7/6/2012: Sunday Times May 27, 2012

This is an unedited version of my Sunday Times article from May 27, 2012.

Slowly, but with punctuality and certainty of a German train system, Irish mortgages crisis continues to roll on.

This week’s comments from the Central Bank of Ireland, the Financial Regulator and the Department of Finance have exposed the reality of the problem. Our banks’ extend-and-pretend ‘solutions’ to dealing with defaulting mortgagees, was only compounded, not ameliorated, by the State prevarication on core crisis resolution measures, such as personal bankruptcy reforms, developing robust measures to compel banks to deal with the owner-occupier loans arrears and putting forward an infrastructure of supports for Irish mortgagees.

Now, pretending that capital injections based on year-old PCAR tests were sufficient to manage ‘the isolated cases’ of defaults no longer works for the Government. As revealed in the Central Bank comments this week, mortgages arrears have now spread like a forest fire, overwhelming the banking system. Per Central Bank admission, almost one quarter of all mortgages in Ireland are now at risk of default or defaulting, with mortgages in arrears 90 days and over accounting for 10.2% of all mortgages outstanding or 13.7% in terms of the amounts of mortgages involved.

Based on the latest available data, 77,630 mortgages across the nation were in arrears over 90 days in Q1 2012. Using the trends in figures to-date, that would imply de-acceleration in the quarterly rate of arrears build-up from 11.5% in Q4 2010 to Q1 2011, to 9.5% in Q1 2012, although in absolute numbers, arrears increased by 6,719 in Q1 2012 on previous quarter, against a rise of 5,101 a year ago.

There are more ominous signs in mortgages data that are likely to be confirmed in the forthcoming Q1 2012 report.

The main one is the rate of deterioration in the quality of already restructured mortgages. In Q4 2010, 59.4% of all restructured mortgages were classified as performing. In Q4 2011, only a year after, that number was 48.5%. This doesn’t even begin to address the bleak reality of previously restructured mortgages that are currently ‘maturing’ out of the temporary interest-only and reduced payment periods.

Courtesy of the Central Bank of Ireland, we do not have any meaningful data for mortgages restructured in 2008-2009, nor do we have any data on what exact vintages and arrangements these restructurings cover. But we do have some information on the matter from the four state-backed banks annual reports. In the case of these, 10.8% of owner-occupied mortgages were in arrears at the end of 2011, while the arrears rate amongst the mortgages that have been previously restructured was running at close to 33%. More significantly, the rate of arrears build up amongst restructured mortgages was running at 77% over 2011, outstripping a 59% rise in overall number of mortgages in arrears.

Now, recall that the entire Government strategy for dealing with mortgages defaults rests on the extend-and-pretend principle of delaying the recognition of the losses. This is done through imposition of forbearance period, introduction on the voluntary basis of a repayments reliefs. Thus, the restructured mortgages are supposed to be cheaper to maintain than ordinary mortgages. Presumably, the restructured mortgages are also closely monitored by the banks, allowing for earlier flagging of growing problems with repayments and potential additional restructuring before the arrears build up.

Yet, as counterintuitive as it might be, the overall strategy is patently not working exactly for those who were supposed to have benefited from it. The menu of solutions developed by our reformed Financial Regulator and the Central Bank and the policy-active Government departments, alongside numerous working groups and task forces is both woefully short of tools and largely ineffective in scope.

The belated realisation of this has now led the Central Bank of Ireland and the Financial Regulator to make repeated calls for the banks to proactively engage in driving up foreclosures and repossessions, appointments of receivers and enforcers. The problem, from the consumer-conscious, yet banks-supporting Dame Street institution is that its estimates for mortgages-related losses produced back in March 2011 are now at a risk of being overrun by the reality. The problem from the economy’s point of view is that these calls come at the time when we have no new tools for dealing with negative equity involved in such foreclosures, thus risking accelerated foreclosure process to become nothing more than an extension of the crisis itself.

Back in March 2011, the Central Bank estimated base-line scenario 2011-2013 banks losses on residential mortgages books of the four core banking institutions to reach €5,838 million. The adverse scenario is for losses of €9,491 million. Taking into the account changes in house prices since the beginning of the crisis, the current running rate of arrears can put losses on mortgages, if the delinquent properties were to be foreclosed, closer to the levels that would wipe out the capital cushion provided for mortgages losses. And this just for the first two years of the three-year programme. Thereafter, either capital for mortgages losses will have to come from other assets cover (such as Commercial Real Estate or SME loans or corporate lending), or fresh capital will have to be injected.

