IMLA Publications

The new government has made clear its priorities to build more homes and to improve the rights of tenants who rent in the private sector. The new administration has also announced its intention to introduce legislation which would require all private rented sector (PRS) properties to achieve an energy performance certificate (EPC) rating of at least a C by 2030.

This report examines these proposed regulatory changes in detail. Whilst many of the measures are no doubt intended to increase renters’ security of tenure and treatment by their landlords, there is a risk that the balance of rights and responsibilities may be shifted too far and cause unintended consequences.

The major problem which the government faces is a chronic shortage of supply/surplus of demand in both the owner-occupied and private rented sectors. So far as the PRS is concerned, we would urge the government to remember that where measures are proposed which could cause private landlords to exit the sector, this will reduce the (already insufficient) supply of rental properties still further—causing tenants to suffer from the lack of supply and higher rents.

To this end we put forward the following recommendations:

• Give greater recognition to the importance of the PRS, which provides homes
  for just under 20% of UK households.
• Acknowledge that small landlords form the backbone of the sector.
• Recognise that, as with any industry, increased regulatory costs will push up prices.
• Accept that increased risk for landlords will require higher returns.
• Acknowledge the ability of the market to drive up standards in the PRS.
• Apply policy more fairly across tenures

• UK economic growth was robust in the first half of the year, rising 0.7% in Q1 and 0.6% in Q2, although growth stalled in June and July. The services sector has been responsible for almost all the growth in GDP so far this year.
• The Bank of England cut Bank Rate by 0.25% in August. It was the first cut since March 2020. The ECB cut rates by 0.25% in June, followed in September by a 0.5% rate cut from the US Federal Reserve and another 0.25% reduction from the ECB.
• CPI inflation was unchanged in August at 2.2%. Core inflation rose from 3.3% to 3.6% while services inflation was also higher at 5.6% and goods prices fell 0.9%.
• The labour market remained robust over the spring and early summer with employment rising by 265,000 between March and June and unemployment falling by 73,000 over the same period, taking the unemployment rate back down to 4.1%. Despite this, regular pay inflation eased back to 5.1% in June.
• Housing turnover continued to rise heading into the summer. July’s figure of 97,000 was the highest total since December 2022. The RICS Residential Market Survey for August suggests that this upward trend is set to continue in the coming months.
• The rise in house prices also picked up momentum over the summer. In July, the Land Registry reported that house prices reached a new peak of £289,700, surpassing the previous record of September 2022. The Nationwide and Halifax indices were up 2.4% and 4.5% respectively in August.
• Mortgage lending and approvals reflect this more buoyant housing market. Lending for house purchase was up 29% in the three months to July while approvals were 10% ahead. But remortgage activity was more subdued, with lending up only 3% over the same period, partly due to the ongoing shift toward product transfers.
• Arrears have stabilised in both the owner-occupied and buy-to-let markets despite the drift of mortgage borrowers to higher rates. Arrears over 2.5% of the loan balance were unchanged in Q2 at 1.03% of all mortgages.

• UK economic growth rebounded sharply in Q1 to 0.7%, after two consecutive quarters of falls in the second half of 2023. The services sector accounts for the bulk of the growth in 2024 so far while construction activity continues to decline with private house building particularly weak.
• CPI inflation fell to the Bank of England’s 2.0% target rate in May for the first time since July 2021. Core CPI inflation (excluding food and energy prices) also fell, to 3.5% in May, down from 3.9% in April. Inflation in the services sector fell from 5.9% to 5.7%. However, after 8 months when it was almost flat, the CPI index increased by 1.8% in the four months to May and the headline rate of CPI inflation is expected to rise during the second half of this year.
• The labour market continued to soften modestly with job vacancies falling to their lowest level since May 2021 and the unemployment rate reaching 4.4%, the highest rate since summer 2021. Despite this, regular earnings growth remained at 6.0% in February-April although pay settlement data show average settlements running at between 4.6% and 5.0% in recent months.
• The Bank of England Monetary Policy Committee (MPC) voted to keep Bank Rate at 5.25% in June by a 7-2 majority. However, Governor Andrew Bailey struck a slightly more cautious tone about future rate cuts, suggesting the next decision could be finely balanced.
• Housing market activity has rebounded from its January lows, with 239,000 transactions in the three months to April, 5% above the previous figure. The RICS Residential Market Survey for May suggests that transactions could continue to rise over the next few months, buoyed by a better flow of stock onto the market.
• A modest but clear upward trend in house prices is evident so far in 2024. The Land Registry reported prices up 1.1% in the year to April while Nationwide showed a 1.3% rise in the year to May. This may reflect improved buyer affordability following falls in fixed-rate mortgage pricing since the peak of last summer.
• Mortgage lending and approvals have both been on an upward trend so far in 2024. House purchase approvals have been particularly strong, up 47% in the three months to April compared to the previous three months.
• Short-term mortgage arrears (1.5<2.5% of the loan balance) fell in both the owner-occupied and buy-to-let markets in Q1, reversing the trend of the previous two years. The rise in arrears over 2.5% of the loan balance also slowed sharply.

