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Are There More Mortgage Rule Changes Coming?

Katherine Martin • Jul 05, 2017

Recently, the Bank of Canada released its semi-annual Financial Systems Review (PDF document), which identifies some of the major risks that the Bank foresees on the economic horizon.

Unsurprisingly, the Bank pinpoints increased levels of Canadian household debt and rapidly increasing prices in Toronto and Vancouver as vulnerabilities to the financial system. The good news is that, despite these vulnerabilities increasing over the past six months, the Bank of Canada is confident that the financial system remains resilient, and that overall, national economic conditions continue to improve. This positive outlook, combined with strong economic growth, are playing a role in the not-so-subtle hint that the Bank may increase interest rates sooner rather than later.

So what does this policy review indicate for future federal interventions in the mortgage market? The short answer is a lot.

It is no coincidence that the aforementioned vulnerabilities mirror the rationale used by the federal government for the mortgage insurance and eligibility changes in October. The Bank of Canada, the Department of Finance and CMHC are all aligned and focused on curbing elevated levels of household debt and ensuring the stability of the housing sector. This report could be viewed as representative of the problems and policies that the finance department is considering.

It is no surprise then that the Bank of Canada is pleased with the impact that the October changes have had on the debt-to-income ratios of insured mortgages (chart 3). But, the changes have also had an impact on increasing the market share of new mortgages that are uninsured. Clearly, this was an intended impact of the federal government’s changes and now the Bank of Canada is identifying the uninsured space as the next place to consider in terms of whether action is needed.

The Bank’s concerns will likely find a supportive audience at the Ministry of Finance and at CMHC. The data showing the increasing debt-to-income ratios for the uninsured sector (table 1) could trigger an investigation into additional regulation in the uninsured space by the Ministry of Finance or OSFI.

The first measure that is likely being considered is related to Home Equity Lines of Credit (HELOCs). This is clear for two reasons. First, because the Bank of Canada believes that the greater use of HELOCs could also be contributing to increasing household indebtedness. According to the Bank, HELOCs have increased at rates above income growth since early 2016, and have accounted for approximately 10 per cent of total outstanding household credit in recent quarters. Second, the Financial Consumer Agency of Canada recently released a report raising concerns that HELOCs may be putting some Canadians at risk of over borrowing. The timing of this report and the Financial Systems Review may not be coincidental.

It seems OSFI may be considering making changes to its B-20 underwriting guidelines ; the Bank of Canada’s report suggests that OSFI will begin a public consultation shortly.

The critical policy question that the Department of Finance could be considering is whether to extend the stress test for insured mortgages to uninsured mortgages as well. This could create a more even playing field for lenders who originate a greater percentage of insured mortgages and could possibly have an impact in cooling the markets of Toronto and Vancouver. However, it could also negatively impact the rest of the Canadian housing market, which is not suffering from the same vulnerabilities of Toronto and Vancouver and could become unnecessary if the Bank of Canada raises interest rates.

Finally, there was a small policy section in the review that few may have paid much attention to but is important and provides some very helpful insights into the future of Canada’s private mortgage securitization market. The Bank of Canada recognizes that the recent changes have negatively impacted mortgage lenders that rely on portfolio insurance and that the increased growth in uninsured mortgages have created an opportunity for private residential mortgage-backed securities. The Bank of Canada goes even further and suggests that “properly structured private securitization would benefit the financial system by helping lenders fund loans.” (page 13).

It is surprising that this issue hasn’t received more attention because the Bank of Canada is tacitly endorsing a significant policy shift away from CMHC-backed mortgage securities to a private sector mortgage securitization market. This confirms that the creation of this market is an intended impact from the federal government’s changes to portfolio insurance and aligns with CMHC President Evan Siddall’s testimony to the finance committee on the changes to portfolio insurance.

Until the Bank of Canada is convinced that the housing sector no longer poses the greatest liability to the Canadian economy, Canadians will continue to see the federal government scrutinize mortgage activity in Canada with an eye to reduce the increasing levels of household debt in the country..

Let’s hope the government shifts their focus to unsecured household debt instead of further secured debt restrictions. However, if the Bank of Canada’s review is representative of the Ministry of Finance’s considerations, watch out for changes to HELOCs, through B-20 changes, the stress test being applied to uninsured mortgages and continued growth in the developing private sector mortgage securitization market.

This article originally appeared on Canadian Mortgage Trends, a publication of Mortgage Professionals Canada on June 20th 2017. It was written by the manager of government and policy for Mortgage Professionals Canada, Samuel Duncan.

