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Experience with DSTI in Lithuania Tomas Garbaravičius 3 July 2015 Vilnius Content ► Recent credit and housing market developments ► Reasons behind changes in housing lending standards ► Challenges/ issues/ policy questions 2 Responsible lending standards (RLS) ► Introduced in Nov 2011 as a preventive measure and as a response to the lessons of the financial crisis ► Amended in May 2015 ► Why changes? 3 A creditless economic recovery Credit growth in Baltic countries Real GDP and credit growth in Lithuania Annual percentage change 60 Annual percentage change 60 50 50 40 40 Lithuania Latvia Estonia Real credit* 30 30 20 20 10 10 0 0 Real GDP –10 –10 –20 –20 2005 2007 2009 2011 Sources: Statistics Lithuania and Bank of Lithuania calculations. * Credit to private non-financial sector from all creditors. 2013 2015 2005 2007 2009 2011 2013 2015 Sources: national banks, Eurostat, and Bank of Lithuania calculations. * Credit to private non-financial sector from all creditors. 4 Low household debt EUR billions 8 percentages of GDP 40 70% RLS RLS 7 60% annual growth 30 6 50% 5 40% 4 30% 3 20% 2 10% 1 0% Household debt 20 Housing debt 10 Housing loans 0 0 2005 2007 2009 2011 2013 2015 Sources: Statistics Lithuania, Bank of Lithuania and Bank of Lithuania calculations. -10% 2005 2007 2009 2011 2013 2015 Sources: Bank of Lithuania and Bank of Lithuania calculations. 5 No excesses in the residential property market House prices do not seem to be overvalued Deviation from a long-term equilibrium value 80 Positive expectations have lost momentum Net percentage 80 60 60 40 40 min-max range median 20 0 20 –20 0 –40 –60 –20 –80 –40 2000 2002 2004 2006 2008 2010 2012 2014 Source: Bank of Lithuania calculations. Note: measures include price-to-rent ratio, price-to-income ratio, deviations from HP-filtered trend and estimates from an econometric model. Latvia (SEB data) Lithuania (SEB data) Lithuania (Bank of Lithuania data) –100 2008 2009 2010 2011 2012 2013 2014 2015 Sources: SEB and Bank of Lithuania. Note: Net percentage is defined as the difference between the percentage of respondents expecting an increase and those expecting a decrease in residential property prices. 6 Nov 2011: Responsible lending standards (RLS) ► DSTI ≤ 40% (no mandatory interest rate test/ shock) ► LTV = 85% ► Maximum loan term = 40 years 7 DSTI and DTI are linked through the interest rate ► DTI = f (DSTI , interest rate, maturity, income) ► Excel function: Debt % , ∗ , ∗ , ∗ Annualincome ► Countries that use DSTI are in fact also using a DTI ratio that varies with interest rates ! – Explains strong DSTI impact on credit growth (Kuttner and Shim, 2015) 8 Housing loan interest rate and maximum loan amount in terms of DTI percentages and times of annual income 12 RLS 10 LITHUANIA Max DTI (debt-to-income) DSTI= 8 40% 1.85% Rate 5% 6% 6 Years 25 30 35 40 8.0 9.2 10.3 11.3 5.7 6.2 6.6 6.9 5.2 5.6 5.8 6.1 4 Interest rate 2 0 2000 2002 2004 2006 2008 2010 2012 2014 Sources: Bank of Lithuania and Bank of Lithuania calculations. 9 DSTI needs to be combined with interest rate test ► DSTI allows increasing DTI ratios in a declining interest rate environment and thus … ► … needs to be combined with an interest rate test to prevent excessive indebtedness ► Interest rate test calibration – Current interest rate plus x% sensitivity test Procyclical, still allows increasing indebtedness when interest rates decline – High absolute (long-term) interest rate level Provides an effective DTI cap 10 Macro-prudential risk assessment ► Risks for banks (weak lending standards) NO ► Risks for households(indebtedness) YES ► Excessive credit/ house price fluctuations ? – No concerns about housing prices, but – Stagnant housing credit, declining as % of GDP 11 May 2015: New lending standards ► ► Regular loans: – DSTI ≤ 40% – DSTI ≤ 50% with r = 5% (or actual rate, if higher) – Loan maturity cap shortened to 30 years Exemptions: – DSTI ≤ 60% for no more than 5% of new mortgages issued 12 Changes in maximum DTI NEW DSTI= Rate= Regular loans 50% 5% 1.85% Rate 5% 6% DSTI= Exemptions 60% 1.85% Rate 5% 6% Years 25 30 35 40 10.0 11.5 12.9 14.1 7.1 7.8 8.3 8.6 6.5 6.9 7.3 7.6 Years 25 30 35 40 12.0 13.8 15.5 16.9 8.6 9.3 9.9 10.4 7.8 8.3 8.8 9.1 OLD DSTI= 40% 1.85% Rate 5% 6% Years 25 30 35 40 8.0 9.2 10.3 11.3 5.7 6.2 6.6 6.9 5.2 5.6 5.8 6.1 No exemptions 5% of new mortgages 13 Impact on housing credit flows Calculations based on housing loans granted in 2014 By number of loans By volume of loans Share of loans which would have exceeded new limits 14 % 20,9 % Share of loans which would not have been issued with the same amount 1,0 % 1,8 % ► Exemption of 5% more than compensates estimated potential reduction in credit flows ► Based on housing loans issued in 2014, total increase in household monthly mortgage payments would amount to less than EUR 1 million per year. – ► Insignificant effect on consumption Changes to become effective as of 1 November 2015 14 Challenges/ issues/ policy questions ► Should DSTI vary with income? ► What is an appropriate level of DTI? ► Should macro-prudential limits vary by county/city? ► Unlevel playing field: unregulated non-bank lenders ► House purchases by foreigners and/or emigrants ► When and how to use LTV? ► What to do with activation lags? Should macro-prudential policy-making emulate monetary policy? ► 15 Source: IMF. South Korea Brunei Darusalam Hong Kong Serbia Singapore Algeria Bahrain China Ecuador Hungary Israel Pakistan Poland UAE Bahamas Canada Mongolia Netherlands USA Kuwait Lithuania Romania Columbia Brunei Saudi Arabia Q1: Should DSTI vary with income? DSTI levels DSTI limit, percentages 70 60 50 Average DSTI = 47% 40 30 20 10 0 16 Q1: DSTI and LTI as predictors of NPLs LTI at origination DSTI at origination Share of households with overdue mortgage payments 18% Share of households with overdue mortgage payments 18% 16% 16% 14% 14% 12% 12% 10% 10% 8% 8% 6% 6% 4% 4% 2% 2% 0% 0% DSTI at origination Sources: NŪFSIS and Bank of Lithuania calculations. Notes: Only loans that were granted in 2006-2008. Loan was categorised as overdue if a payment was overdue for more than 60 days during any quarter up to Q4 2013. (0-1] (1-2] (2-3] (3-4] (4-5] (5-6] (6-7] (7-8] (8-9] (1015] LTI at origination Sources: NŪFSIS and Bank of Lithuania calculations. Notes: Only loans that were granted in 2006-2008. Loan was categorised as overdue if a payment was overdue for more than 60 days during any quarter up to Q4 2013. 17 Q1: Higher DSTI + High income = Higher NPLs High wages were much less reliable in a downturn Share of households with overdue mortgage payments 15% Share of households with overdue mortgage payments 30% DSTI >60% 25% 12% 20% 9% 6% DSTI > 40% 15% DSTI (50‐60%] DSTI < 40% 10% DSTI (40‐50%] 3% 5% DSTI (30‐40%] All households 0% 0% (1-2] (2-3] (3-4] (4-5] (5-6] (6-8] (8-10] (10- >15 15] Household income, LTL thousands Sources: NŪFSIS and Bank of Lithuania calculations. Notes: Only loans that were granted in 2006-2008. Loan was categorised as overdue if a payment was overdue for more than 60 days during any quarter up to Q4 2013. DSTI (0‐30%] (1-2] (2-3] (3-4] (4-5] (5-6] (6-8] (8-10] >10 Household income, LTL thousands Sources: NŪFSIS and Bank of Lithuania calculations. Notes: Only loans that were granted in 2006-2008. Loan was categorised as overdue if a payment was overdue for more than 60 days during any quarter up to Q4 2013. 