• In November 2021, IMLA published a paper entitled The mortgage affordability paradox, highlighting the fact that, despite a record house price to earnings ratio of 8.8, mortgage payments relative to earnings were close to their all-time lows. This paper provides an update to assess the impact of the higher interest rate environment we have entered.
• The long-term trend of higher house prices relative to earnings coupled with improved affordability, driven by lower mortgage rates, has reversed. In 2020, interest and capital payments as a percentage of home-buyer income reached a record low of 16.9%. This figure rose to 20.8% in 2023, a level it remained at in February 2024, 11% above its long-term average.
• The regional picture has changed a little in recent years, with the affordability gap closing slightly between London and the South East and the rest of the country. The house price to earnings ratio peaked in London in Q4 2016 at 12.9 but was down to 10 by Q2 2023. Over the same period this ratio has remained broadly unchanged in Scotland, Yorkshire and the Humber, the North East, West Midlands and South West and risen in the North West, East Midlands, Wales and Northern Ireland.
• Our 2021 report found that buying was cheaper than renting but this has reversed in most regions due to higher mortgage rates. Nationally, the cost of renting and buyers’ mortgage interest costs are broadly equal but once capital repayments are included, buying appears more expensive.
• We estimate that the cumulative shortfall in first-time buyer numbers since the financial crisis reached 3.1 million by the end of 2023. Despite strong affordability in the 2013–2022 period, first-time buyer numbers failed to pick up as previous trends would have suggested. Now, with the payment burden above its long-term average, first-time buyer numbers have fallen back.
• Lenders have innovated to meet the challenges of stretched affordability. 100% products include Skipton Building Society’s Track Record Mortgage, Halifax’s Family Boost and Barclays’ Family Springboard. Accord/Yorkshire Building Society has introduced a 5% deposit mortgage, and there is also a range of 5% deposit schemes offered by other organisations.
• The future path of mortgage affordability will depend overwhelming on the path of interest rates. Interest rates are expected to fall from current levels, which should underpin an improvement in affordability going forward.

• The UK entered a shallow recession during the second half of 2023 with GDP falling 0.1% in the third quarter and 0.3% in the fourth. However, these figures are subject to possible revision and GDP rose by 0.2% in January while business surveys have also improved.
• CPI inflation fell to 3.4% in February, down from 4.0% in January. Core inflation (excluding food and energy prices) also fell, to 4.5% in February, but perhaps the most positive news on inflation came from producer input and output prices, which were 3.5% and 1.2% down in the latest three months compared to the previous three despite a rise in commodity prices and disruption to shipping in the Middle East.
• The Governor of the Bank of England has signalled that rate cuts are most likely on the way this year and that cuts do not have to wait until CPI inflation hits its 2% target after the MPC voted 8–1 to leave Bank Rate unchanged at 5.25% in March.
• The labour market continues to show signs of a modest softening with job vacancies falling for the twentieth consecutive month on the latest figures. But the unemployment rate has bucked this trend, being 3.9% in the three months to January, below the level of last summer. One possible explanation is that a slight softening in employment levels has been more than matched by higher inactivity (people neither in work nor looking for it).
• Housing market activity remains weak with transactions down 13% in the three months to January compared to the previous three months. However, the forward-looking components of the RICS Residential Survey suggests activity levels are set to recover over the coming months.
• House prices were broadly flat over the course of 2023 but the latest data from the Halifax and Nationwide indices suggest that a gentle recovery is underway. This may reflect improved buyer affordability following falls in fixed-rate mortgage pricing during recent months.
• Improved swap rates over recent months have driven fixed-rate mortgage pricing down sharply. However, this trend stalled in February as financial markets reassessed the timing of Bank of England rate cuts.
• At the end of 2023, mortgage arrears of more than 2.5% of the loan balance reached 1% of all loans for the first time since 2015. However, shorter-term arrears were up less than 0.5% between Q3 and Q4, pointing to a possible slowdown in the rise in arrears overall in 2024. Owner-occupier arrears of 2.5% or more were up 7% on the quarter while buy-to-let arrears were up 18%.

• Output has continued to show a broadly flat picture.
• CPI inflation fell unexpectedly to 3.9% in November following a sharp fall in
  October, as the energy price spike from October 2022 fell out of the 12-month
  comparison.
• After the latest MPC interest rate decision, Andrew Bailey, Governor of the Bank
  of England, played down talk of early cuts in Bank Rate.
• The Office for National Statistics (ONS) has stopped publishing data based on its
  labour force survey after concerns that it is no longer providing reliable results.
• Housing transactions in the 3 months to October were up 9% on the previous 3
  months but the number of house purchase approvals was down 19% over the
  same period, pointing to weaker house purchase lending going into 2024.
• There has been a divergence of trends recently between Land Registry house
  prices and those of the Nationwide and Halifax.
• Fixed-rate mortgage pricing continued to ease in November. Average 2-year
  fixed-rate pricing fell almost 1% between the end of July and the end of August as
  swap rates fell.
• There was a 9% rise in mortgage arrears of more than 2.5% of the loan balance
  between Q2 and Q3 to 0.92% of all loans.

• Gross lending fell by an estimated £225.5 billion in 2023, down 28% on the previous year
• The buy-to-let market experienced a steeper contraction, with gross lending
  estimated to have fallen 48% to £30 billion in 2023
• Gross mortgage lending expected to fall further to £205 billion in 2024 before
  recovering slightly to £210 billion in 2025
• A forecasted further fall in buy-to-let lending is in 2024 to £27 billion before it
  recovers slightly in 2025 to £29 billion
• Arrears and possessions expected to continue to rise sharply in 2024 and 2025
• 2023 saw a sharp rise in the share of cash in house purchases. Buyers are estimated to have spent a total of £295 billion on property purchases in 2023. A record 54%
  of that was financed by cash

• IMLA has conducted a survey of a random selection of 503 landlords to get a better understanding of the providers in today’s private rented sector (PRS).
• In contrast to most sectors of the economy, where large corporates dominate, the overwhelming majority of providers in the PRS are individuals operating either in their own name or through small limited companies.
• We asked respondents for key financial data about their rental businesses.
• We asked whether respondents believed they were paying more tax as a result of the removal of the mortgage interest deduction.
• On average landlords with mortgages expect to see their monthly interest payment rise by 80% over the next two years.
• New regulations have increased landlords’ costs and further regulation could prove unaffordable for some landlords, pushing them out of the sector.
• Despite the current headwinds, the majority of landlords said they planned to expand their portfolios.

