OSFI’s B-21 is Finalized: Update 2

On Thursday, the Office of the Superintendent of Financial Institutions (OSFI) announced its complete B-21 guidelines for underwriting insured mortgages. But it didn’t stop there. The banking regulator also tweaked some of its B-20 guidelines, rules that shook the mortgage market when they were initially released in summer 2012.

This time around, OSFI’s actions will have far less impact on the housing market. 


Oliver Meets With CAAMP

Finance Minister Joe Oliver met with the Canadian Association of Accredited Mortgage Professionals (CAAMP) on Friday. The meeting covered a range of mortgage hot-topics.

CAAMP President & CEO Jim Murphy tells CMT, “CAAMP’s key messages were to provide consumer choice, for example the need to support smaller lenders and monolines, a view that we have had enough regulatory changes and the economic importance of housing and real estate finance in terms of jobs and tax revenues.”


Collateral Pitfalls Disclosed

Collateral-MortgageBanks are improving their disclosures on the drawbacks of collateral charge mortgages.

Effective January 31, 2015, the Department of Finance says banks will start warning individual consumers about the implications of collateral charge mortgages “before entering into the mortgage loan agreement.”

The DoF says “consumers require sufficient information in order to more clearly understand the costs and consequences of a collateral charge mortgage relative to a conventional mortgage.”


Lenders’ Worries

Housing bubble conceptNot many lenders go on record forecasting a housing bubble, but what they say in private surveys is another matter.

FICO, a consumer analytics firm, released poll results on Tuesday that show just how concerned lenders are about housing overvaluation. But its data, which was picked up by multiple media outlets, featured responses primarily from U.S. respondents. The opinions of Canadian lenders, alone, haven’t been fully reported.

Today, however, we got our hands on Canadian-specific data, and it revealed some surprising expectations.


The Public MIC Advantage

Jeffrey D. Sherman, Special to CMT

Public or private. keyboardThe function of Canada’s securities regulation is to protect investors. To help investors make informed decisions, regulated public markets require broad access to information on exchange-listed companies.

In the June 9 article entitled “A Threat to Private Financing,” it was noted that Ontario has restrictions on the sale of securities. These limit many investors to buying only publicly traded Mortgage Investment Corporations (MICs), and not private MICs. This is sound regulatory policy.


A Few Last Tweaks by CMHC

CMHCLast week CMHC eliminated some more mortgage insurance offerings. Effective July 31, for example, it will no longer insure amortizations over 25-years or $1 million+ properties with low-ratio transactional insurance.  (More details here)

Canada’s largest insurer says this was a business decision. But most business decisions maximize profit and/or significantly reduce risk. These changes don’t necessarily do that, making it appear more like a political decision.


A Threat to Private Financing

Wayne Strandlund, Special to CMT

Borrower choice and the success of mortgage brokers is tied to the availability of a wide variety of mortgage funds. Apart from conventional insured and uninsured mortgages, there are Alt-A and B, 1st and 2nd mortgages available through the private mortgage market.

For years, Mortgage Investment Corporation (MIC) lenders have provided billions of dollars of this private alternative mortgage financing. But under proposed regulations, this opportunity for borrowers and brokers will be severely curtailed, causing measurable economic harm.


CMHC Sends Another Message

CMHCSince 2008 the nation’s largest mortgage default insurer has been on a mission to reduce its risk exposure. Yesterday that mission continued with CMHC announcing that it would stop insuring both second homes and self-employed borrowers without traditional proof of income.

Canadians have used these two programs for the last nine and seven years respectively.

But these are not the only adjustments CMHC has in store. It put the market on notice that “This is the first set of changes” we should expect, as a result of its internal insurance business review.

Thankfully, at least one private insurer is not making knee-jerk changes because of this news.

Andy-CharlesAndy Charles, CEO of Canada Guaranty, told CMT:

“We are currently reviewing the announcement and potential implications…(The) overall materiality of the change is modest but indicative of an evolving market dynamic…(We have) no current plans to alter our product offering but, as indicated, are reviewing…”


What’s behind CMHC’s announcement?

  • Terminating these programs appears to be a business decision by CMHC.
  • Sources tell us that the insurance regulator, OSFI, was not behind this decision. (OSFI doesn’t generally impose product restrictions on individual institutions.) Moreover, there is no indication that this news is directly related to the recently released B-21 guidelines.
  • We’re also awaiting comment from the Department of Finance. In recent years its leadership has clearly indicated a desire to see less government involvement in the mortgage market. (CMHC is 100% backed by the federal government.)

Canadian-HousingMarket impact

  • CMHC says these two programs only accounted for a combined 3% of its unit volume.
  • It claims this should not have “a material impact” on the housing market. (Mind you, this is yet another instance where CMHC is withdrawing and/or limiting its programs. All of these “immaterial” changes may ultimately combine to slow the market further.)
  • There is no word yet on whether the second-largest insurer, Genworth Canada, will follow suit. It’s in its quiet period before earnings so it couldn’t comment.
  • Even before this news, it was clear in talking with CMHC sources that it plans to meaningfully reduce its insurance business. This will create further opportunities for private insurers and self-insured lenders (e.g., Equitable Bank, Home Trust, Optimum Mortgage, certain credit unions, private lenders, mortgage investment corporations, etc.)

Housing-and-mortgage-trendsBorrower impact

  • The last day to submit CMHC-insured “stated income” and second home mortgage applications is May 29 (but many lenders may set a cut-off date earlier than this.)
  • The majority of Canada’s 2.7 million self-employed borrowers prove income in traditional ways (for example, using a 2-year average of income from their NOAs, grossed up by 15% to account for write-offs)
  • Self-employeds who can’t prove income traditionally, and Canadians who buy a second home with less than 20% down, will be left with these options:
    • Prime lenders who insure through private insurers (assuming the privates keep their “low-doc” and second home programs intact)
    • Non-prime institutional lenders, who finance up to 85% loan-to-value (less in non-urban areas) at higher interest rates
    • MICs and private lenders who finance up to 80% with even higher rates and fees
    • Private lenders who offer second mortgages in urban areas above 80% loan-to-value
  • Anyone with a CMHC-insured residence will no longer be able to obtain, or co-sign for, an additional CMHC-insured mortgage. There are two exceptions:
    • Bulk-insured mortgages are not affected by this particular rule (“The rules apply to all transactionally insured homeowner mortgages, both high and low ratio,” says CMHC spokesperson Charles Sauriol. “The rule does not apply to loans that are bulk insured — (i.e., CMHC’s Portfolio insurance product.”) Lenders purchase bulk insurance on mortgages with 20% equity or more, typically so they can resell these mortgages to investors.
    • CMHC-insured rental mortgages are also unaffected (“There is no limit on the number of CMHC-insured rental mortgages a borrower may have,” Sauriol adds.)

Rob McLister, CMT (email)

B.C.’s New B-20-like Guideline

mortgage-rules-2012In June 2012 Canada’s banking regulator (OSFI) created guideline B-20 to tighten underwriting practices on conventional mortgages.

To date, provincially regulated lenders (like credit unions) haven’t been significantly impacted by B-20 because OSFI only supervises federally regulated lenders.

But now, for the first time (that we know of), a province has put forth its own underwriting standards along the lines of OSFI’s B-20. That province is B.C. and these are its proposed Residential Mortgage Underwriting Guidelines (PDF).

CMT asked Doug McLean, Deputy Superintendent of FICOM, for details on why these rules were needed and what effect they’ll have. Among other things, it looks like we might be saying goodbye to 80% loan-to-value revolving HELOCs in B.C.