Central Bank Consultation - Policy for mortgage lending


#1

Hi All,

Didn’t see this using the search, apologies if it has been posted before but its quite important.

Anybody submitting to this public consultation? I am certain from a brief look at some of the previous consultations, the vested interests will be submitting.

Link here or you can simply search for Consultation paper CP87.

:laughing: :laughing: :laughing:

Of course I personally am far from an expert but would like a sustainable and affordable future for prices in this country as I am sure most here do also. I may submit but its hard to draft something without sounding too angry/insane.

Personally I would advocate very restrictive lending to any kind of BTL purchaser and dealing with the tens of thousands of people who have basically given up paying their mortgage(10K of which are BTLs). I would like to enquire why the banks are continuing to be allowed to screw deposit holders despite having being bailed out to the tune of tens of billions - when will this practice stop 2015? 2020? 2035? I would also to tell them to always overegg what they are about to do to make sure they can pretend to compromise with the vested interest people. They should have said intially for example they would like to see depositors putting down 40% and they would like to see the government CP’ing thousands of acres of prime development land around Dublin at a 50% haircut…

Anyway there seems to be a bunch of questions in the document, I dont know what the point of them is really - to frame and limit the discussion probably, they are listed here:

**Question 1: **Which of the tools or combination of tools available to the Central Bank
would, in your opinion, best meet the objective of increasing resilience of the banking and
household sectors to shocks in the Irish property market and why?
Question 2: Do you agree that the measures should apply to all lending secured by
residential property (which will include lending on property outside the State)?
**Question 3: **Do you agree with the exemptions set out? Are there any additional
exemptions which you consider appropriate, taking into account the objectives of the
proposal and the balance between the benefit of any exemptions and the resulting
increase in potential for unintended consequences?
**Question 4: **If there are any significant operational difficulties envisaged by regulated
financial services providers in complying with the measures as outlined above and in the
draft Regulations (Annex 1) and the proposed exemptions, please submit brief details of
same.
Question 5: Should some adequately insured mortgages with higher LTVs be exempted
from the measures and if so what should be the criteria for exemption?
**Question 6: **Do you agree that the measures should apply to all lending secured by
**Question 7: **Do you agree with the exemptions set out? Are there any additional exemptions which you consider appropriate, taking in to account the objectives of the proposal and the balance between the benefit of any exemptions and the resulting increase in potential for unintended consequences?
Question 8: Do you consider restrictions on loan-to-income ratios as suitable for buy-to-let mortgages? What impact would a restriction on such loan-to-income ratios have on buy-to-let lending in the State? Question 9: If there are any significant operational difficulties envisaged by regulated financial services providers in complying with the measures as outlined above and in the draft Regulations (Annex 1) and the proposed exemptions, please submit brief details of same.
Question 11: Is the threshold of €50 million over 2 quarters an appropriate threshold and time period for reporting requirements? If not, please indicate a threshold you believe to be appropriate and provide reasons why you believe this is the case.
**Question 12: **Are there any significant obstacles to compliance by regulated financial services providers with the limits?
Question 13: Please provide comments on the following draft Regulations.

So any thoughts?


#2

Would the Pin not make a submission?


#3

Under what group heading ?


#4

We have a thread here on it, 43 pages long and counting…

viewtopic.php?f=10&t=63339


#5

This is specifically about the consultation and if people will submit to it. Has anyone said they are submitting there?


#6

Yes, I made a submission.

One thing to note is that all details of your submission will be published, including your name and address. That’s appropriate, of course, but worth knowing before you write.

As for a group effort, I think it’s better to have lots of individual submissions to counterbalance the (probable) deluge of replies from VIs who are against the plan, and some FTBs who are also against it.

Funnily enough, the auctioneer who was on Matt Cooper yesterday urged concerned people to have their say ‘by the end of December’ when he thinks the consultation period ends. :laughing: I hope they listen to him…
[Consultation ends December 8, as you know]


#7

If these LTV and LTI constraints come in for 2015 as described by CBI, would it be inappropriate to send Honohan, Donnery et al, a bottle of champagne, for being the first public figures/body to do anything at all in the public’s interest* when it comes to property in this country in living memory? 8DD

  • who cares if ECB or whoever is driving it - the main thing is that it’s coming in!

#8

Can a few more experienced people put a submission, and the rest of us put our names to it.

At this stage, I feel that there is nobody standing up for what is even vaguely considered right in my mind, that I will put my name to anything. I get the same feeling on here a lot.

Sinn fein, how are ya!


#9

I would just go ahead and draft something and submit it. There’s no reason not to, just keep the language non-emotive and stick in a few facts like the 40,000 in mortgage arrears of that the current loan:gross wage levels are excessive by both international and historical standards. There are tons of articles out there that you can quote mine also to make yourself look “informed”. You have to make an argument from authority or others authority, this is what the VIs are basically doing - “I’m a registered so and so & you must listen to me” etc.