• Output rose 0.2% in Q2 following a 0.1% increase in Q1. Although estimates suggest GDP fell 0.5% in July it was impacted by strikes on the rail network and in the NHS and followed a strong performance in June.
• CPI inflation fell unexpectedly to 6.7% in August, as a softening of some food prices offset a rise in forecourt petrol prices. Core consumer price inflation fell sharply from 6.9% to 6.2%.
• In early September, Andrew Bailey, governor of the Bank of England, told the Commons Treasury Committee that he did not expect Bank Rate to rise much further. Following this the MPC left rates unchanged for the first time in almost two years at their September meeting.
• In May to July, unemployment rose from 4.2% to 4.3% and other labour market indicators also softened slightly. Despite this, wages grew by 8.5% in the year May to July, but these figures were affected by one-off bonuses in the public sector. Regular pay, which excludes bonuses, was up 7.8%, unchanged from the previous month.
• Both housing transactions and mortgage approvals fell in July, but on a three- month on previous three-month comparison, they were up by 7% and 18% respectively. Gross lending for house purchase and remortgaging were also both up on this comparison, suggesting the housing and mortgage markets are stabilising.
• House prices are also showing a more robust picture. Both the Land Registry and Nationwide indices have been up on a three-month on previous three-month comparison in recent months.
• Fixed-rate mortgage pricing eased slightly in August after the spike that followed disappointing inflation figures in April and May. Average 10-year fixed-rate pricing was below that of either 2 or 5 years in August but the share of customers fixing for this longer period remains low.
• There was a 9% rise in mortgage arrears of more than 2.5% of the loan balance in Q2 to 0.84% of all loans. Within the total, buy-to-let arrears rose much faster, up 29% to 0.44%, although they remain at less than half the rate in the owner-occupied market.

• Output has continued to hold up in recent months despite rising interest rates.
  First estimates of GDP growth in Q1 showed output up 0.1%, with the monthly
  estimate for April showing a further rise of 0.2%.
• Core consumer price inflation hit 7.1% in May, the highest rate since 1992 while
  CPI inflation remained at 8.7%, above market expectations. Rising domestic
  inflationary pressures are now offsetting the impact of lower global commodity
  prices.
• Concerns about the persistence of inflation have pushed up interest rates across
  the yield curve. The Bank of England raised Bank Rate to 5.0% on 22 June and
  the market now predicts that Bank Rate could go as high as 6% by the end of this
  year as the Bank faces the need to reassert its ability to bring inflation back to its
  2% target.
• The labour market is now a significant source of inflationary pressure. Regular
  earnings across the economy rose 7.2% in the three months to April compared
  to a year earlier and in the private sector growth was 7.6%. Although
  unemployment has been rising and job vacancies falling modestly in recent
  months, the labour market remains tight with the unemployment rate at 3.8%.
• Housing transactions and mortgage approvals were both weaker in April.
  However, the latest RICS Residential Survey points to the market stabilising with
  a lower negative figure for buyer enquiries and a slight rise in the stock of
  properties for sale.
• The main house price indices are showing a somewhat mixed picture with the
  Nationwide index showing a fall of 3.4% in the year to May and Halifax/Markit a
  fall of 1.0% but the Land Registry still showing an annual gain on their latest
  figures. But the latest data from Nationwide suggest prices have stabilised for
  the time being.
• As a result of higher market interest rates, fixed rate mortgage pricing has risen
  since May with some lenders withdrawing products. Moneyfacts reported that
  average 2-year fixed rate mortgage rates reached 6% by mid-June.
• There was a small uptick in mortgage arrears in Q1. Arrears of more than 2.5%
  of the loan balance rose from 0.74% in Q4 to 0.77%. Possessions were also
  higher in Q1, but at 1,250 remain far below their historic average. Short term
  buy-to-let arrears (1.5%<2.5% of loan balance) rose fastest in Q1, up 32% to
  0.18%.

• The imbalance between supply and demand in the private rented sector (PRS) has worsened
• Real rents in the PRS have declined in recent years despite the supply shortage
• Some landlords have seen mortgage payments rise by 238% since December 2021
• Higher rate tax paying landlords face a double whammy
• A significant proportion of buy-to-let landlords are failing affordability assessments and cannot remortgage
• As more landlords reach the end of their current fixed deal, rents will need to rise in real terms
• The threat of more draconian regulation including rent controls is the most serious threat to the health of the PRS

• The UK economy has performed better than expected in recent months. First
  estimates of GDP growth in Q4 showed output flat, meaning the economy just
  avoided entering a technical recession after Q3’s fall of 0.2%, itself revised down.
• CPI inflation rose unexpectedly to 10.4% in February from 10.1%. But hopes that
  inflation will fall back sharply this year have been buoyed by lower commodity
  prices, which have already fed through into producer input prices, which turned
  negative on a 3-month comparison in January for the first time since July 2020.
• Less positive for the outlook for inflation, wage rises continue to pick up, the
  largest shift in recent months being a steeper rise in public sector pay after it had
  lagged well behind the private sector. Regular pay in the public sector rose 4.8%
  in the November-January period although private sector pay is still growing faster
  at 7.0%.
• Given the lags involved in the home buying process, it is unsurprising that the
  shock to buyer confidence and spike in mortgage rates that followed the mini-
  budget were not obvious in either transaction levels or house price data up to the
  end of 2022. But transactions were below 80,000 in both January and February
  and the RICS Residential Market Survey for February shows that both price and
  sales expectations are heavily negative, though slightly improved on January.
  However, falling vendor instructions and low levels of homes on the market
  should temper future house prices falls.
• Fixed term mortgage rates have eased back since their highs of October, following
  the gilt market’s adverse reaction to the mini-budget and the announcement that
  the Bank of England would begin selling gilts bought under its QE programme. The
  largest falls have been with 5 year deals, with some falling below 4% in February.
• Despite the return of stability to the mortgage market and improving fixed rates,
  approvals both for home purchase and remortgages fell very sharply in December
  and January. Comparing the 3 months to January with the previous 3 months,
  both house purchase and remortgage volumes were down 48%. This largely
  reflects the market disruption that followed the mini budget given the lags in the
  mortgage process and points to a period of weak lending in the months ahead.

