Westpac Lobbies for Expense Verification Changes

Discussion in 'Loans & Mortgage Brokers' started by albanga, 4th Jul, 2019.

Join Australia's most dynamic and respected property investment community
  1. Rolf Latham

    Rolf Latham Inciteful (sic) Staff Member Business Plus Member

    Joined:
    14th Jun, 2015
    Posts:
    10,653
    Location:
    Gold Coast (Australia Wide)
    Mr/Mrs/Ms Broker Banker..........

    We are planning to have 3 children sometime in the next 5 years.

    And we arent yet sure who will be doing the maternity/paternity thing, but we want to be honest and provide full disclosure to the lender so they can meet their obligations.

    Further, as soon as we get the loan we will move into a contracting role from full time, and We are looking to start a business in 2 years time, and leave the contracting roles as well.

    Im sure there are lots more permutations, and you can see just how silly it can really be.

    Im not bad with expense verification, its needed for sure.

    We have a couple of level of verifications

    if a client tells me they take home 10 k, and their expenses are 5k and they save 4 k a mth over a period, and the loan services with some fat, thats all good

    If a client tells me they take home 10 k, and their expenses are 3 k, and they save none or 1000 a mth............. obviously we need to dig deeper.

    Line by line analysis isnt sensible in most cases, and we go to that as a fall back to rescue a deal.............to ascertain extraordinary or discretionary expenses.

    No method is perfect, and expecting to be so is daft, and quite normal from organisations that stipulate and dont implement.

    ta
    rolf
     
    TheSackedWiggle and paulF like this.
  2. Rolf Latham

    Rolf Latham Inciteful (sic) Staff Member Business Plus Member

    Joined:
    14th Jun, 2015
    Posts:
    10,653
    Location:
    Gold Coast (Australia Wide)
    And there you have it right there............

    The hedonic treadmill is in fact, highly discretionary, more so for someone earning higher income than for someone earning less.

    Fillet and business class are both discretionary, as are Penfolds Bin 389 over chateux le cardboard.

    Good examples of non discretionary for me are Private School fees, and another is child care where the child care is needed to earn an income.

    There is lots of interpretation and therein lies the challenge in trying to force a standard way of doing things

    ta
    rolf
     
    Blueskies likes this.
  3. hieund85

    hieund85 Well-Known Member

    Joined:
    16th Nov, 2017
    Posts:
    1,068
    Location:
    Melbourne
    Not true. In the last 2.5 years, my family income has significantly increased (approx. 100%) but our expense has gone down (same lifestyle but kid is at school now so no childcare). We use our extra income to invest, not spend.
     
  4. neK

    neK Well-Known Member

    Joined:
    18th Jun, 2015
    Posts:
    2,842
    Location:
    Sydney
    If only people took responsibility of their own actions and stopped blaming others when things go wrong.
     
    Brady likes this.
  5. Brady

    Brady Well-Known Member

    Joined:
    18th Jun, 2015
    Posts:
    2,570
    Location:
    Adelaide, SA
    100% unfortunately it's what happens.
    Defaults are usually due to a change in circumstances not living expenses.
    Reducing borrowing power doesn't mitigate against this.
    Having higher assessment rate doesn't mean that everyone now has lump sum available in time of need.
     
    Peter_Tersteeg likes this.
  6. TheSackedWiggle

    TheSackedWiggle Well-Known Member

    Joined:
    28th Jun, 2015
    Posts:
    1,826
    Location:
    canberra
    Responsible lending safeguards can't guarantee against all Known-Unknowns risks, but they should, at the very least, provides safeguards against Known-Knowns risks.
    Big disparity between 'what you claim you spend' and 'what you really spend' comes under Known-Knowns risk category.

    Agree with @Rolf Latham
    If one claims to earn X and spend Y he needs to demonstrate a saving of X-Y or close to it.
    How its measured is immaterial really, line by line, month by month or thru some voodoo magic.
     
  7. Brady

    Brady Well-Known Member

    Joined:
    18th Jun, 2015
    Posts:
    2,570
    Location:
    Adelaide, SA
    It's not just about what one is spending, it's about the ability to adjust that spending if required.
    Rates are dropped to increase discretionary spending, not much point doing that if impacts your ability to borrow.
    I like the approach of a detailed open discussion regarding spending habit between client + bank.
    Some expenses are not ongoing, they can be address and noted on the file. Risk mitigated, compliant.
     
  8. Brady

    Brady Well-Known Member

    Joined:
    18th Jun, 2015
    Posts:
    2,570
    Location:
    Adelaide, SA
  9. ChrisP73

    ChrisP73 Well-Known Member

    Joined:
    5th Oct, 2018
    Posts:
    1,214
    Location:
    Brisbane
    Totally agree. I don't need or want anyone else to take responsibility for my commitments. I also don't want anyone getting in my way either. Happy to deal with a lender or borrower on their own terms and happy for the government / courts to continue playing the role of umpire to ensure we all meet our commitments and enforce penalties for those that don't
     
    Last edited: 6th Jul, 2019
  10. Redom

    Redom Mortgage Broker Business Plus Member

    Joined:
    18th Jun, 2015
    Posts:
    4,658
    Location:
    Sydney (Australia Wide)
    In terms of this actually being an issue, it is a bit strange (there’s no real evidence underreporting of living expenses is an issue to lending quality).

    I don’t think ASIC have actually thought too deeply about the policy here, they’re needs to be more coordination to help them understand what the actual aim is rather then just going out enforcing what their interpretation of the law is. Perhaps they feel pressure to be seen, given how the RC slammed their performance.

    What exactly is the problem? What exactly is the aim/goal here?

    If regulators stick to these two questions as first principles of policy making, they won’t end up at solutions that involve line by line assessments. They can come up with a number of better ways to achieve their goal, than line by line expense treatment. It’s too slow.

    I.e this particular approach is classic ‘red tape’ regulation that serves little benefit to Australians and comes at a real cost. It’s 2019, Australians expect answers quickly and policy should help facilitate this. Tech helps improve loan quality too. Adding 2 hours to every file and requiring a manual assessment process is antiquated in today’s tech/auto business environment.

    Over time, I expect Treasury/RBA will get involved via the CFR and give ASIC clearer instructions here. It’s probably already happening, key ministers are getting vocal about this. They just need some quality advisers/consultations to pin point where blockages are and how to fix them. Ideally they’re not picking up the phone to APRA demanding assessment rate changes, when the issue isn’t borrowing power per se, but flow of credit. They need to get money moving quicker. It’s already happening, but banks appear to be unsure of what they’re actually required to do or why their being sued by ASIC.

    It’s part of the problem with three tier agency model to lending policy (ASIC are clueless about lending policy, it’s not their expertise and look at it in a silho). APRA/RBA should decide what to do here and ASIC lawyers should be told to enforce what they say.

    If you wanted better loan quality, Ideally you could just have a higher assessment rate or a higher/better adjustable HEM figure and have this relied upon as the ‘responsible buffer’ and then rely on standard common sense (humans will give up the San Pellegrino to save their home and avoid bankruptcy if required). All loan data, arrears feedback, actual macro evidence suggests this is how humans react.
     
    wilso8948 likes this.
  11. sumterrence

    sumterrence Well-Known Member

    Joined:
    19th Jun, 2015
    Posts:
    448
    Location:
    Sydney
    I don't mind the living expenses verification using most recent statements, but the fact that we need to assume people that earn more spend more it really does not make sense to me. Just becuase someone is earning $300k a year doesn't mean they need to spend a minimum of $5k a month on life style goods on top of their mortgage or rent expenses...
     
    luckyone likes this.