Housing affordability must-do 23 banking recommendations: Lindsay David and Philip Soos

LF Economics duo Lindsay David and Philip Soos have published 23 recommendations into Australian banking reform in an attempt to curb what they believe is a 'perverse culture of homeowner entitlement' and a 'religious-like culture of property ownership and speculation'.

Featured in their submission to the House of Representatives Standing Committee on Economics 2015 Inquiry into Home Ownership, The Great Australian Household Debt Trap: Why Housing Prices Have Increased, the paper backs the use of macro-prudential tools to moderate house price inflation, suggests the implementation of a new RBA risk assessment framework and the RBA raises in the current interest rate.

The 23 recommendations are:

Recommendation #1

Prepare legislation for the implementation of a future Chicago Plan-style reform in the event of a severe banking crisis. This includes a progression to 100% reserve lending and backing for deposits, and public control of the money supply via issuance of government money (equity) when banks want to lend, unless they wish to pay an increased premium for private debt liabilities. Forcing the requirement that banks issue debt instruments to the government, rather than the private sector, is a blueprint forremoving the noxious impact of usurious fees and interest charges, and rapid inflation in themoney supply that causes asset bubbles and financial instability.

Recommendation #2

A range of macro-prudential tools should be implemented to moderate housing price inflation and subdue credit growth in a pro-cyclical financial system, particularly those affecting the loan to value (LVR), debt servicing (DSR) and debt servicing to income (DSTI) ratios.Quantitative restrictions are placed on the share of new mortgages with moderately high LVRs (60 to 79%), and significantly strengthened for mortgages with an LVR of 80 to 89%. Mortgages with an LVR of 90% and above, interest-only loans and those backed by parental guarantee are disallowed. Mortgage debt is capped at a multiple of ten times the imputed or actual annual rental income of the property being purchased to prevent a positive feedback loop forming between rising housing prices and debt.41 The ’30-10-30 Plan’ should be a future policy consideration following a severe downturn in the housing market.

Recommendation #3

To reduce systemic risk, a large rise in capital and liquidity ratios (buffers) is implemented so banks can withstand a future economic downturn, bank run, credit market freeze or large fall in the value of collateral. Research suggests the probability of a banking crisis can be reduced to a 1 in 100 year event by raising core equity (Tier 1) capital ratios to 11 per cent in isolation or raising core equity to 10% with an additional rise in liquid assets of 12.5% (the rise in liquid assets over total assets).For the Big Four banks, this represents a rise of around 3% in core equity. Liquidity and capital buffers (and general debt provisioning) must rise during the expansionary phase of the credit cycle, taming the size and duration of a debt-financed asset price boom.

Recommendation #4

APRA enforces a transparent and prudent risk-weighting methodology for determining capital ratios. APRA rescinds banks’ authority to calculate their own risk-weights with advanced internal methods (APS 113) and enforces all new bank lending under APS 112, applying more conservative criteria and risk weights for residential mortgages. Requisite modifications to APS 112 include higher risk-weights when asset prices significantly diverge from the long-term mean (25-30 year minimum), and re-calculation of potential super-sized LGD, PD and EAD during a large housing correction.

Recommendation #5

Significant capital allocations arising from conservative risk-weights imposed on financial derivatives, with prudential regulations requiring derivatives to be placed on-balance sheet in SPVs. 

Recommendation #6 

Development of a new RBA risk assessment framework including a range of macroeconomic, banking, market-priced and qualitative indicators:

• Macroeconomic metrics include the stock and flow of credit to all sectors of the economy (household, non-banking financial, non-financial business, and government sectors), sectoral leverage, associated DSRs and estimations of credit quality. 
• Banking sector metrics include capital adequacy as a proportion of total asset value (not RWAs), liquidity ratios, non-performing loan rate, asset quality in high-risk sectors (e.g. residential housing), proportion of high-LVR and interest-only lending, asset concentration on bank balance sheets, and the level of specific provisions for bad debts. 
• Market-priced metrics include the divergence of asset prices from long-term averages (e.g. P/I and P/R ratios), credit spread between market/deposit and lending rates, proportion of securitised, offshore and short-term wholesale funding, degree of foreign investment, loan to deposit ratios, and the average maturity profile of debt. 
• Qualitative measures include lending standards and risk appetite, ratio of prime to non- prime/subprime lending, trends in loan control frauds, rapid bank network growth and the intensity of financial sector competition.
  

Recommendation #7

Strict limits are placed on the Big Four banks to prevent any further mergers or acquisitions due to the high concentration of Australian financial system assets under management and the already non-competitive operating environment. A maximum threshold is established for the proportion of credit aggregates directed towards any single asset class.

Recommendation #8

APRA enforces less reliance on wholesale borrowing, particularly short-term foreign debt, via existing regulatory powers. The average maturity of wholesale funding is lengthened by adopting suitable benchmarks for short and long-term wholesale borrowing, and imposing restrictions on off-shore bond issuance. A minimum level is also set for ‘stickier’ funding sources like domestic deposits.

Recommendation #9

Covered bonds are phased out, as this dual recourse funding arrangement poses significant over-collateralisation risks. The numerous funding advantages of the Big Four banks over second-tier lenders indicate they are not disadvantaged by this reform. Legislative amendments to the Banking Act 1959 subordinating depositors in the creditor hierarchy are unwound.