• Since the last Market Briefing, Kwasi Kwarteng’s mini-budget of 23 September and the Bank of England’s announcement the previous day that it would start to sell government bonds to unwind QE sent the bond market into turmoil. The situation was exacerbated by pension funds’ need to sell bonds to raise cash to meet margin calls on derivatives, having pursued a strategy known as liability driven investment which created leveraged exposure to bond prices.
• Such was the volatility in the interest rate swaps market in the wake of the min-budget that many lenders felt compelled to withdraw their fixed rate mortgage deals until it became clear where pricing would settle. At one point swap rates were indicating that Bank Rate would exceed 6% by mid-2023. Lenders that did continue to offer fixed rates raised their pricing sharply.
• The turmoil in financial markets and consequent spike in fixed rate mortgage pricing had an immediate impact on sentiment in the housing market. Housebuilders reported a drop in sales and rise in cancellations while the Nationwide and Halifax both reported falling house prices in October and November. The RICS residential market survey reported a sharp fall in both buyer enquiries and agreed sales.
• Inflation exceeded expectations in October, with the 12-month change in the CPI rising to 11.1% before falling slightly to 10.7% in November. RPI inflation reached 14.2% in October, the highest rate since 1980, but inflation would have been higher still if the government had not intervened to cap domestic energy bills.
• The UK economy appears to be entering a recession with GDP falling by 0.2% in the third quarter. The main driver was falling private consumption although business investment has also been weak. The latest monthly estimate was more positive with GDP rising 0.5% in October although this largely reflected a bounce back in output following the impact on output of the Queen’s funeral.
• There are early signs of a slowdown in the labour market with unemployment rising from 3.5% in July to 3.6% in August and 3.7% in September. The number of job vacancies has fallen from a peak of 1.3 million in March-May to 1.19 million in September to November. Regular pay, which excludes bonuses, has been picking up since late 2021 and reached 6.1% in August to October but is failing to keep pace with inflation.

• Mortgage lending has held up well in 2022 despite rising interest rates and the worsening cost of living crisis, but the market dislocation that followed the mini-budget in September triggered a slowdown towards the end of the year.
• The dramatic rise in fixed-rate mortgage costs following the mini-budget and Bank of England announcement that it would start selling government bonds to unwind QE triggered a sharp shift in market sentiment.
• The buy-to-let market has seen record gross lending in 2022 of an estimated £56 billion.
• The most important determinant of the economic outlook in 2023 and 2024 is the future path of inflation.
• We expect gross mortgage lending to fall to £265 billion in 2023 and £250 billion in 2024.
• 2022 saw a significant rise in intermediaries’ share of distribution from around 80% to 84%.
• IMLA projects negative equity of only 16,000 by Q4 2024.

• Inflation measured by the 12-month change in the CPI fell slightly to 9.9% in August after hitting the highest rate since February 1982 in July. Over the same period the RPI rose 12.2%. A further sharp increase in consumer prices was expected in October but the government’s decision to cap energy bills can be expected to dampen the rise.
• GDP contracted by 0.1% in Q2, including a 0.6% fall in June but the July figure was better at plus 0.2%. The Bank of England is projecting falling output from Q4 2022 to Q4 2023, driven mainly by an unprecedented contraction in real household incomes as wages struggle to keep pace with inflation.
• The labour market remains strong despite weak output growth. Unemployment fell to 3.6% in the May-July period, the lowest rate since 1974. However, there are tentative signs of a slight softening, with job vacancies down 14,000 on the latest data compared with the previous period. Wage rises including bonuses were 5.5% in the 3 months to July, well down on the 7.0% figure recorded in March, and failing to keep pace with inflation.
• Unsurprisingly, mortgage rates have moved sharply higher this year in response to higher Bank Rate. 60% LTV 2-year fixed rate loans averaged 3.51% in August, against 1.39% in December. But higher LTV products have seen a more modest increase, compressing the differential between 95% and 60% LTV mortgages from 138bp in December to 64bp in August.
• There are tentative signs of a rebalancing in the housing market. The RICS Residential Market Survey for July showed a negative balance of new buyer enquiries for the third month but the stock of properties remains low, underpinning house prices. The lettings market remains strong, with rising tenant demand and lower landlord instructions putting upward pressure on rents. According to the Homelet rental index, rents were 8.5% up over the year to August.
• On 1 August, the Bank of England removed the affordability test requirement, as it had indicated in June that it planned to do. This is not expected to have much impact on the amount consumers can borrow, given that the FPC LTI flow limit and the MCOB requirement that lenders take account of expected rate increases still apply, but at least lenders are not having to increase their stress rates in line with their reversionary rates.

