Thank you very much, Mr. Chair, and thank you for the opportunity to present to the committee today.
My name is Paul Taylor. I'm president and CEO of Mortgage Professionals Canada, Canada's mortgage industry association representing 11,500 individuals and over 1,000 companies. We include mortgage brokers, mortgage lenders, mortgage insurers, and service industry providers.
The mortgage broker channel we represent originates 33% of all mortgages in Canada and over 50% of mortgages for first-time homebuyers, which equates to approximately 80 billion dollars' worth of economic activity annually. Canadians are also increasingly choosing mortgage brokers to obtain a mortgage. Our most recent data shows that, year over year, mortgage brokers have been used 9.6% more this year than last.
Not all the traditional bank products are available through the mortgage broker channel, which is an important distinction to make. The recent changes are having a cumulative negative impact on the mortgage marketplace and ultimately on the Canadian consumer. In light of this, we're asking for some slight amendments to portfolio insurance, which I will get to shortly.
As the committee is probably very well aware, as of November 30, all mortgages submitted for inclusion in portfolio insurance are now subjected to the same stress test as high-ratio insured mortgages and many important categories have also been made ineligible. These changes disproportionately impact non-traditional bank lenders who rely on the portfolio insurance mechanism for liquidity and ease of access to capital.
As an example of the impact of these changes, Genworth Canada estimates that if submitted today approximately one-third of their total volume of mortgage insurance written in October 2016 would no longer be eligible.
Banks can take loans onto their balance sheets. Smaller lenders do not have the same capital volumes to effectively compete. As a result, all ineligible portfolio insurance mortgage products now have to be financed by the smaller lenders through other private capital mechanisms, which makes their products more costly for consumers and therefore uncompetitive.
From a policy perspective, if the intent of the stress test is to protect highly leveraged buyers from themselves, then all consumers should be subject to the stress test to ensure a fair marketplace. OSFI could achieve this by amending the required underwriting guidelines.
Also setting the stress test at the Bank of Canada's current five-year rate serves to imply that the government's intention was to favour the big banks over smaller lenders. This rate is set by the mode of the big five banks' posted rates, which in effect allows the banks to control the rate that creates their competitive advantage.
An important contextual note is that while many of the non-traditional bank lenders do not fall within OSFI's regulatory purview, it would be incorrect to suggest they are not regulated. Each province has its own regulations related to mortgage lending and non-traditional bank lenders statistically originate mortgage loans with equivalent or slightly better default rates than the banks. For Canadian mortgage consumers, non-traditional bank lenders play an invaluable and necessary role in a competitive marketplace.
There are some significant negative impacts on price of these changes. As of January 1, the average cost for a conventional mortgage fund has increased by 25 basis points; in real dollars, that's about $2,300 over the five-year term. To the full amortization period of the mortgage, it's about $10,400.
In addition to these additional costs, mortgage insurers are increasing their insurance premiums on non-conventional mortgages for the third time in three years. This is due to OSFI's newly released capital adequacy guidelines and the premiums in some loan-to-value categories are jumping by more than a full percentage point of the value of the mortgage. These, of course, will be costs passed on to the ultimate consumer.
The stress test also creates a reduction in the purchasing power for many Canadians, which some of the other panellists have discussed. We have some regional issues as well that were created by them. Many will be first-time buyers.
Our chief economist, Will Dunning, tells us the stress test will mean homebuyers will have their calculated total debt service ratios increased by 5 to 7.5 percentage points, which is going to have a material impact on their purchasing power without really changing any of their specific details. The spin-off impacts of a reduction in purchasing power for the middle class could have the unintended consequence of creating the scenario that these policies aim to prevent, which is a national debt crisis caused by a significant economic decline.
The new capital requirements from OSFI also require insurers to look at two new characteristics of a loan to determine how much capital they need to hold on hand to portfolio insure it: credit scoring and geography.
We're concerned that these changes create regional price and access disparities that will disproportionately impact middle-class Canadians in areas deemed high risk. The proposal to introduce risk sharing into the market would also cause major price and access disparities. While Canada has enjoyed historically low default rates, somewhere below one-third of 1%—I think it was 0.28% on Monday—data has always demonstrated that job losses are the number one trigger for mortgage defaults.
Under a risk-sharing structure, as regional economies suffer downturns, local mortgage costs are going to increase proportionately. We would suggest that this is the exact opposite of the result the government would like to see, as opposed to the social mechanism that CMHC and the securitization program is intended to create.
In conclusion, the announced changes negatively affect the mortgage broker channel as a whole, and Canadian consumers have been more and more inclined to use the services of a broker to provide choice, advocacy, and support, and to assist in the technical requirements of mortgage qualification. Placing competitive disadvantages then on the non-traditional bank lenders will adversely affect this segment of the Canadian mortgage marketplace, which consumers clearly are voting for with their purchasing habits.
We have five recommendations that we would like the committee to consider to help mitigate the effects of these changes.
First, suspend all regulatory measures not yet implemented.
Second, adjust the November 30 change to allow for refinanced mortgages to be included again in portfolio insurance. If an 80% loan-to-value ratio is unacceptable, please consider reducing the threshold to 75% rather than removing the eligibility of these products entirely.
Third, the government should reconsider the increased capital reserve requirements implemented in January for insured mortgages.
Fourth, we recommend that a review be conducted into the long-term impact of regional-based pricing on the Canadian economy as a whole, and the potential additional harmful effects on already strained regional economies.
Finally, please uncouple the stress-test rate from the big five banks’ posted rates. Use an independent mechanism to determine the rate and require its use to qualify all mortgages, not just those insured.
Thank you very much, indeed.