The media VIs are continuing their campaign to stop restrictions on mortgage lending. Shameful really. People here who have been posting for years have no reason really not to submit as they should have a good grasp of the issues by now.

independent.ie/business/pers … 43729.html


#10

I’d agree that many short reasoned submissions (a half-page email) is preferable to one collective submission. The volume of submissions will matter. Try to use rational argument & data where possible, but it is ok to convey a personal aspect to it - why it is in the interest of potential buyers/ the economy/ social fabric that we do not indenture the next half-generation of Irish people - just like the last.

If you wanted to use specific detail - there is no case more compelling than quoting Ulster Bank’s Jim Brown’s numbers that 68% of the FTBers that he has loaned to in last year would not meet the CBI criteria. This is tacit evidence that banks are already over-extending FTBers, by consequence inflating a property bubble, and ultimately endangering the future of the bank AND those that are being green-lit for these mortgages.

Jim Brown has made the case for the CBI, using his OWN numbers.

NOTE: The Central Bank may make the submissions public at some point, or on request via FOI, so be measured in what you say, and careful with including any personal information that you would not be comfortable disclosing publically: address, job, circumstances etc.


#11

The case could also be made that it’s in the banks interest to overextend new borrowers in an effort to bolster prices and, ultimately, their balance sheets.

Serious conflict of interest.


#12

I submitted something short about two weeks ago - am not thrilled that my details will be published as a result (only realised that AFTER I clicked ‘Submit’!) but kept it very short and sweet, I was supportive of the proposed measures and explained why, though didn’t use facts and figures.


#13

For anyone thinking of doing so, I presume this is how to go about making a submission;

*The Central Bank invites all stakeholders to provide comments on the draft regulations which form part of this Consultation Document and on the questions raised in this Consultation Paper. Please make your submissions electronically by email to realestate@centralbank.ie.

Responses should be submitted no later than 8th December 2014. *


#14

I remember thinking, if one were of the opinion the public sector costs were to high, instead of the taxpayer bailing out the banks, the banks could have automatically approved all public sector workers mortgage applications (while prices were high, but falling). This would have effectively bolstered the price of the loan, and the public sector would be footing the bill, indirectly taking a pay cut for the higher mortgage costs, savings for the private sector tax payer.

Of course this is roundabout can kicking looney nama thinking, but it may have been politically sound.


#15

That’s done - I answered each of the questions, with non emotive language, clearly articulating the reasons why they were excellent, and why they were in the interests of the state, the households and the banks.
It’s not as simple to do, given that there are so many questions. Perhaps the way to do it is to just answer the question one, which asks what method the CBI should use and why.
Well worth doing


#16

You can submit up to the end of Monday.

The central bank is a bit glitchy at the moment.

Document is here once again.
centralbank.ie/regulation/po … ending.pdf

If will be gas to see all the shill submissions in one place(no doubt many under their friends names etc).

Some fucking tool on twitter is trying to get 100s of signature to a petition to stop the CB. Like we need more people getting into huge debt.

Mick Wallace retweeted them - says it all.

twitter.com/UpliftIRL/status/541277090721828865
uplift.ie/centralbank/


#17

The collection of holier than thou lefties re/tweeting that stuff is incredible


#19

Let me guess. The IT doesn’t also have another article from somebody in favour of the proposal? For balance like?


#21

rte.ie/radio1/this-week/

Gerry Adams :can’t give a straight answer on the CBI Mortgage restrictions - seems he’s not aware of the proposals (6:00) - he just shites on about mortgage distress when asked about proposals


#22

The revolution may not be televised but it sure will be retweeted and Liked.

I see one of the Uplift people is called Anna Bates who has two masters degrees. Quite literally Master Master Bates then.

What is Uplift’s status on people not paying debts?

I am not in favour of the proposed Central Bank LTI/LTV limits as a means of limiting demand in response to limited supply. If the Central Bank were serious about changing borrowing behaviour they would modify their Code of Conduct on Mortgage Arrears (CCMA) to enable faster property repossession when loans are defaulted on. This would have the dual result of increasing supply and limiting irresponsible loan behaviour. However in the light of the long-predicted fuck-up on rental properties, especially in Dublin, this will not happen.

I am in favour of quick and aggressive repossession when the terms of loan agreements are not being met. I feel the best approach to loan compliance is for people to see the rapid consequences of default which would be more effective in adjusting borrowing behaviour and responsibly taking on debt. It would demonstrate that the action of non-payment has consequences. There is nothing wrong with debt, except if you have an ideological bias. There is something wrong with irresponsible debt and people not being held liable for their actions.

The proposed Central Bank LTI/LTV limits would not stop a borrower not repaying their loan if that was their intention.