• Inflation measured by the 12-month change in the CPI hit 9.1% in May, the highest rate since March 1982, with the RPI showing an even faster 11.7% increase. A 54% rise in the energy price cap in April was a major factor but prices are rising across a broad range of goods and services and producer input prices rose 22.1% in the year to May, pointing to still more upward pressure on inflation to come.
• Unemployment was 3.8% in the February-April period, a slight rise on the first quarter figure, while over the same period job vacancies reached a record 1.3 million, equal to the number of unemployed workers. The combination of a strong labour market and soaring inflation has put significant upward pressure on wage rates which including bonuses were up 6.8% in the February-April period and by 8.0% in the private sector against only 1.5% in the public sector.
• Rising inflation and building upward pressure on wage rates is putting further pressure on the Bank of England to raise interest rates. Bank Rate was raised again in June by 0.25% to 1.25%, the fifth increase since December, to reach the highest level since 2009. Mortgage rates have risen in response, the sharpest increases being on lower LTV products. 60% LTV 2-year fixed rate loans averaged 2.56% in May, the highest rate since 2012. But there has been a dramatic shrinkage in the margin between high and low LTV products with 95% mortgages now averaging only 63pb more than 60% LTV, down from 267pb a year earlier.
• Output growth is stalling in the face of the headwinds of rising import prices, labour shortages, rising interest rates and disrupted supply chains. In April GDP is estimated to have fallen by 0.3% after a decline of 0.1% the previous month. With consumer real incomes being squeezed and some firms having to reduce margins, prospects for the year ahead are poor.
• Despite the highly uncertain economic environment, the housing market continues to be characterised by limited supply and strong demand, putting upward pressure on prices. 3-month rolling average house prices increased by 2.7% in April with prices reaching a record £281,200 in April. The lettings market appears even stronger with RICS reporting soaring tenant demand and declining landlord instructions resulting in rising rent expectations.
• The government is to launch a comprehensive review of the mortgage market. It will examine “how we can give our nation of aspiring homeowners better access to low-deposit mortgages, and what our own mortgage industry can learn from counterparts around the world who have all kind of alternative ways of offering finance, managing risk, and unbolting the door to ownership.”
• On 20 June, the Bank of England announced that it was removing the affordability test requirement, following a consultation recommendation it made earlier in the year. Lenders no longer have to apply a 3% stress to the reversionary mortgage rate when assessing affordability but other affordability constraints remain.

• The Russian invasion of Ukraine has heightened uncertainty, pushing up global energy and commodity prices. Unless the crisis is quickly resolved, this will feed into higher UK producer input and output prices and consumer prices. The CPI is already rising at the fastest rate since 1992, up 6.2% in the year to February and was already forecast to go higher before the conflict in Ukraine, in particular due to the forthcoming rise in the energy price cap.

• The rise in consumer price inflation prompted the Bank of England to raise Bank Rate to 0.5% in February and 0.75% in March. Markets were anticipating a rise in Bank Rate: average low LTV mortgage rates have been rising since late summer. However, growing competition in the 95% LTV market, as lenders unwind their Covid induced restrictions, has more than offset the impact of increased Bank Rate for these loans so far.

• The Bank of England faces a difficult balancing act as higher energy and commodity prices are both inflationary and detrimental to domestic activity as they squeeze corporate profit margins and reduce households’ real incomes. It may be impossible to avoid a period with both high inflation and low or negative growth.

• The labour market remains buoyant with record numbers of job vacancies and falling unemployment. This has underpinned wage growth which was 4.8% in the three months to January. The Bank of England will pay particular attention to trends in pay growth, watching for signs that wages are following prices up, and may feel compelled to raise Bank Rate faster and further if earnings accelerate.

• The housing market continues to be characterised by limited supply and strong demand, putting upward pressure on prices. As a result, house price inflation in the latest 3 months rose at a double digit rate despite the removal of the impetus of the stamp duty holiday.

• Lending data confirms that remortgage activity is rebounding after a year when lenders prioritised house purchase lending. The prospect of higher interest rates has also encouraged some borrowers to look to fix their rate for longer.

Despite—and in some cases as a result of—the continuing COVID-19 pandemic, 2021 remained a very busy year for the housing market. The experience of “lock-down” prompted some homeowners to relocate out of city areas in search of more space and greener surroundings. The extension of the Stamp Duty holiday to September kept demand high amongst home buyers and landlords. Even after that incentive was withdrawn, the sector remained busy, with the first of a possible series of rate rises from the Bank of England set to drive re-mortgaging business in the immediate future.

Amid this ongoing demand, there is still plenty for the sector to get to grips with as we enter 2022. Our latest manifesto identifies the key areas that we believe should be a focus for the mortgage market and the Government in the year ahead.

• Gross mortgage lending in 2021 is estimated to have reached £304 billion, the best performance since 2007.
• We estimate that the total value of housing transactions reached a record of nearly £370 billion in 2021.
• The need to raise interest rates to curtail the post-Covid rise in inflation will dampen the housing and mortgage markets in 2022 and 2023.
• Bond markets are continuing to signal that interest rates will remain in ultra-low territory for the foreseeable future.
• Gross buy-to-let lending to fall back to £38 billion in 2022 and £37 billion in 2023.
• Intermediaries set to remain the dominant distribution channel, serving nearly 80% oof the market.
• IMLA welcomes the Bank of England Financial Policy Committee (FPC) decision to consult on redrawing its stressed affordability requirements.

• Concerns about the Omicron variant arise at a time when economic growth is already stalling because of raw material and labour shortages. While it is too early to be confident about ramifications for the wider economy, there is comfort in knowing that the UK is well-placed to implement whatever coping strategies are appropriate.
• The sharp upwards spike in consumer price inflation over recent months prompted the Bank of England in mid-December to increase Bank Rate from its historic low of 0.1% to 0.25%, the first tightening of monetary policy in more than three years.
• Stamp duty arrangements have returned to their pre-pandemic settings across all parts of the UK, with no obvious ill effects. Housing demand and house prices continue to be supported by lifestyle preferences, still low interest rates and attractive mortgage pricing.
• 2022 is expected to be a strong year for refinancing activity and this will help to shelter mortgage lenders and brokers from any slowdown in the housing market.
• Lenders are alert to and well-placed to support households hit by rising cost of living pressures over the coming months and to minimise any adverse impact on arrears and possessions.

