A recent report from the Bank of
Canada reviewed the impact of the government’s policy changes on the mortgage
market. It found that overall market activity had slowed -- something we knew
would happen. The bank also found a correlation between the quality and
quantity of credit. While the data shows
a slowdown in “riskier” mortgages, some economists wonder if these borrowers
have turned to the unregulated market.
Approximately 20% of the mortgage
lending market were made up of people who borrow at least 4.5 times their
annual income to buy a home. That
percentage went down to 6% in the second quarter of 2018. That amount of mortgage
indebtedness may or may not be a problem for borrowers; however, coupled with
other debt, including credit cards, lines of credit and car loans, it may cause
some financial problems as rates rise.
History of Mortgage Lending Changes
In 2016, the Office of the
Superintendent of Financial Institutions (OSFI) announced a stress test for
insured mortgages (mortgages with less than 20% down and requiring mortgage
default insurance), stipulating that those buyers must qualify at the Benchmark
rate (currently 5.34%).
Then in October 2017, a similar rule
was unveiled for uninsured mortgages (mortgages with more than 20% down) stipulating
that those buyers must qualify at either 2% more than the contracted mortgage
rate or the Benchmark rate, whichever is higher.
These two rule changes -- along with
several others, including; increasing minimum down payments, mortgage premium
hikes, and decreasing amortization limits – have made it harder for Canadians
to qualify for mortgages, which is what the government wanted for borrowers ‘on
the margin’. The rationale was to encourage people to take on less overall
debt, including less risky mortgage debt, which would, in theory, keep housing
markets safe and protect borrowers in the event interest rates increased.
The Fallout
Mortgage brokers can attest that the
impact was seen almost immediately. The rate of clients who may have qualified
previously but no longer did from large banks and traditional monoline mortgage
lenders went up as much as 20%.
As a result, alternative lenders saw
an uptick in business as brokers presented highly credit worthy homebuyers and
refinancers with borrowing options in the unregulated space including private
lenders, mortgage investment corporations (MICs) and credit unions. Some credit
unions opted to include the stress test as part of their mortgage lending requirement.
The Bank of Canada admits that this
segment of mortgage lending is growing, although it falls outside their
purview. For example, the market share for private lenders in the GTA has grown
by 50% since last year, and now makes up nearly one out of every 10 borrowers,
the bank said.
There are now questions about risk in
the unregulated market; however, the market is not necessarily riskier, it’s
just not under OSFI’s purview.
What the unregulated market is seeing
are better quality mortgage clients. Hali Noble, Fisgard’s senior
vice-president of residential mortgage investments and broker relations said in
an interview, “A lot of these people should be bankable, but they’re not (when
applying the new stress tests).”
So, many good quality borrowers have
to shift down the ladder to lenders with a higher risk tolerance. The one
downside is it comes with a higher cost, but not necessarily more risk.
Borrowers who don’t fit into the
mainstream box are now not limited to those with past credit issues, and may
include those who are self-employed, those who are new to Canada, and even “A”
clients. They simply don’t fit into the new box.
The Unregulated Market
The unregulated market is primarily
comprised of private mortgage lenders -- companies and individuals -- who fall
outside the purview of Canada’s banking regulators. Private lenders offer
mortgage rates higher than traditional mortgage lenders for shorter terms.
Typically, borrowers who could not qualify for traditional lending turned to
alternative lenders.
Alternative mortgage lenders or
private lenders, also known as “B” Lenders, are more willing to look at each
situation on a case-by-case basis. They do have criteria, but consider a
borrower’s “story”. For example, if a
borrower had a bankruptcy or have some credit issues, they want to know why.
For self-employed borrowers, they will consider other documentation to prove
income rather than a tax return, which may reflect business write-offs.
Interest rates
Yes, are higher compared to “A”
lending, because the borrower profile is considered riskier, but remember it’s
only a short-term solution.
You can also expect to pay a larger
down payment, from 15% to 35%, depending on both your situation and the
property you’re financing. And, there may be lender fees and mortgage broker
fees.
Usually, the pre-payment privileges
are flexible but there may be a charge for paying out the mortgage early. Alternative
lenders are strict about missed payments, and service fees may be higher as
well.
Whatever the reason for needing to use
an alternative lender, the goal is to get back into the “A” lending space.
Is there cause for concern?
Maybe, maybe not. The reason for all
the changes was to ensure that borrowers could manage their debt loads in the
future, as interest rates rise.
Inadvertently, the new rules have grown the unregulated market, which
may or may not defeat the purpose. People want to buy homes and will do what
they need to, to get one.
The increase in demand has caused
interest rates to go up even in the private sector, but these lenders are
short-term lenders. There must be an exit strategy. There is the risk that
borrowers will rely on the private funds for longer terms, which may have a
negative financial impact.
The Bank of Canada is also concerned
about the potential for mortgage default and bankruptcies. Consumer
insolvencies peaked during the 2007-08 financial crisis and have been
relatively stable since 2012. Around 120,000
Canadians went insolvent last year, less than 0.4 per cent of the
country's population.
- Mortgages in arrears across Canada have fallen this year, to one of the lowest levels in history. Only 11,641 mortgages fell into arrears at Canadian banks in January, representing 0.24% of all mortgages held.
- The biggest indicator for potential arrears is a worsening unemployment rate.