The irony, of course, is that as I suggested in my analysis of the PCAR results a year ago, the Blackrock original adverse case scenario for life-time losses on residential mortgages – put at €16,898 million – was probably closer to what can reasonably be expected to materialize in the current crisis. Incidentally, the difference between Blackrock’s estimates and Central Bank provisions would mean an injection of €2-4 billion of new capital into the banks to deal with worsening mortgages losses over 2013-2014. This is exactly the volume of additional capital required as estimated by the Deutsche Bank analysts in a note published last week.

So the crisis has now crossed or is about to cross the lower bound of PCARs-allowed losses. And the Central Bank is spurring on the banks to more aggressively foreclose on defaulting mortgages. A major issue with such calls is that absent reforms of personal insolvency regime, accelerated foreclosures will mean lower banks losses at the expense of households. Central Bank’s vision for ‘more robustly addressing the crisis’ would put more people into a perpetual serfdom to the banks in order to undercut banks losses.

Instead of forcing banks to foreclose on defaulting and at-risk mortgages, the Central Bank should create a series of structural incentives that will compel banks to share burden of negative equity with households in financial distress.

CB should shed their pro-banks stand and force banks to take on deeper losses on defaulting mortgagees for owner-occupiers. They should re-evaluate banks capital allocations, and ring-fence specific funds, well in excess of those allocated under PCAR to mortgages writedowns only. In the case where mortgages are at risk of default bit not yet defaulting, banks must be forced to restructure these with a haircut on overall debt relative to equity.

One of the vehicles for restructuring can be the model deployed in the 1920s under the land purchase annuities. Funding a combination of interest relief and mortgage maturity extension can be secured via Central Bank underwriting for a ring-fenced distressed mortgages pool. In addition, it is crucial that banks are forced to consider both the current and the expected future taxes and charges increases in computing mortgages affordability.

Mortgage-to-rent scheme and split mortgages are valid tools in some cases, but these are not being deployed fast enough and the banks have no incentive to structure these in favour of the households. Short-term forbearance should be replaced by measures aimed at achieving long-term sustainability.

A functional and robust mechanism must be put in place to independently oversee the on-going restructuring of these debts. Having sided with the banks all the way through the crisis, existent State bodies cannot be trusted to deliver on this. Instead, a transparent and fully independent entity, involving the non-profit sector operating in the areas of assisting people in mortgages difficulties, plus the strengthened Financial Services Ombudsman and the National Consumer Agency, should be put in place to police the resolution process. Legacy institutions, such as Mabs, should be reformed, if not reconstituted top-to-bottom. Alongside the reform, their resources, professional and board-level, should be strengthened.

Simply talking tough at the banks, as our Financial Regulator and the Central Bank are doing, will not resolve the crisis we face.

CHARTS:

Source: Author calculations based on data from the Central Bank of Ireland

Box-out:

A recent World Bank research paper “Performance-Related Pay in the Public Sector: A Review of Theory and Evidence” surveyed the literature on the theoretical and empirical studies of performance-related pay schemes in the public sector spanning the fields of public administration, psychology, economics, education, and health. The authors found that, based on a comprehensive review of 110 studies of public sector and relevant private sector jobs, a majority of studies (some 60%) found a positive effect of performance-related pay, with higher quality empirical studies generally more positive in their findings (68%). However, these studies predominantly covered jobs where the outputs or outcomes are more readily observable, such as teaching, health care, and revenue collection. There is insufficient evidence, positive or negative, of the effect of performance-related pay in organizations characterized by task complexity and the difficulty of measuring outcomes. Several observational studies identify problems “with unintended consequences and gaming of the incentive scheme”. With a number of caveats in place, this evidence strongly suggests that Irish Government approach to ‘reforming’ the public sector within the confines of tenure-based, rather than performance-based salaries and bonuses, as enshrined in the Croke Park agreement, is a false start on achieving meaningful productivity improvements in the sectors where outputs can and should be measured and cross-linked to actual performance.