Borrowers should explore all their options after the mortgage industry’s radical steps to innovate in response to the pandemic

• The easing of social distancing restrictions has allowed a re-opening of the economy and a period of strong economic growth. This will fade somewhat in the second half as Covid support measures are withdrawn and the country tackles raw material and labour shortages.
• While it is difficult to gauge the true extent of inflationary pressures, the odds are shortening on the Bank of England nudging interest rates higher next year.
• The housing market has experience huge spikes in activity associated with the stamp duty holiday. While the second half of the year will be quieter without stamp duty concessions, housing demand and house prices will continue to be supported by lifestyle preferences and attractive mortgage pricing.
• The availability and pricing of high LTV loans has improved materially over recent months. These trends look set to continue over the short-term and will provide much-needed support for first-time buyers who are having to cope with higher house prices and elevated deposit requirements.

• We agree with and support many of the statements made in the Discussion Paper.
• Firms which embrace diversity at all levels, but particularly at Board and senior management level, have been proven to be more effective and – by implication – more profitable/sustainable. So quite apart from the fact that increasing diversity and inclusion is simply the right thing to do in terms of treating people with respect and as individuals, there is a big incentive for firms to expand their horizons and ways of thinking and operating.
• For financial services firms, this should go beyond internal structures and management: they need to ensure they are engaging effectively with their current and future customer bases to make sure that they are responsive to those customers’ expectations and demands.
• The challenge will be in how to measure success: what does success look like? Any new rules need to be effective and enforceable.
• It may be necessary to do a lot more preparatory work to ensure individual firms have effective internal communication and have built up the trust of their staff before embarking on data-collection exercises which, if not properly positioned and introduced, could end up being ineffective and even misleading.

• It is not clear to IMLA what benefits a new Consumer Duty would bring
• Since its creation the FCA’s predecessor, the FSA published numerous documents emphasising its expectations of firms and of the leadership provided by Boards and senior management
• There are numerous examples of statements made by the former FSA and the FCA setting out the regulator’s expectations of firms’ behaviour towards their customers
• If the regulator has been unable to enforce its own rules it is unclear that the creation of a new package of measures will succeed in the instances where the existing framework has failed

• The economy has staged a strong recovery from the COVID-19 lockdown induced slump
• The UK housing market has defied economic forecasts and staged a sharp recovery in terms of prices and transaction levels
• The strong housing market has stimulated a surge in mortgage lending
• Longer term implications of COVID crisis are becoming clearer
• IMLA forecasts that house prices will be broadly flat in the second half of 2021 but will rise 1.6% in 2022
• IMLA is raising its forecast for mortgage lending from £283 billion to £285 billion in 2021

• The UK economy is currently enjoying a post-lockdown bounce in economic activity, amid growing confidence that the successful roll-out of our Covid vaccination programme will allow further easing despite the ongoing challenge of new variant strains.
• Housing market sales and house prices have recently been running at their strongest since the global financial crisis and look set to continue strongly for much of the year.
• It is a similar story for mortgage lending, with gross and net industry mortgage lending this year set to deliver their strongest performance since 2007.
• First-time buyer numbers have lagged somewhat, as higher house prices have exacerbated affordability pressures by lifting the size of loans needed and deposit requirements. This may be mitigated by better availability and keener pricing of high LTV loans.
• The Bank of England is currently happy to look through short-term inflationary pressures and to maintain an accommodative monetary stance.

• While the UK economy is currently stuck in reverse gear because of the third national lockdown, there is a growing confidence that the successful roll-out of our Covid vaccination programme and further fiscal stimulus measures herald a sustained economic recovery.
• A shift in housing demand, triggered by the social distancing measures made necessary by Covid-19, rather than the temporary stamp duty holiday, appears to underpin the recent strength of housing market sales and house prices.
• While the end of the stamp duty holiday may mean that activity levels are more subdued for a period, widespread market disruption or house price falls now seem very unlikely.
• The new mortgage guarantee scheme will encourage mortgage firms to return to 95% LTV lending sooner, but it does not represent a panacea for first-time buyers nor will it transform the affordability challenge facing them.

The eighth in our series of annual reports looking at the outlook for the UK mortgage market in the coming year.

• With GDP still considerably below its pre-Covid level, there should be further
  economic recovery next year. But there is huge uncertainty about its precise
  path and nature, and this means that prospects for jobs, household sentiment
  and the housing market are also uncertain.

• The housing market has been experiencing strong growth and record house
  prices in recent months because of the release of pent-up demand, changes in
  housing aspirations and the temporary stamp duty holiday. These factors are set
  to unwind in the first quarter of next year.

• House prices may ease back through 2021 and 2022, reversing some of the
  recent sharp gains.

• Government policies have created an inadvertent “cliff edge” for the housing
  market at the end of March, with the stamp duty holiday ending and a move to
  less generous Help to Buy arrangements at the same time as job support
  schemes are withdrawn.

• While most mortgage borrowers who opted to defer their mortgage have
  already resumed payments, some households will be struggling with their
  finances and their ranks are likely to grow when Government support measures
  wind down. This will show through in higher arrears and possessions figures
  through 2021 and beyond.

• Post-lockdown, there has been a strong recovery in housing market activity
  across most of the UK. July’s temporary cut in stamp duty appears to have
  accelerated demand. House prices on several measures have reached record
  levels.

