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Frustration mounts as lenders’ expense policies lack clarity

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The Adviser

A leading broker has voiced frustration over the lack of clarity from lenders over the documentation and evidence they need to service loans.

Following the suggestion during the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry that ANZ was “non-compliant with the National Credit Act, responsible lending obligations and with regulatory guides issued by ASIC” by not verifying “inconsistent” living expenses, many lenders have been tightening up their credit policies around expenses and benchmarking.

The Commonwealth Bank of Australia (CBA) brought in new debt-to-income measurements for borrowers last month, and Westpac updated its expense guidelines, requiring borrowers to provide documentation at an “itemised and granular level” across 13 different categories and include expenses that will continue after settlement as well as debts with other institutions. 

Building on concerns raised that the ongoing crackdown on living expenses is an “overkill”, Aussie Parramatta principal Ross Le Quesne told The Adviser that he believes there was still a lot of confusion over what exactly lenders want to see to satisfy expense checks.

 
 

Speaking to The Adviser, Mr Le Quesne said: “I do a lot of property investors and we’re now seeing property-related investment expenses as a separate line for those criteria.

“So, where clients may think they have a positively geared property portfolio and it’s looking after itself and not costing them a lot of money, that needs to now be detailed in an investment property’s line. And that obviously takes away from what they can afford to repay and what they can afford to borrow.”

However, the leading broker said that one major source of frustration was a lack of coherence around what is actually required to service a loan.

The leading broker said: “The market is definitely different. I think there is a lot of fear in the market at the moment because with the things that are coming out of the royal commission, it means that [lenders are] being very conservative from a risk profile.

“No one is prepared to go outside the lines. So, the number of documents that we are getting asked for, as brokers, has significantly increased [because] the banks want to dot the i’s and cross the t’s of a lot of their files.” 

He continued: “I don’t think the banks even know what documents they want right now. You can practically tear up their checklists because they are coming up with all this stuff that is not even on their checklist. 

“This is what is frustrating and challenging for brokers in the market right now because it is an unknown. As soon as we know exactly what we need to provide and our systems and processes can change to be able to provide that on a consistent basis, then it will set in to the new normal.

“But the period of change is frustrating for us and it’s frustrating for clients, because there is not that clear expectation and guidelines in place.”

The broker added that the additional checks and multiple touch points had led to a slowdown of approvals (which ANZ CEO Shayne Elliott had previously warned would be a likely outcome of tougher expense checks), highlighting a case where a lender came back for clarification on a $79.99 iiNet charge on a borrower’s statement. 

“Everyone knows that is an internet charge, so the level of detail is crazy… and it definitely has slowed down approvals,” Mr Le Quesne said. 

The Aussie broker added that it was therefore increasingly important for brokers to have conversations with their clients early to prepare them for the deep dive into their expenses.

“I think communication is really important. Obviously, clients are going to be asked for more documentation than they’ve ever been asked for before, so it is important that we communicate that, explain the new guidelines and what the possible flags are to customers ahead of time. That way, if it does come up or if there are questions around it, it is not a surprise to them.”

[Related: ‘Overkill’: Top broker questions living expenses crackdown]

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Comments (4)

  • Some good commentary above - my time is now spent focusing on pulling apart bank statements (which are inherently difficult for many customers to obtain) - rather than actually focusing on the customer requirements.

    HEMs is an efficient, yet inaccurate method that leads to poor outcomes for those on lower incomes, and higher risks for those on higher incomes.
    100% expense verification is extremely inefficient, poor method that leads to poor outcomes for all due to inflexibility of assessment. (If a customer had to choose between the overseas holiday and paying the mortgage....)

    A % of income calculation provides for easy scalability, efficient applications, but carries with it an inherent risk.

    All broker's want is consistency - when dealing with poorly trained, inexperienced or incompetent assessors the simpler solution is almost always best.

    A more accurate base expenditure figure determined on family income (the base level of HEMs is set FAR too high for lower-income families), with verification and assessment on "additional" expenses (such as Private School Fees, Insurances, ongoing liabilities) would provide for a far more accurate expenses position.

    0
  • The collection and assessment of everyday items that make up the clients living expenses, is wasting everyone's time and resources. In the example above regarding the iiNet Bill of $79.99, there is nothing stopping the client from going out tomorrow and increasing this expense to a new plan. And what if in one month they go over their data cap and get charged additional megabytes? Does the Bank need a copy of iiNet's contract to ensure that the $79.99 bill is locked in as a set amount regardless of the amount of data the client uses in any given month? What is the difference between a Bank assessing a Credit Card debt as if fully drawn, even if the client pays the Credit Card in full every month via a Direct Debit?

    Where is this going to end?

    KISS...

    Allowance - 40% of Net Income to cover Living Expenses (which obviously increases the more you earn)
    Allowance - 10% of Net Income to cover Other Financial Debts (regardless if they have some because the car they drive today won't be the last they buy in their lifetime)
    P&I Loan Repayment (after any I/O Term) calculated at their actual Interest Rate - Cannot exceed 40% of Net Income - allowing 10% for future rate rises (instead of using an arbitrary assessment rate of 7.25%)
    Investment Property Loans - we calculate gross rent (Valuer's Estimate/Managing Agent Estimate or Actual current Tenancy Agreement, which ever is less) less 15% Management Fees, less estimated property costs, less P&I Loan Repayments (after any I/O Term) calculated at their actual interest rate. If cash flow negative (before tax & depreciation), let's assume it is 10% of their Net Income, then their current home loan repayments (or own rent payable) must be less than 30% of their Net Income.

