we have seen one reporter question these proposed changes.  This article by Peter Foster in the National Post was great…   He questions why we need any more changes when our mortgage and banking system is the envy of the world….  There is no emergency, no arrears problem, nothing to indicate our mortgage lending policies are overly generous.

It should be noted that non-bank lenders will not be affected by this… leaving them as a potential winner if these guidelines become policy…

Here’s a link to the entire 18 page draft.

SUMMARY OF THE PROPOSED CHANGES:

–Cash back mortgages could disappear.. currently, one could get a mortgage for 95% of the purchase price at Bank posted rates and then get a 5% cashback.  The cashback can be used as the down payment.  ( I don’t see many reasons for applicants to buy with no money down so this isn’t a big issue for me)

-homes would have to be appraised at renewal time… this is just crazy… can you imagine if your property value dropped and the bank asked you to pay down your mortgage at renewal time or even worse, call in your mortgage?  What’ s OSFI trying to do.. force everyone to take a 10 yer fixed rate mortgage?   They have already made Variable Rate mortgages harder to qualify for…. what’s the matter, they don’t want us to pay less interest?  

–HELOC’s would have to be amortized meaning NO MORE INTEREST ONLY PAYMENTS...  this one will affect more households and business owners than the OSFI probably realizes… businesses use their homes to finance businesses… that’s been going on for decades… but they aren’t borrowing with no assets.. remember, they are putting up their homes as collateral.. if we start to make it even more difficult for self-employed to obtain financing, this will affect the economy almost immediately.  But how about the 2nd or 3rd time buyer in their 30’s or 40’s that wants to tap into their equity for investments… ?  Are we going to eliminate all interest only payment facilities?  

-HELOC’s maximum would be reduced from 80% to 65% loan to value of your house…. and let’s not forget that just a few years ago we could have obtained up to 90% loan to value through CMHC insured products. Again, just another crazy idea and very radical change in just a few years… where is OSFI taking us?

–mortgages would require tighter debt servicing guidelines including fewer exception approvals by your lender…

Mr. Kruger, your intentions may be honorable, but you are not being practical or realistic.   Why have you introduced these proposals?   To reduce access to credit?   To make it more difficult for Canadians to tap into their home equity?   To make it tougher to buy a house?     Whatever you think these changes might do, I can tell you, as a 22 year mortgage industry veteran and industry insider, that these proposed changes will just shrink our economy, force us to take longer fixed rate products resulting in even higher mortgage penalties for the Banks…  It will force us to tap into our credit cards and unsecured, higher interest credit facilities.… It will force business owners to pay more for raising capital… it will discourage investors….

Give this one a rethink… you are searching for a solution to a problem that doesn’t exist.