The mortgage market has been rocked by the introduction of the new “Mortgage Market Review” changes, which have been implemented over the last few weeks.Â
The intention, to make certain that a borrower can afford mortgage repayments and thereby reduce the likelihood of another market failure and credit crunch, is a remarkably good and sensible intention. The role of avoiding the creation of such â€˜toxic debtâ€™ has previously been the responsibility of banks and the Financial Services Authority, but the new rules have switched a portion of this burden of proof to the client, making it onerous and in some cases potentially impossible for the self or sporadically employed to secure a mortgage.Â
Thus, whilst avoiding a ban on the financial â€˜securitiesâ€™ into which bad debt was bundled along with good debt, passed off as a high-quality investment and sent around the world, the Government has instead sought to cut dangerous loaning off from source.Â
Specifically, the new rules require the lender to carry out checks on the applicants’ income, background and circumstances even before a mortgage consultation including:
1) Full new property details incl. agentsâ€™ details to arrange survey/valuation.
2) Solicitors details incl. contact number.
3) Signed sole trader accounts for the last two years.
4) SA302’s for the last two tax years (These can be obtained by calling HMRC on 0300 200 3300)
5) Full details of any outstanding personal credit commitments.
On the face of it, these seem reasonable â€“ though less so when you try to obtain a SA302. Two members of staff from this office tried to do so last week, spending well over half an hour (the longest was 44 minutes) on hold. Whilst both are familiar with the failings of the HMRC phone service, this was an excessive wait.Â
Still, once these hoops are navigated, all manner of personal and probing questions can be put to you, including:Â
-Â Â Â Â Â Â Â Â Â Is your husband a member of a golf club?
-Â Â Â Â Â Â Â Â Â How often do you have steak for dinner?
-Â Â Â Â Â Â Â Â Â Are you a regular gambler and how much do you gamble per month?
-Â Â Â Â Â Â Â Â Â How much do you give to charity?Â
On that basis, steak twice a week, golf on a Sunday and a flutter on the races might just cost you your next home.Â
Flippancy aside, for a new borrower and acquisition this may reduce the risk of taking on a debt they cannot afford and, in particular, the probing questions are designed to test your resilience to potential interest rate rises. Whilst a number of prospective purchasers will become frustrated despite being able to pay the required monthly amounts, this is likely to only adversely limitÂ the minority and could provide resilience when the Bank of England finally decides to elevate the base rate. For most borrowers with a decent credit rating, these questions wonâ€™t actually be asked.Â
Some existing borrowers however, are potentially in an awkwardÂ predicament if their circumstances have changed since they took out a loan. Recent reports indicate a fall of as much as 12% in the last month in terms of re-mortgage applications.Â New mortgage arrangements due to the end of an initial fixed-rate term or a change of lenders to gain a reduced rate is evidently becoming difficult, with many existing borrowers falling foul of the new rules and not being able to get a rate which they may otherwise have been entitled to. Â
Whilst the real reason behind these changes may be to deflate the current property boom, it is unfortunate that most of the real impact will be outside of the capital. In London, rapid house sales fuelled by foreign demand will only continue, though more first-time-buying locals may lose out to the stringent restrictions.Â
Outside of London, prices which remain at reasonable levels (see our monthly factfile) may be counterproductively deflated as buyers struggle to secure the funds they need. London is undeniably important, but any policy which could potentially harm already struggling areas should be reviewed and scrutinised for its necessity.Â
Nonetheless, the impact of such a change may be less than a BOE base rate rise and a source from inside a building society currently implementing these changes has revealed to us that the regulations are designed to put off this eventuality for as long as possible â€“ perhaps, one might cynically suggest, until after the general election.Â
This might, then, be the lesser of two economic evils.Â
One could argue though, that the real solution to the potential for another â€˜credit crunchâ€™ lies with the regulators, who failed to spot dodgy dealings throughout the early noughties – dealings which led to unknown levels of toxic debt hidden in mis-labelled financial instruments flooding the world and lurking beneath the surface on a thousand banksâ€™ balance books.Â
A tightened regulator which controls the system, pries where they are not wanted, ensures all investment vehicles are correctly labelled for their risk and thwarts (excessively) greedy practices at source could sufficiently avert the risk of future crises, whilst still maintaining the excellent progress the property market is making across the country â€“ that is, after all, what the FSA (and now the FCA) was created for. Fundamentally, if there is no money to be made from bad loans, then they will not be issued and the banks will control the quality of their own lending.Â
Naturally, the Government are frightened of the potential for another crisis. Economically, the last one set us back six years. Politically, the Labour party suffered for its mismanagement. A housing boom can be a double edged sword, but a draconian approach is arguably not the soft handling the situation requires; rather having the potential to be a damp blanket on embers of growth which might otherwise have flared white hot.Â
SRJ / PB / LCB Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â 12.05.14