18 Q1: Should DSTI vary with income? ► Higher DSTI + High income = Higher NPLs Requests to apply higher DSTI for high-wage earners should be assessed cautiously as income of such borrowers can drop precipitously in a downturn ► Why was this the case for Lithuania: – – – – Volatile macroeconomic environment Most companies SMEs by European standards Aggressive borrowing/ high indebtedness Low wealth buffers 19 Q2: What is an appropriate level of DTI/ LTI? ► Lithuania: Estonia: UK: Ireland: 7.8 6.9 4.5 3.5 (embedded) (embedded) (explicit) (explicit) ► Could be higher for “converging” economies with higher potential growth rates, but by how much? ► What should be income growth assumptions? 20 Q3: Should macro-prudential limits vary by county/city? ► Euro area vs. countries ≈ Country vs. its counties/cities? ► Example: South Korea and Seoul ► Housing price bubbles are probably more likely to start in capital cities 21 Q3: Housing credit and GDP by county in 2013 GDP structure, % Housing credit-to-GDP, % Vilniaus apskritis 39 20 Vilniaus apskritis Kauno apskritis 20 16 Kauno apskritis Klaipėdos apskritis 12 24 Klaipėdos apskritis Šiaulių apskritis 7 10 Šiaulių apskritis Panevėžio apskritis 6 10 Panevėžio apskritis Telšių apskritis 4 8 Telšių apskritis Marijampolės apskritis 3 8 Marijampolės apskritis Alytaus apskritis 3 10 Alytaus apskritis Utenos apskritis 3 6 Utenos apskritis 7 Tauragės apskritis 16 LIETUVA Tauragės apskritis 2 0 10 20 30 40 0 5 10 15 20 25 22 Q4: Unlevel playing field: Unregulated non-bank lenders ► Macro-prudential lending standards apply to credit institutions only Not a significant issue in bank-dominated financial systems ► Forthcoming transposition of the EU Mortgage directive should change the situation – Non-bank housing lenders will have to register with the Bank of Lithuania and to comply with RLS – As is now the case for consumer lenders 23 Q5: House purchases by foreigners and/or emigrants Money transfers from abroad and housing transactions (Q1 2004 – Q4 2014) Thousands of transactions 15.0 until 2009 12.5 10.0 7.5 after 2009 5.0 2.5 0 100 200 300 400 500 Transfers from abroad, EUR millions Sources: Registrų centras and Bank of Lithuania calculations. 24 Q6: When and how to use LTV ratios? LTV ratios and changes in housing lending standards Procyclicality of LTV ratios in Lithuania Percentages 80 Percentages/ percentage points 15 Annual real GDP change (rhs) 60 10 Net percentages 100 LTV ratio, percentages 84 Easing of lending conditions 70 82 LTV (rhs) 40 5 40 20 0 10 78 0 –5 –20 76 –10 –50 74 –15 –80 72 –20 Annual LTV change (rhs) Annual change in house prices (lhs) –40 80 Tightening of lending conditions –20 –60 2005 2007 2009 2011 2013 Sources: Department of Statistics, Registrų Centras, PRDB and Bank of Lithuania calculations. –110 2005 2007 2009 2011 2013 70 Sources: Department of Statistics, Registrų Centras, PRDB and Bank of Lithuania calculations. 25 Q6: LTV and DTI changes in Hong Kong Source: McDonald C., „When is macroprudential policy effective?“, 14 November 2014 26 Q7: What to do with activation lags? ► Long activation/ implementation periods – – – Draft proposals revealed to public: Final standards announced: Activation: 9 April 2015 2 June 2015 1 November 2015 ► Banks need to prepare IT systems ► Unnecessary flurry in the lending market before activation ► Hong Kong – changes effective as of next day 27 Final question: Should macro-prudential policymaking emulate monetary policy? ► “General documentation” for macro-prudential instruments Banks fully prepared, no need to adjust IT systems after every decision ► Regular macro-prudential meetings and decisions – At least quarterly (countercyclical capital buffer decisions) – Decisions on lending standards effective immediately 28