    Maximum Home Loan/Rent payments &/or Home Loan/Rent + Investment Property negative cash flow (before tax) cannot exceed 40% of Net Income

    We ask, 'How much can you afford to pay towards your loan repayment, without affecting your Other Financial Debts and Living expenses?' And every client who I ask this question always give me a figure because intuitively they know what they can or cannot afford. As for FHB, the same question applies + current rent they pay, which ceases when they move into their first home.

    If the amount they say is less than 40% of their Net Income, then this is where we need to ask some questions about their Living Expenses.

    'Do you have any large expenses, like Child Care/Support or Private School Fees that may cease in the future?'

    If the expense is discretionary, due to cease in the next 5 years and represents less than 10% of their Net Income, we can proceed with a loan amount repayment that is 40% or less of their Net Income, so long as we make appropriate notes that the client signs for that details any potential issues if income is reduced, or expenses increase.

    Child Care is non-discretionary because the only way to avoid it is to stop work, which reduces income, whereas Private School Fees is discretionary because you can easily move your child to a government school.

    The current path of obstructive compliance is turning our industry into joke...

    Pro Broker
    0
  • I spoke with a new, potential client on Monday, who the previous week was in a Westpac branch and she said:
    "Westpac asked for heaps of information and then went though my Living Expenses, which I was put on the spot to provide details that I was unprepared with the information she wanted to know."
    I asked, 'So what was the figure you came up with?"
    My clients said, '$1,600 per month...' ($19,200 per year)...
    I asked, 'Did you provide all of the details or did the Westpac Loans Officer prompt/suggest the amounts?'
    My client said, 'Some of the figures I tried to work out myself, but others were prompted and I felt pressured to just say yes.'
    I asked, 'How much did they pre-approve you for?'
    My client said, '$540,000'
    I said, 'Firstly, as a single mum with 2 dependants, the poverty line expenditure is approximately $2,850 per month or $34,200 per year. I can guarantee that you are spending more than $19,200 per year on living expenses, would you agree?'
    My client said, 'Yes'...
    I said, 'You earn $95,000 per year, so after tax this is $70,000 per year. What Westpac are saying is that from that $70,000 you pay rent of $500 per week or $26,000 per year, you have no other debts, therefore $70,000 less rent of $26,000 less living expenses of $19,200 = $24,800 surplus funds. Did you have $24,800 in savings last year?'
    My client said, 'No'
    I said, 'Therefore you spent more on Living Expenses and if your Westpac Loan Officer submitted a loan application, only stating $19,200 in Living Expenses, they have effectively committed fraud because clearly the information is false and misleading... but the culture of these large institutions is that they have no regard for the authorities and the Loan Officer who is chasing KPI's if ever found guilty of fraud would only ever get sacked and get a job in another institution...'

    Clearly the Westpac Loans Officer doesn't know anything about Responsible Lending, has been instructed / taught / coached by her superiors to keep Living Expenses to a minimum and/or is under pressure to maintain her KPI's. As a Bank Loan Officer, they have no fear of being fined up to $200,000, go to prison for 8 years, lose their ability to work in the industry, therefore your career, which is why my story above is the norm...


    The expense debacle will only continue until strong leaders in the Mortgage Industry get together and change the way all lenders calculate 'serviceability'. Some lenders classify 'Communications' as discretionary, which in today's society, it clearly isn't. Some lenders add up Child Care & Education together, whilst other separate these categories. And if they are going to ask for Investment Property Expenses, then they need to include 100% of rental income instead of 80%.

    I disagree that we should go down the path of using technology providers who can suck out 12 months worth of data because living expenses is always going to be variable, in particular for FHB who have grown up to the point they have have decided to buy a property instead of going out to bars, restaurants and nightclubs every weekend.

    Instead of using HEM as a guide, ASIC should provide details on their classification of Mortgage Stress as a percentage of Net Income. For example, if Mortgage Stress is when you are spending 50% of your Net Income on loan repayments, then no lender can provide a loan if the actual repayments are greater than 40% of Net Income. Other financial debts don't exceed 10% of Net Income, allowing 50% of Net Income to cover Living Expenses.

    Anything would be better than the current situation of collecting clients private expenditure details for the sake of collecting data...

    Pro Broker
    0
    • I agree with you that all this expense gathering process is a total joke. But what's wrong with just using HEM??

      Why would we want to use a net % of income as a blanket stress level? I'm sure I could get by without much stress on 50% of say $1Mil / year.

      I think part of our industries problem is we have a confusion of a thousand new and wonderful ideas, when the regulators simply needs to be educated that the system that had been in place for many years was working perfectly well.

      A few regulatory adjusted around the edges to remove more risky lending practices in small pockets of our industry was all that was needed. Not major adjustments to loan servicing practices.

      Spartacus
      0
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