25/5/2012: Mortgages in Arrears: Q1 2012

Latest mortgages arrears data from the CB of Ireland came in with a slight surprise that most of the media should have anticipated. During the launch of the annual report, the CBofI has pre-leaked some of the top-level figures for arrears, with media reports of 10.5% (or ca 80,000) of mortgages in arrears expected in Q1 2012 figures. Of course, given the usual tactic of first exaggerating, then underwhelming (presumably there's some psychological strategy working its magic somewhere here), it should have been expected that actual numbers - bad as they may be otherwise - will 'surprise' to the positive side relative to the leak-related expectations. It might have worked.

Alas, the end numbers - whether or not they are better than leaked out 'estimates' - are pretty dismal.

In Q1 2012, there were 764,138 mortgages outstanding amounting to €112,688.5 million. The latter number is €789 million down on Q4 2011 and€3.27 billion lower than Q1 2011 figure. So in 12 months, with foreclosures and restructuring factored in, Irish mortgagees were able to pay down just 2.82% of the mortgages outstanding. This is not exactly a massive rate of de-leveraging for heavily indebted households.

Of these, 77,630 mortgages were in arrears over 90 days (up 9.4% qoq and 56.5% yoy), with total outstanding amounts of €15,386 million (up 10% qoq and 60.3% yoy). Previous quarter-on-quarter increases were, respectively, 12.7% and 13.1%.

Repossessions in Q1 2012 stood at 961 up from 896 in Q4 2011.

Restructured mortgages:

• At the end of Q1 2012, there were 38,658 mortgages restructured, but not in arreas, up 5.06% qoq (against previous qoq rise of 1.16%) and up 5.44% yoy.
• In addition, there were 41.054 restructured mortgages that were in arrears, up 9.23% qoq against previous quarterly rise of 12.67%, and up 56.25% yoy.

Overall, defining at risk or defaulted mortgages as those mortgages that are currently in arrears (including restructured and in arrears), plus restructured but not in arrears mortgages and repossessions:

• At the end of Q1 2012 there were 117,249 at risk or defaulted mortgages, constituting 15.34% of all mortgages outstanding and amounting to €21.72 billion, or 19.27% of total volume of mortgages outstanding.
• Number of mortgages at risk or defaulted has increased 7.93% qoq in Q1 2012 as compared to a rise of 8.39% qoq in Q4 2011. Annual rise in Q1 2012 was 34.83%.
• Volume of mortgages at risk or defaulted has increased 8.09% qoq in Q1 2012 as compared to a rise of 9.8% qoq in Q4 2011, and there was an annual increase of 37.67%.
• In Q4 2011, mortgages that are at risk or defaulted constituted 14.13% of the total number of mortgages, while in Q1 2011 the proportion was 11.11%, and this rose to 15.34% in Q1 2012.

CHARTS:

Note: more on this next week.

14/4/2012: Sunday Times 8/4/2012 - Irish banks: The Crunch is Getting Crunchier

This is an unedited version of my Sunday Times article from 08/04/2012.

A year has lapsed since the much-lauded publication of the first set of the Prudential Capital Assessment Review results – the stress tests – by the Central Bank of Ireland.

Covering the four core banking institutions subject to the State Guarantee, AIB, Bank of Ireland, Irish Life & Permanent and EBS, the tests were designed to be definitive. Once recapitalized by the Exchequer in-line with the PCAR, Irish banks were supposed to be returned to health – recommencing lending to the SMEs and households, returning to normal funding markets around 2013, while continuing to shed loans to improve their balance sheets.

The PCAR made some major predictions with respect to the banking sector performance over 2011-2013 that were not subject to Nama-imposed losses and, as such, are expected to continue into the future. Chiefly, the Central Bank allowed in its stress scenario for the lifetime losses of €17.2 billion on the residential mortgages books of the four institutions. Only €9.5 billion of these were forecast to hit in 2011-2013. Owner-occupier mortgages losses provided for 2011-2013 amounted to just 60% of the above. Post-2013, it was envisaged that the Irish banking system will be able to fund remaining losses out of its own operations with no recourse to the Exchequer assistance.

Having published the PCARs, the Irish Government proceeded to take a break from the banking crisis. Throughout the second half of 2011 there was a noticeable ‘We’ve sorted the banks’ mood permeating the refined halls of power.

