The Basel framework ensures that banks, building societies and other deposit-taking institutions have sufficient capital for the underlying risks they bear. While supporting this objective, IMLA has raised significant concerns over some proposed revisions in the latest Basel consultation, which it argues are not justified by differences in risk and could limit access to mortgage finance in key areas of the UK housing market.
In particular, one of the most serious impacts could be on lending to UK housing associations. By preventing lenders from taking into account borrowers’ financial strength, the Basel proposals could see loans to many housing associations redefined and subject to much higher capital requirements, despite the exemplary payment track record and their government regulated status.
The same proposals mean the regulatory cost of buy-to-let (BTL) lending could far outweigh the risks involved, as they do not accommodate the fact that many BTL borrowers are substantially more financially secure than the average owner-occupier.
IMLA also strongly disagrees with proposals* which could distort mortgage pricing and push up the cost of higher loan-to-value (LTV) mortgages, which are relied on by many first-time buyers to become homeowners.
Doing so could incentivise them to seek out unsecured ‘top-up’ loans to fund their house purchases with a lower LTV mortgage, which would be potentially harmful to their finances.
IMLA’s consultation response highlights how aspects of the Basel proposals could:
• create a “bizarre” situation where unsecured lending can be given a lower risk weighting than secured lending to the same borrower
• penalise lenders that have adopted conservative lending standards
• create an artificial incentive to lenders to remortgage or ‘churn’ customers, creating outcomes that would not be deemed good for either the customer or the lender
*This refers to proposals on risk weighting of residential property loans by LTV ratio on an untranched basis
Peter Williams, Executive Director of IMLA, comments
“It is vital to have the right checks and balances in place so lenders can provide mortgage finance where there is a legitimate need while maintaining a stable UK housing market.
“The Basel consultation sets out with the important aim of ensuring capital requirements are appropriate to the underlying risk, but we are concerned that the current proposals will not meet this goal.
“Government and industry need to work together to bring greater balance to the UK housing market. This includes ironing out the technical details of the Basel proposals to defend consumer interests across all housing tenures.”
For further information please contact:
Tora Turton / Maham Uzair / Will Muir, Instinctif Partners
Tel: 0207 427 1422 / 29 / email@example.com
Notes to Editors
The Intermediary Mortgage Lenders Association (IMLA) is the trade association that represents mortgage lenders who lend to UK consumers and businesses via the broker channel. Its membership unites 43 banks, building societies and specialist lenders, including 16 of the top 20 UK mortgage lenders responsible for more than £180 billion of annual lending.
IMLA provides a unique, democratic forum where intermediary lenders can work together with industry, regulators and government on initiatives to support a stable and inclusive mortgage market. Originally founded in 1988, IMLA has close working relationships with key stakeholders including the Association of Mortgage Intermediaries (AMI), UK Finance and the Financial Conduct Authority (FCA).