• This sits oddly with the economic damage that social distancing measures have
  wreaked on businesses and households, the scale of which will become more
  apparent when the Government unwinds key support schemes at the end of
  October.

• Mortgage lenders have successfully grappled with significant operational
  challenges over recent months, not least administering wide-scale payment
  holidays and a shift to remote-working.

• A surge in borrower demand over the past couple of months has created
  additional challenges. Firms have been competing less aggressively in parts of
  the market such as higher LTVs, as a way of managing new lending pipelines,
  maintaining customer service standards and controlling risk in the face of
  economic uncertainties.

• Significant numbers of mortgage borrowers who opted to defer their mortgage
  payments have already resumed their normal monthly payments, and this bodes
  well for the numbers in genuine financial distress that are likely to need ongoing
  forbearance.

• The strong pick-up in activity that has followed the re-opening of England’s
  housing market has surprised on the upside, but seems likely to dissipate over
  the coming months as households become more cautious in the face of business
  failures and higher unemployment.

• The housing and mortgage markets are unlikely to be shielded from the
  economic damage resulting from the Covid-19 pandemic, although fresh
  concerted action by the Government should help to limit the adverse impacts.

• Lenders’ credit risk appetites will shrink back as we go through a period of house
  price weakness and jobs uncertainty. Higher deposit requirements may mean
  that would-be first-time buyers see little benefit from any house price falls.

• The financial sector is resilient and well-placed to handle an expected increase in
  mortgage arrears and possessions from historically low levels and to support new
  lending when market conditions improve.

• First time buyer numbers fell back slightly in 2019 to 352,000, but were still 84% above the low of 191,000 recorded in 2008.

• Main drivers of higher first time buyer numbers have been improved affordability as mortgage rates have fallen and lenders’ increased appetite to support this group.

• Longer term context suggests that first time buyer numbers are still disappointing.

• Short-term outlook is highly uncertain due to the coronavirus but longer-term outlook is positive as strong affordability coupled with a large pool of potential first time buyers points to continued growth.

• Lenders need to ensure that the proposed end of Help to Buy equity loans in March 2023 does not create a new constraint on first time buyers of new homes.

• IMLA calls for government to assess the impact of post-financial crisis regulatory changes and consider easing these restrictions to help new home buyers lead the post-Covid recovery.

• We are in every sense in uncharted territory, given the rapid pace of
  developments associated with the Covid-19 pandemic and the backwardlooking
  nature of market and wider economic indicators.

• The coronavirus outbreak represents an additional headache for the UK
  Government, given that it threatens to derail our economy at a time when
  global slowdown and the need to adjust to life outside the EU makes the UK
  especially vulnerable.

• The UK authorities have responded with a determined and coordinated effort
  to pre-empt the challenges that preventative measures will give rise to and to
  limit the economic fall-out.

• Mortgage lenders, and financial firms more widely, have been quick to play
  their part, offering timely help to households and businesses.

• The next several months will undoubtedly be challenging for the housing and
  mortgage markets (and more widely), but, with a solid framework for
  damage limitation in place, we can at least be relatively optimistic about the
  medium-term.

This article was originally published on 7th February in Mortgage Solutions

This article was originally published on 28th January in Mortgage Strategy

The seventh in our series of annual reports looking at the outlook for the UK mortgage market in the coming year.

This article was originally published on 16th December in Mortgage Solutions

• Concerns about the domestic political situation, economic slowdown and job security have been adversely affecting household sentiment. December’s clear General Election result offers a short-term psychological boost. It is not clear to what extent this will specifically benefit the housing market.

• Negotiations regarding our future trade relationship with the EU are important for the UK’s longer-term prospects and, at this stage, a source of uncertainty.

• The housing market is more or less in a steady state currently, as far as house prices and activity levels are concerned.

• The phasing out of the Help to Buy Equity Loan Scheme from 2021 will loom ever more strongly next year, and it is to be hoped that the forthcoming Budget addresses this issue.

• Younger generations are struggling to attain the financial security that most of their parents enjoyed
• There has been a marked reduction in homeownership rates among younger households compared to the rates seen in earlier generations
• High house prices is not the main cause of the fall in first time buyer numbers
• The long term cost to consumers of not purchasing a home is extraordinary
• As well as the generational divide we need to remain mindful of the housing divide
• IMLA calls for a cost benefit analysis of the current regulatory regime for mortgages which takes account of the cost to consumers who have failed to enter owner-occupation because of the additional hurdles they face accessing mortgage finance because of tightened regulation.

• Brexit represents a momentous economic change for the UK and huge uncertainties are associated with it.
• Mortgage lenders hope that our departure from the EU can be an orderly one.
• But the odds of a disorderly no deal Brexit, with adverse short-term consequences for the wider UK economy, have shortened over recent months.
• Policy-makers have extensive tools to mitigate any adverse effects in the housing market and are likely to deploy them.

This article was written for the October 2019 issue of Housing Market Intelligence

Key developments in the housing and mortgage markets

• The housing market has been relatively resilient in the face of Brexit
  uncertainties to date, with most measures indicating slightly higher activity as we
  headed into the summer.

• House purchase activity has been underpinned by the strong jobs market,
  competitive mortgage deals and slowing house price growth.

• Levels of remortgaging remain high but have begun to ease back following a
  lengthy upturn.

• Concerns about the domestic political situation, slowing economy and job
  security are adversely affecting household sentiment. The forthcoming Autumn
  Budget provides an opportunity for the Government to counter the gathering
  economic headwinds.