Fast-forward twelve months. Annual results for the four domestic State-guaranteed banks for 2011 are, put frankly, alarming. Set aside for the moment the entire media spin about ‘lower 2011 losses compared to 2010 records’. Once controlled for Nama effects on 2010 figures, the data shows acceleration, not an amelioration of the crisis on the mortgages side.

Excluding IBRC, total amount of owner occupied mortgages that remain outstanding on the books of AIB and EBS, Bank of Ireland and PTSB comes to €71.8 billion or 63% of all such loans held by the banks operating in Ireland. According to the Central Bank of Ireland, 12.3% of all mortgages held in Ireland were 90 days or more in arrears – some €13.9 billion. Of these, the four State-guaranteed banks had €7.7 billion owner-occupier mortgages in arrears, representing 10.8% of their combined holdings. Given banks’ provisions, by the end of 2012, the expected combined losses on mortgages, can add up to 60% of the total 2011-2013 losses allowed under PCAR.

And this is before we recognise the risks contained in a number of mortgages restructured in 2009-2010 that will come off the forbearance arrangements. Many are likely to go into arrears once again in 2012 and 2013. Recall that the entire Government strategy for dealing with mortgages defaults rests on the extend-and-pretend principle of delaying the recognition of the loss by giving borrowers some relief from repayments, e.g. via interest-only periods. This approach is patently not working.

Looking at EBS and AIB results tells much of the story behind the forbearance risk factor. In 2010, the two banks had 16,992 restructured residential mortgages amounting to €3.7 billion. Of these, residential mortgages amounting to €3 billion were interest-only. Of all forbearance mortgages, 92% were classed as performing. By 2011, AIB and EBS held 32,266 forbearance residential loans totalling €6.2 billion – almost double the levels of 2010. Total amounts of mortgages in forbearance arrangements that went into impairment or arrears over the course of 2011 jumped more than seven-fold. One third of the forbearance mortgages are now in arrears.

While Bank of Ireland data is not as comprehensive on 2010 and 2011 comparatives, current (end of 2011) levels of restructured mortgages run at €1.25 billion, of which €249 million were impaired or past-due more than 90 days. This means that €999 million worth of restructured mortgages remain at risk of future arrears. PTSB report for 2011 shows restructured mortgages rising from €1.7 billion in 2010 to €2.1 billion, with those in arrears rising three fold to €524 million.

Taken together with the aforementioned 2010-2011 dynamics, changes to the insolvency regime imply that mortgages losses can exceed Central Bank’s forecasts for 2011-2013 period. Of all four banks, Bank of Ireland remains the healthiest, and the likeliest candidate when it comes to mortgages-related losses. Of course, the banks can continue extending recognition of the losses past 2013, but that will mean no access to non-ECB funding at the time when ECB is increasingly concerned about extending more loans to Irish banks. Worse, with the first LTRO maturing in 2014, Irish banks will be staring into a new funding storm, when their healthier competitors all rush into the markets to fund their exits from LTRO.

Which, of course, means that the entire Government exercise of shoving taxpayers cash into insolvent institutions is unlikely to resolve the crisis. The core banks will continue nursing significant losses well into 2014-2015, with capital buffers remaining strained once potential losses are factored in. And this, in turn, will keep restrained their lending capacity.

Recent Central Bank estimates show that Irish economy will require up to €7 billion in SMEs lending and €9 billion in new mortgages in 2012-2014, while banks are to accelerate deleveraging of their loans books to meet lower loans to deposits standards. At the same time, there will be huge demand for Irish banks lending to the Exchequer, once some €28 billion of Government debt come to mature in 2013-2015. As we have seen with the Promissory Notes ‘deal’, so far, the Government has difficulty getting Irish banking system to buy into Government debt in appreciable amounts.

In other words, we are now staring at the basic conflict inherent in running a zombie banking system that continues to face massive losses on core assets. At the very best, the choice is: either the banks’ will lend to the real economy, while foregoing their support for Exchequer post-2013; or the state uses banking sector resources to cover its own bonds cliff, starving the real economy of credit. The first choice means at least a shot at growth, but the requirement for more EFSF/ESM borrowing (Bailout 2). The second choice means extending domestic recession into 2015.

It is also likely that we will see amplifying politicization of the banking system, with credit allocated to ‘connected’ enterprises and politically prioritized sectors, at the expense of overall economy. Reduced competition – from already below European average levels, judging by the ECB data – will continue to constrain credit supply.

