10/10/2024
What if Canada's Mortgage Stress Test Went Away?
The government's mortgage stress test (a.k.a. "MQR") kept borrowers and lenders mostly out of trouble as rates soared from March 2022 to June 2024. It was instrumental in reducing the buildup of overborrowing, at least at federally regulated prime lenders.
Now, it's under the microscope. Could it go away altogether?
Recent words from OSFI head Peter Routledge have hinted at just that.
"We will consider the continued need for the Superintendent-prescribed minimum qualifying rate (MQR) for uninsured mortgage originations following the full and successful implementation of the Loan-to-Income (LTI) limit framework," an OSFI spokesperson told MLN today.
OSFI will require federally-regulated mortgage lenders to implement a LTI portfolio limit starting November 1 for the Big 6 banks and January 1 for lenders with calendar fiscal years.
OSFI's comments follow Routledge's revelation at a recent Global Risk Institute event where he said:
“… We're going to test [the LTI policy] next year and if it works the way we want, and we'll probably have to tighten or loosen the bolts here and there, but if it works the way we expect it to, then it is [either] a legitimate alternative or a legitimate complement to the MQR. And we'll make that decision after we have a full year of testing, to make sure if we do anything we do it right.”
Routledge said the stress test mitigated risk significantly. Yet, it's like a financial prophylactic of sorts - it does the job, but nobody's too thrilled about it.
"...There are two challenges with respect to the MQR. The first is that it really didn't stop a very substantial build-up in mortgages with very high loan-to-income ratios, which I define as 450% loan-to-income and greater."
"Unfortunately, during COVID that big block of very highly leveraged mortgages also happened to be weighted towards variable rate products that had fixed payment components to it, which we see as a manageable but serious risk concentration. For all the work we put in the MQR, I would have rather had that risk concentration not emerge. That’s the first challenge."
"The second challenge is by virtue of the way it is implemented, which is at the institution-to-borrower level. It feels to the borrower like it's OSFI regulating them individually. It's not the intent; I could read out B-20 and argue that we actually only regulate institutions and not the borrowers but if you're walking into your branch down on Main Street on a Saturday afternoon to talk about renewing a mortgage or getting a new one it feels like OSFI is regulating you and that is not the intent Parliament has ever set for OSFI."
"OSFI's job is to regulate financial institutions, not Canadians. But the MQR creates that perception and I think that’s a challenge to it. With those challenges in mind, stealing from our peer regulators and other jurisdictions, particularly the United Kingdom, we looked at this loan-to-income test."
OSFI's Peter Routledge discussing the MQR at GRI Summit 2024
Routledge casually tossed another truth gr***de at the event — this time regarding the LTI limit.
"The loan-to-income test is pretty simple. It says every quarter a bank or a lender can only lend 15% of their mortgages in that quarter to borrowers with loan-to-incomes higher than 450%. That is a very effective ceiling that stops the build of risk concentration."
Say what, now? Where did that 15% come from?
When OSFI floated its LTI concept in January 2023, it proposed a "credible, industry-wide LTI volume limit." Its example of credible was limiting quarterly originations so that no more than "20 to 30%" of mortgages (by total dollar value) could exceed 4.5x (450%) of borrower income.
If our abacus is correct, 15% is meaningfully less than 25%, which was the expectation until now (+/- 5%).
Slashing the LTI limit by 10 percentage points could have several ramifications:
Debt ratio exceptions at prime lenders would be meaningfully reduced.
Countless first-time homebuyers—and those with lower incomes—would find it more challenging to qualify.
In some cases, lower LTI limits would contribute to more sustainable household debt levels,in other cases, more borrowers could be displaced from prime lenders, pushed into the arms of more expensive non-prime lenders.
Amid the credit tightening, rental demand could increase to some degree.
It's unclear if OSFI will disclose its average LTI industry-wide.
Moreover, lenders are prohibited from revealing their individual LTI limits. If no one knows the actual overall limit, it might effectively veil the extent of OSFI's policy tightening.
Conveniently, that might help the regulator dodge some heat—and angry tweets. And public perception is clearly important to it.
As Routledge explains it:
"When we looked at that and tested it out, we learned that a single 15% ceiling or 20% ceiling across the industry wouldn't work. We determined we would do it on a bespoke model. We would go institution by institution and calibrate it to those business models.
Our backtesting on that method tells us that it would have eliminated or at least severely blunted this risk concentration I mentioned earlier [i.e., highly-leveraged mostly variable mortgages], and it does not involve the borrower at all. It is a direct regulator-to-financial-institution metric."
"The way Canadians feel OSFI's presence through the MQR is a factor."
So again, one gets the sense that OSFI prefers to distance itself from policies that may be seen as directly and unjustly restraining individual borrowers. They'd rather be the invisible hand than the wagging finger.
Optics aside, Routledge also adds that housing market impact—while not a direct determinant of the LTI policy's effectiveness—is a factor OSFI considers.
"...Enlightened self-interest would tell us [that]...if you had a sudden and volatile shift down in the overall value of collateral that would weaken credit quality and weaken capitalization in the system. We should consider that reality..."
In other words, calibrating LTI levels will involve some trial and error. To a degree, OSFI's playing financial Jenga with our mortgage and housing markets, and they don't want to yank out the wrong block.
Source: Robert McLister Oct 09, 2024