• The ongoing recovery of real earnings has helped to offset some of the negative
  sentiment arising from Brexit uncertainties.
• Housing market activity and property prices are flat, broadly speaking, across
  much of the country. First-time buyer numbers continue to rise modestly,
  underpinned for the time being by a strong jobs market and competitive
  mortgage deals.
• Levels of remortgaging are high, but there are early signs of waning borrower
  demand and limits to how much more intense competition between mortgage
  lenders can be.
• The market may enjoy a temporary “Brexit bounce” when the UK agrees a
  transition deal with the EU, but market fundamentals may dictate a quieter
  period down the track.

This article was originally published on 14th May in Mortgage Introducer

This article was originally published on 14th May in Mortgage Introducer

This article was originally published on 5th May 2019 in Mortgage Solutions

• The housing market has not been immune from the wider Brexit uncertainties adversely affecting the UK
• This, together with growing job insecurity, has sapped household confidence and weighed down on housing market activity and property prices
• Mortgage credit terms and availability remain mostly favourable, however, and, once there is a degree of clarity about the UK’s future relationship with the European Union, we could see a bounce-back as pent-up demand is released.

This article was originally published on 7th February 2019 in Mortgage Introducer.

The sixth in our series of annual reports looking at the outlook for the UK mortgage market in the coming year.

Response by the Intermediary Mortgage Lenders Association

This article was first published on 19th January in Mortgage Solutions

IMLA responds to proposals to increase the FOS award limit.

Digitisation and advances in computing power are reshaping numerous industries. In travel, entertainment and retail the structure of the industry and the key providers have been fundamentally altered by the digital revolution. Retail financial services has also seen transformation in products such as current accounts and insurance. In mortgages change has been slower to come but both back office processes and distribution are in the process of being dramatically reshaped.

This article was first published on 5th December in Mortgage Finance Gazette.

IMLA comments on proposals set out in DP 18/5, and provides responses to specific questions.

This article was first published on 23rd October 2018 in Mortgage Finance Gazette.

As homeowners age at a faster rate than the UK population, developments in post-retirement lending are putting a strain on the current model of financial advice, with the need to serve a growing population of older homeowners producing a new generation of mortgage products. In its latest report, IMLA calls on UK financial advisers to break down the silos between pension and mortgage advice, and offer a more holistic service to keep up with the pace of product innovation.

This article was first published on 21st May 2018 in Mortgage Strategy

A guide to the requirements of the GDPR, which comes into force on 25th May 2018: this guide is designed to be helpful to lenders and intermediaries, and to complement the guidance issued to its members by the AMI.

Bob Pannell discusses how net lending levels serve useful barometer for the underlying health of our mortgage market, as published in Financial Reporter:
http://www.financialreporter.co.uk/features/approaching-the-limits-to-lending-growth.html

The fifth in our series of annual reports looking at the outlook for the UK mortgage market in the coming year.

The latest figures confirm that there were about 366,000 first-time buyers in the UK in 2017. This is a positive outcome, in a year when overall property transactions eased back a little. First-time buyers now account for 30% of overall housing market activity.

This article was first published on 26th February 2018 in Mortgage Solutions

Looks at the impact which a plethora of tax and regulatory changes have had on the buy-to-let mortgage market and the wider implications for the private rented sector.

Examines lenders’ increasing confidence in lending on new-build property, together with the impact of the Help to Buy equity loan scheme.

Charts the rise, fall and resurgence of specialist lenders and the emergence of “challenger” banks.

The fourth in our series of annual reports looking at the outlook for the UK mortgage market in the coming year.

Summarises the views of leading figures from four mortgage intermediary firms and four mortgage lenders about how they see the current state of the intermediary/lender relationship and how this might evolve in the future.

Analyses whether the market is delivering appropriate access to credit, together with sufficient competition and transparency for consumers.

An industry guide to lender and intermediary accountabilities and responsibilities in mortgage sales and servicing: updated to take account of the Mortgage Credit Directive

Argues for a more joined-up approach to UK housing policy.

The third in our series of annual reports looking at the outlook for the UK mortgage market in the coming year.

Charts the changing pattern of intermediated and direct mortgage business pre-and post- the financial crisis.

Examines the key issues facing the main segments making up today’s mortgage market: buy-to-let, first-time buyers, home movers, re-mortgagers, lifetime mortgages and further advances.

Analyses the cost of the regulatory changes brought in following the financial crisis and the impact these have had on the efficiency of the financial system and on the wider economy.

The second in our series of annual reports looking at the outlook for the UK mortgage market in the coming year.

December 2014–January 2105 research

Summarises the key agendas for the political parties and politicians to address during the election campaign.

Joint response by the Council of Mortgage Lenders and the Intermediary Mortgage Lenders Association to the Financial Conduct Authority Consultation Paper CP 14/28

A response by the Intermediary Mortgage Lenders Association

Looks at the impact of the financial crisis on non-standard borrowers: the self-employed, those with adverse credit, those borrowing into retirement and those with complex financial affairs.

Q3 2014 research

A Statement of Shared Principles by the Intermediary Mortgage Lenders Association (IMLA) and the Association of Mortgage Intermediaries (AMI)

Examines the housing and mortgage markets and the likelihood of the Bank of England using its new macro-prudential powers to curb the latter.

Analyses the growth in the proportion of private rented sector properties being acquired without a mortgage.

An industry guide to lender and intermediary accountabilities and responsibilities in mortgage sales and servicing: updated to take account of the Mortgage Market Review

The first in a series of annual reports looking at the outlook for the UK mortgage market in the coming year.

January 2014 research

July 2013 research

Contributes to the discussion between government and the industry about the future operating basis and assumptions for the UK housing market, and whether current government support for the housing and mortgage markets will move both forward on a stable and sustainable basis.

July 2012

Q4 2011

An industry guide to lender and intermediary accountabilities and responsibilities in mortgage sales and servicing