The lesson to be learned from the 2011 full-year results for Irish banks is a simple, but painful one. Banks going through a combination of a severe asset bust and a massive debt overhang crisis are simply not going to survive in their current composition. We need to carry out a structured and orderly shutting down of the insolvent institutions, in particular, IBRC, EBS and PTSB. We also need to restructure AIB. At the same time, we should use the process of liquidation of the insolvent banks to incentivise emergence and development of new service providers.

This can be done by using assets base of the insolvent institution to attract new retail banking players into the market. This process can also involve enhancing the mutual and cooperative lenders models.

Given current funding difficulties, it is hard to imagine any significant uptick in lending in the Irish economy from the traditional banking platforms. Thus, we need to create a set of tax and regulatory incentives and enablers to support new types of lending, such as facilitated direct lending from investors to SMEs. Such models already exist outside Ireland and are gaining market shares around the world, in particular in advanced Asian economies.


The State Guaranteed banking model is, as the 2011 results show, firmly bust. Time to rethink the strategy is now.


Charts:

Box-out:

On the positive front, Q1 2012 Exchequer results released this week showed total tax take rising to the levels, not seen since 2009. Total tax revenues came in at €8,722 million, just below €8,792 in 2009. Year on year tax take is up 16.2%. But hold that vintage champagne in the fridge for a moment. Tax revenues for Q1 this year include reclassified USC charges which used to count as departmental receipts instead of tax revenues. The department of Finance does not provide estimates for how much of the income tax receipts is due to this change, but based on 2010 figures it is close to ca €525 mln. They also include €251 million of corporation tax receipts from 2011 that got credited into January 2012 figures. Netting these out, tax revenues are up 8.2% year on year – still appreciable amount, but down 7.6% on 2009. Compared to Q1 2008 – the first year of the crisis, we are still down in terms of tax receipts some 26.2%. Even at the impressive rate of growth, net of one-off changes, achieved in Q1 this year, it will take us through 2017-2018 before we get our tax take to 2007-2008 levels. As the Fianna Fail 2002 election posters used to say “A lot done. More to do.”

12/3/2012: Why the 'trackers deal' is bad news for Irish mortgagees

The news galore surrounding the Promissory Notes (usually reported cheerfully with the customary references to unnamed sources as to the eminence of the 'deal') and so-called 'lobbying' by the Irish Government to restructure more broadly (un)defined 'banks debts' is continuing to gain momentum day after day, with no actual real signs of anything tangible being done. 


But the real news here is what is being 'rumored' and 'discussed', not the actual feasibility of the 'deal'.


Per reports and Ministerial statements, Ireland is lobbying ECB / EU Commission /EU in general (whatever that means) to allow the country to alter the burden of the IBRC Promissory Notes and, crucially, as per last night news - restructure loss-making tracker mortgages on the balancesheets of its banks.


Minister Noonan stated yesterday on RTE that the discussions on the promissory notes also included the possibility of 'shifting' loss-generating (for banks) tracker mortgages off banks balancesheets into IBRC. The problem, of course, is that these mortgages account for ca 53% of all mortgages held/issued by the Irish banks in relation to the residential property. The rates of default on tracker mortgages is lower than that for ARMs


The banks are complaining loudly that their funding costs exceed the tracker mortgages returns due to low ECB financing. So the real issue here is that the banks are facing state-imposed 'reforms' that are in effect forcing them into future losses on tracker mortgages. The current losses are due not to the actual tracker mortgages problems, but due to the banks prioritizing bonds and debt repayments (raising cheap funding to do so) while complaining about losses on tracker mortgages.

Alas, something is seriously off in this argument for the following reason. Irish banks largely fund themselves at ECB rate via LTROs and normal repo operations. What 'funding costs' they have in mind, beats my understanding of their operations. So the whole issue is a red herring. The banks simply make too small of a margin on these mortgages to use them to cross-subsidize market funding access. That's the real story - the story of the potential loss, not actual loss.


How bogus the issue is? Bank of Ireland doesn't even bother to identify specific losses or any issues relating to tracker mortgages in its latest interim report.