Recommendation #10

RMBS funding arrangements are reviewed and a maximum 10% limit set for total RMBS financing in any asset class. The AOFM explicitly rules out any future support for RMBS.

Recommendation #11 

Establishment of a Royal Commission to conduct an exhaustive investigation of the financial system and regulatory bodies. The Terms of Reference are broad and explore accusations of extensive subprime mortgage fraud, predatory lending, and regulatory agency culpability and negligence in addressing systemic risk and unconscionable financier conduct.

Recommendation #12 

External dispute resolution (EDR) organisation regulations are reformed to better assist victims of predatory lending. Arbitrary caps on mortgages are removed, allowing EDRs to write-off the entirety of loans in the worst cases of fraud. The powers of EDRs are significantly expanded to deal with recalcitrant lenders.

Recommendation #13

The Financial Claims Scheme (FCS) is broadened to include significant ex-ante funding from banks to provide depositor and general policy insurance. A financial contribution from banks discourages moral hazard and guarantees they bear a greater loss for subsequent failures.

Recommendation #14

Economists in senior and executive public roles are subject to a suitable incentive structure to ensure appropriate management of the economy and commentary. A range of key performance indicators can be adopted and benchmarked against the performance of the economy. Economists are held accountable for the quality of their work, with a number of penalties being introduced for poor performance: fines, loss of employment and even imprisonment in the worst cases of financial and economic collapse.

Recommendation #15

The development of a more transparent and empirically-validated stress-testing framework. Primary variables that predict future instability include the size of the credit-to-GDP gap (breaching 6%), DSRs greater than 20% (related to more severe recessions), a large proportion of credit aggregates directed towards real estate (42% of all Australian banking assets are housing loans), large deviations of asset prices from the long-term mean, and low equity to deposit ratios (a greater number of creditors have a claim on banking assets). APRA ceases to use ‘soft stress-testing assumptions’ for liquidity as noted in the 2012 IMF Financial Stability Report.

Recommendation #16

The APRA stress-testing framework includes the following secondary variables: large ToT shocks precipitating a significant fall in national income, persistent tepid or negative economic growth, steep rises in unemployment stressing high DSR households, and significant Australian bank exposure to the New Zealand market.A mining sector downturn would increase the likelihood of rising personal and commercial defaults, declining credit quality, and rising bank funding costs as credit ratings agencies lose confidence in credit quality. New Zealand’s housing bubble is also heavily dependent on capital inflows for funding, suggesting a simultaneous property downturn could amplifydifficulties for the Australian parent companies, despite legal ring-fencing.

Recommendation #17

The decision to implement a CLF is reviewed, alongside the conditions of access and possible taxpayer risk. At a minimum, the cost of accessing CLF liquidity should be substantially increased, as there is a spread of well over 100bps between the wholesale funding and cash rates. Banks may otherwise try to access the CLF for cheaper funding, instead of as a last resort measure. The RBA could also threaten to convert debt into equity following a large fall in the value of collateral pledged to access liquidity. Abolishing the CLF is the most prudent measure as it is a thinly-disguised, taxpayer-funded bailout mechanism. If financial institutions require capitalisation at taxpayer expense, they should be nationalised rather than bailed out.

Recommendation #18

Bail-in provisions overseen by the FSB and endorsed by APRA are repealed, despite Australia’s implementation of the new global liquidity framework (Basel III International Framework for Liquidity Risk Measurement, Standards and Monitoring). An independent panel of experts considers a range of alternative policy measures that contribute to financial stability, outside of the costly bailout/bail-in paradigm.

Recommendation #19

A ‘true cost of service provision’ regulation is implemented regarding the pricing of essential bank services. The banking and financial sector is regulated like utilities, rather than viewed as profit centres yielding infinitely rising returns for management and shareholders.

Recommendation #20

A levy is imposed on the financial sector for the government deposit guarantee, and calculated to be the approximate size of the derived market benefit. The Big Four’s heavy concentration and majority control over financial system assets means theyalready reap significant cost savings due to economies of scale.

Recommendation #21

The alleged benefits and costs of high frequency trading are reviewed. Algorithm-based trading has led to heightened volatility in many of the world’s markets and innumerable cases of market manipulation, such as front-running of orders by large institutional players with computerised infrastructure advantages.

Recommendation #22

Lender’s mortgage insurance (LMI) is disallowed. The shifting of risk to mortgage insurers is a form of private moral hazard providing banks with an incentive to lend without considering the capacity to repay. LMI does not afford lenders any real protection in a major crisis as these companies are often severely under-capitalised for the sizeable real estate risks they are insuring.

Recommendation #23

The RBA raises the interest rate. The current speculative housing price booms in Sydney and Melbourne are amplified by the cuts to the cash rate in recent times and thus should be reversed in an attempt to dampen speculation. This may provide an incentive to many highly-leveraged and negatively-geared investors to offload their properties and dissuade new entrants into the market. The knock-on effects of record low interest rates also negate the ability of retirees, dependant on their cash savings, to spend within the domestic economy. By sustaining housing price growth through lower interest rates, the RBA has reduced incomes which will inevitably push more retirees onto the pension as their bank accounts yield increasingly fewer returns.