Liberal local lending rules tightened: Cameron McEvoy

Liberal local lending rules tightened: Cameron McEvoy
Cameron McEvoyDecember 17, 2020

April 24th, 2015 was a significant date in the Australian property investment landscape. Why? On this date, APRA (the Australian Macro Prudential Authority – an institution who helps regulates the rules of play for banks and other kinds of lenders) implemented some new rules / codes of conducts for lenders to adhere to.

The new rules mean that for some lenders who previously had very liberal lending rules and practices for local Australian property investors; had to tighten them up to comply with APRA’s policies.

Whilst it is still early days; we have seen a number of “Big 4 lenders, as well as many other tier #2 and tier #3 lenders, begin to implement more restrictive borrowing rules for investor-based loans.

These have come in all shapes and sizes, such as (but not limited to):

- Restricting maximum LVR (loan to value ratio) allowance for ‘investment’ category mortgages from, say, 90/10 to 80/20. Part and parcel with this has been some lenders refusing to allow LMI (Lender’s Mortgage Insurance) as a capitalised cost on to loans at those higher (say, 90/10) LVR ratios.

- Removal of discounted interest rate package deals for their mortgage products; again, for investor-only mortgages (many lenders have retained discounts for owner-occupied, or PPOR – Principal place of residence – loan products)

- In light of further interest rate cuts from the RBA in recent months; some lenders have; whilst passing on rate ‘cuts’ not actually reduced their ‘calculation of repayment capability’ for mortgage applicants. What this means is, let’s say when interest rates were 0.50 basis points higher, several months ago, and lenders were calculating an applicant’s serviceability based on a scenario where interest rates spiraled to say, 7% (they run these calculations as standard for all applicants); typically when RBA rates drop by 0.50 basis points; so too should the lender’s serviceability calculation assumptions (I.e. their calculation should be using a rate of say 6.50%, not 7%). However, lenders in recent months have maintained say that 7% figure in that calculation.

These changes have substantial implications for would-be property investors: 

1) The reduced LVR allowance by lenders means borrowers need to cough up more initial deposit. Say you wanted to borrow to buy a $300K investment property. Some lenders at 90/10 LVR acceptance would only require your $30K (10%) deposit, plus purchase costs. A drop to 80/20 means borrowers need to find another $30K to make up a $60K deposit.

2) Removal of discounted interest rates also is a deterrent to first-time investors entering the market, as their interest repayments will now be slightly higher than what home owners pay. There could thus be a cooling of investors being active in many markets throughout Australia.

3) For investors who remain active or don’t perceive the above two changes to inhibit their ambitions; they’ll continue with their property investment purchases. However, they simply won’t be allowed to borrow as much. If banks are calculating serviceability based on a higher ‘worst case scenario’ forecast; the banks won’t lend as much. To some investors, this could be the difference between being allowed to buy a $500K investment property, to now only perhaps $320K – $350K. If this eventuates, this will be a game-changer in the market as it’ll wipe a lot of the Sydney and Melbourne potential investor buyers out (who can play in the Sydney and Melbourne markets with >$350K, these days) and into lower-median markets such as Brisbane, Adelaide, Hobart, and some regional centers.

The role of foreign investors in amongst APRA rules for local lenders: 

And what of the foreign investors? What will be the effect on foreign investor demand of APRA-inflicted local bank and non-bank lender restrictions on investment-based loans? This is hard to infer with any kind of concrete certainty; due to all data relating to foreign residential property investors (including actual volumes of them; types of financing etc.) not being readily available to the public.

As such, there is already speculation and confusion on just how many foreign investors are using the following kinds of financing for their Australian purchases:

a) Pure cash from overseas sources/local funds, to buy (no loans required). In this instance; APRA regulations on local lenders will have zero consequence on foreign buyers; or;

b) Financing/loans given by their local country’s lenders (in these instances; the lending rules imposed by APRA on local Australian institutions don’t apply – meaning foreigners may continue to have access to great cost-efficient mortgage products, for the purchase of Australian property); or;

c) Foreign buyers who are accessing local Australian lender mortgage products. For this type of foreign buyer; the APRA rules will have the same consequence as for local buyers.

When comparing drivers for foreign investors to local investors, we must be mindful that there are so many more variables beyond purely the loan or finance structure of choice, that affects their overall attraction to buying property in this country. For instance; exchange rates, FIRB levies or taxes they must pay, the type and condition of the housing stock they have access to, to purchase, are just a few of the many other factors related to foreign investor demand in this country’s residential housing stock.

So – and I must stress this is pure speculation based on the resources and news I’ve been reading on this subject – there are two quite likely outcomes I would speculate as a result of the tighter APRA rules on local lenders, in regards to the effect of these on foreign investor interest in the market, and on residential property values as a result:

1) Local buyers (investors, not home owners) get scared off and this takes a substantial amount of ‘heat’ out of 'most' markets. I say ‘most’, because the exception (as in; the markets that will still remain hot despite the APRA rulings) will be the foreign-investor ‘obsessed’ postcodes around Australia. These are the suburbs built in areas where foreign buyers and local buyers alike; both highly desire to purchase in. I say this because though we don’t know what foreign investors are using what finance structures; a more consistent and reliable metric of measurement here, is the actual postcodes they take interest in buying within.

2) Or, more markets will remain hot anyway. Why? Because those wannabe local first home buyers (FHB’s) who were thinking of applying the recently growing strategy of ‘Keep renting and buy an investment property now instead of a home; to kick start some growth so I can have enough money for a home deposit later on’, will throw that strategic approach straight out the window and say ‘nope, forget investment, the APRA rules don’t make it worth the effort; I’m going to go for that home purchase straight off the bat; better rates, discounts, and possibly LVR’s (depending on their chosen lender…) so I might as well go ‘all-in’ and buy my dream home’.

Unfortunately, for FHB’s who want to buy into suburbs that also happen to double as hotbeds for foreign buyers; the same bubbling of high housing prices will remain, and continue further. However, in this instance, opportunity could present for FHB’s buying in non-foreign-buyer postcodes, as the local investor volumes will dilute, which should deflate the bubble in those other postcodes enough to help FHB’s.

So, if either of these outcomes eventuate, I think it can only be a good thing for FHB’s, and less so for local investors. Foreign investors will likely remain unperturbed in their relentless pursuit of the postcodes that they so desire.

This means that in postcodes where the top 10-20 schools are, per-state (the ones where the Chinese investors specifically, are most active); prices will likely remain as high as ever.

 Cameron McEvoy is a NSW-based property investor and maintains a blog, Property Correspondent. He can be contacted here.

Cameron McEvoy

Cameron McEvoy is a NSW-based property investor and maintains a blog, Property Correspondent.

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