So overall, the issue is a bogus concern for mortgagees covering up the real desire of the Government to provide yet another rescue line of taxpayers' funds to the banks. In other words, the move of tracker mortgages will do absolutely nothing to alter the conditions of loans repayments or costs of these mortgages to the mortgagees. Nor will it reduce the mortgagees debt. Instead, it will simply shift lower margin products off banks balancesheets, allowing the banks to gouge their ARM holders with higher margins over the ECB rate without direct comparative (transparent) pricing to tracker mortgages. More opacity, higher margins, no help for tracker mortgagees, shifting more burden of banks bailouts onto ARM mortgagees - that is, in the nutshell, what Minister Noonan's game plan appears to be.

16/10/2011: Negative Equity and Debt Restructuring

This is unedited version of my article in Irish Mail on Sunday (October 16):

This week, we finally learned the official figure for what it would cost to address one of the biggest problems facing this country.

According to the Keane Report - or the Inter-Departmental Mortgage Arrears Working Group Report - writing off negative equity for all Irish mortgages will cost “in the region of €14 billion”. Doing the same just for mortgages taken out between 2006 and 2008 would require some €10 billion.

These numbers are truly staggering, not because of they are so high, but the opposite: because they contrast the State’s unwillingness to help ordinary Irish families caught in the gravest economic crisis we have ever faced with the relatively low cost it would take to do so.

Let me explain.

Firstly, the figure of €14billion itself is a gross overestimate of the true cost of dealing with negative equity. This is because this figure appears to include not just owner-occupiers but also people with buy-to-let loans in his sums.

Secondly, the real amount required to get rid of negative equity where it matters most – for ordinary first-time buyers - is lower still. For example the scheme could be set up in a sliding scale based on value of house compared to average house prices. This would reduce the final cost of the scheme and help those who need it most - moderate income and younger-age households.

In other words, a realistic and effective debt cancellation scheme can be priced at closer to €6-8 billion instead of the €10-14 billion estimated in the report.

In its simplest form it would work like this: say you bought a house for €300,000, with a mortgage of €250,000, and it is now worth just €150,000. The government, or the bank using the recapitalisation funds they have received, would pay off the €100,000 difference.

By doing this your monthly payments would be less, and you could now sell up to pay off the debt or move house, and in the meantime the extra money you have to spend could go back into the economy.

The scheme could even be set up so that write downs would be smaller on houses with above average values so as to prioritise young and low-earning families. In the above example, if the house was purchased for, say €500,000 and is no worth half that amount, the bank would write-off, say, €200,000, leaving the household with residual negative equity of €50,000. This would still improve affordability, but will also cut the overall cost of the scheme.

So why did the report completely rule this out? It was very clear on this topic: “a blanket debt or negative equity forgiveness scheme would not be an effective use of State resources and would not solve the problem,’ it says.

But it goes further, claiming that “the primary driver of mortgage arrears is affordability, not negative equity. While a write-down of negative equity would help mortgage holders in arrears, in many cases it is unlikely to create an affordable mortgage”.

I believe this rejection betrays the overall lack of understanding by our senior civil service officials of the problems we face.

The Irish economy is suffering primarily from three things. The biggest is excessive household debt.

While this would be bad enough, it is exacerbated by two additional factors. The cost of the government’s policy of bailing out our banks, which is being paid for with higher taxes on ordinary working households. And the rising cost of mortgagesdue to aggressive drive by Irish banks to improve their profit margins at the expense of the most vulnerable mortgage holders - those with adjustable rate mortgages who cannot protest. Both contribute to mortgages defaults.

By saying that cancelling negative equity will not be a magic bullet solution to the problem of the defaulting mortgages, the report is simply referencing the smaller problem of mortgage affordability to evade addressing the effects of the much larger crisis facing us.

Negative equity is the single most egregious and damaging segment of the debt problem faced by Irish families.

It is the most egregious because it was caused not by reckless borrowing, but by reckless lending by the banks - actively supported at the time by the Irish Government.

The problem of negative equity is the result of state policy in the first place, and it is up to the state to rectify it.

And contrary to the assertion of the report and Government claims, we do have the funds to deal with negative equity. Freeing these funds to help ordinary families is just a matter of priorities for the Government and the state-controlled banks.

To-date, the Irish Government has injected €63 billion worth of taxpayers’ funds into Irish banks.

Various other commitments, and the banks’ own state-guaranteed borrowings from the Central Bank bring the total cost of keeping our banking sector working to a gross figure of about €125 billion.