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Katherine Martin

Origin Mortgages

Phone: 1-604-454-0843
Email: kmartin@planmymortgage.ca
Fax: 1-604-454-0842

Why Downpayment Source Matters

By Katherine Martin • 01 May, 2024

If you’re looking to purchase a property, although you might not think it matters too much, the source of your downpayment means a great deal to the lender. Let’s discuss the lender requirements, what your downpayment tells the lender about your financial situation, a how downpayment helps establish the mortgage loan to value. Anti-money laundering Lenders care about your downpayment source because, legally, they have to. To prevent money laundering, lenders have to document the source of the downpayment on every home purchase. Acceptable forms of downpayment are money from your resources, borrowed funds through an insured program called the FlexDown, or money you receive as a gift from an immediate family member. To prove the funds are from your resources and not laundered money from the proceeds of crime, you’ll be required to provide bank statements showing the money has been in your account for at least 90 days or that you’ve accumulated the funds through payroll deposits or other acceptable means. Now, if you’re borrowing all or part of your downpayment, you’ll need to include the costs of carrying the payments on the borrowed downpayment in your debt service ratios. If you’re the recipient of a gift from a direct family member, you’ll need to provide a signed gift letter indicating that the funds are a true gift and have no schedule for repayment. From there, you’ll need to show the money deposit into your account. Financial suitability Lenders care about the source of the downpayment because it is an indicator that you are financially able to purchase the property. Showing the lender that your downpayment is coming from your resources is the best. This demonstrates that you have positive cash flow and that you’re able to save money and manage your finances in a way that indicates you’ll most likely make your mortgage payments on time. If your downpayment is borrowed or from a gift, there’s a chance that they’ll want to scrutinize the rest of your application more closely. The bigger your downpayment, the better, well, as far as the lender is concerned. The way they see it, there is a direct correlation between how much money you have as equity to the likelihood you will or won’t default on their mortgage. Essentially, the more equity you have, the less likely you will walk away from the mortgage, which lessens their risk. Downpayment establishes the loan to value (LTV) Thirdly, your downpayment establishes the loan to value ratio. The loan to value ratio or LTV is the percentage of the property’s value compared to the mortgage amount. In Canada, a lender cannot lend more than 95% of a property’s value. So, if you’re buying a home for $400k, the lender can lend $380k, and you’re responsible for coming up with 5%, $ 20k in this situation. But you might be asking yourself, how does the source of the downpayment impact LTV? Great question, and to answer this, we have to look at how to establish property value. Simply put, something is worth what someone is willing to pay for it and what someone is willing to sell it for. Of course, within reason, having no external factors coming into play. When dealing with real estate, an appraisal of the property will include comparisons of what other people have agreed to pay for similar properties in the past. You’ll often hear of situations where buyers and sellers try to inflate the sale price to help finalize the transaction artificially. Any scenario where the buyer isn’t coming up with all of the money for the downpayment, independent of the seller, impacts the LTV. All details of a real estate transaction purchase and sale have to be disclosed to the lender. If there’s any money transferring behind the scenes, this impacts the LTV, and the lender won’t proceed with financing. Non-disclosure to the lender is mortgage fraud. So there you have it; hopefully, this provides context to why lenders ask for documents to prove the source of your downpayment. If you’d like to talk about mortgage financing, please connect anytime; it would be a pleasure to work with you.

Porting Your Mortgage

By Katherine Martin • 24 Apr, 2024

Porting your mortgage is when you transfer the remainder of your current mortgage term, outstanding principal balance, and interest rate to a new property if you’re selling your existing home and buying a new one. Now, despite what some big banks would lead you to believe, porting your mortgage is not an easy process. It’s not a magic process that guarantees you will qualify to purchase a new property using the mortgage you had on a previous property. In addition to re-qualifying for the mortgage you already have, the lender will also assess the property you’re looking to purchase. Many moving parts come into play. You’re more likely to have significant setbacks throughout the process than you are to execute a flawless port. Here are some of the reasons: You may not qualify for the mortgage Let’s say you’re moving to a new city to take a new job. If you’re relying on porting your mortgage to buy a new property, you’ll have to substantiate your new income. If you’re on probation or changed professions, there’s a chance the lender will decline your application. Porting a mortgage is a lot like qualifying for a new mortgage, just with more conditions. The property you are buying has to be approved So let’s say that your income isn’t an issue and that you qualify for the mortgage. The subject property you want to purchase has to be approved as well. Just because the lender accepted your last property as collateral for the mortgage doesn’t mean the lender will accept the new property. The lender will require an appraisal and scrutinize the condition of the property you’re looking to buy. Property values are rarely the same Chances are, if you’re selling a property and buying a new one, there’ll be some price difference. When looking to port a mortgage, if the new property’s value is higher than your previous property, requiring a higher mortgage amount, you’ll most likely have to take a blended rate on the new money, which could increase your payment. If the property value is considerably less, you might incur a penalty to reduce the total mortgage amount. You still need a downpayment Porting a mortgage isn’t just a simple case of swapping one property for another while keeping the same mortgage. You’re still required to come up with a downpayment on the new property. You’ll most likely have to pay a penalty Most lenders will charge the total discharge penalty when you sell your property and take it from the sale proceeds. The penalty is then refunded when you execute the port and purchase the new property. So if you are relying on the proceeds of sale to come up with your downpayment, you might have to make other arrangements. Timelines rarely work out When assessing the housing market, It’s usually a buyer’s market or a seller’s market, not both at the same time. So although you may be able to sell your property overnight, you might not be able to find a suitable property to buy. Alternatively, you may be able to find many suitable properties to purchase while your house sits on the market with no showings. And, chances are, when you end up selling your property and find a new property to buy, the closing dates rarely match up perfectly. Different lenders have different port periods Understanding that different lenders have different port periods is where the fine print in the mortgage documents comes into play. Did you know that depending on the lender, the time you have to port your mortgage can range from one day to six months? So if it’s one day, your lawyer will have to close both the sale of your property and the purchase of your new property on the same day, or the port won’t work. Or, with a more extended port period, you run the risk of selling your house with the intention of porting the mortgage, only to not be able to find a suitable property to buy. So while the idea of porting your mortgage can seem like a good idea, and it might even make sense if you have a low rate that you want to carry over to a property of similar value, it’s always a good idea to get professional mortgage advice and look at all your options. While porting your mortgage is a nice feature to have because it provides you with options, please understand that it is not a guarantee that you’ll be able to swap out properties and keep making the same payments. There’s a lot to know. If you’re looking to sell your existing property and buy a new one, please connect anytime. It would be a pleasure to walk you through the process and help you consider all your options, including a port if that makes the most sense!