Yet while they have saved the banks, all of these measures have acted to increase, rather than reduce, the level of debt being carried by the households of this country.

In addition to their own household borrowings like credit cards or credit union loans, mortgages-holders are now in effect liable both for banks’ debts and their losses on property development and investment.

In contrast, even at Keane’s upper estimates, the cost of paying off negative equity liabilities for household mortgages would require just one ninth of the funds we have made available to the banks.

Last July the Government injected some €19 billion worth of capital into Irish banks. This capital is provided to cover potential future losses on loans. This included €9.5 billion, which was the estimated worst-case scenario for losses on residential mortgages. It also included another €8.9 billion to cover remaining expected losses on commercial property.

If some of these funds were used instead to restructure negative equity mortgages on family homes it would do two things for the banks.

Firstly, because the banks would now have securities as valuable as the mortgages they have given, a mortgage default would not be such a threat in terms of losses. This then reduces the bank’s need for further capital.

Secondly, the writedown of the mortgages will prevent defaults in the first place, at least for some families.

This implies that prioritising how that money is used to help mortgages rather than losses on commercial property loans, will be a more effective way to improve their balance sheets.

And it’s not like the money is not there. Our banking system currently has surplus capital available. Since August this year, our ‘pillar’ banks, instead of helping the struggling households, have used taxpayers funds to quietly buy high-yield Irish Government bonds.

Some €3 billion worth of Government debt was bought by the banks using our money in order to beef up their own profits. Don’t tell us that the banks cannot afford negative equity restructuring when they clearly can afford buying junk bonds in the markets to book higher profits.

And the farcical nature of Irish government responses to the mortgages and personal debt crises continues.

The Keane report ruled out increasing tax relief on mortgage interest finance for first time buyers during the boom, 2004-2008. Why? Because the estimated cost each year would have been €120 million.

Yet, come November, the very same state will pay in full the unguaranteed and unsecured €737 million debt of the bankrupt zombie Anglo. Between Anglo and INBS, the state has also committed to repaying in full €2.4 billion more of similar bonds in 2012.

Instead of repaying un-guaranteed bondholders, the Government should use the funds available to the banks to cancel commercial property-related losses on banks books, freeing the capital injected for this purpose in July this year to restructure negative equity mortgages.

Earlier this year, I proposed that Irish Government impose an obligatory restructuring of all mortgages to achieve a maximum Loan-to-Value ratio of 110%.

This would reduce the problem of ‘moral hazard’ because households with greater borrowings will still be left with more debt than their more prudent counterparts. But it would also reduce the overall debt burden faced by our families, freeing them to return to active economic and social life, helping to restart the Irish economy. Based on the Keane Report’s own estimates of the cost of such a scheme we have more than enough money to make this choice.

All we need is the will - the will to free hundreds of thousands of Irish families from the negative equity jail that was built by reckless banks which lent the money with explicit approval of the previous Governments.

13/10/2011: Mortgages report - offensive & ineffective failure

Inter-Departmental Mortgage Arrears Working Group report, released yesterday is a truly abysmal document that neither delivers meaningful solutions to the problems it sets out to tackle, nor provides any really new solutions that were not already discussed in the Cooney report of 2010.

Let’s consider the ‘solutions’ advanced by the Report. Let us also juxtapose these ‘new’ proposals against the existent means for alleviating stress on households finances arising from the excess debt or lack of debt affordability, which are enumerated in the Report.

An excellent additional analysis of the report is provided by Namawinelake blog (here) and I am broadly in agreement with its author conclusions.

Note that, unlike the Report authors, I view two problems as separate, but related.

The problem of debt overhang is the problem of too much debt carried by the household preventing this household from accumulating pensions and precautionary savings, reducing its ability to provide insurance cover for catastrophic losses of income due to illness or unemployment, restricting reasonable investments in household members’ education and skills (children education, but also adult education – both of which require outlays from the household finances), extending care for incapacitated relatives, saving for potential investment in family business etc.

The problem of debt servicing is the problem whereby debt to income ratios rise to levels whereby debt financing becomes unbearable for the household. This can arise due to any of the following factors or a combination of several factors, such as: loss of income due to unemployment, loss of income due to wage cutbacks or decline in bonuses and commissions, loss of income due to higher taxation burden, loss of income due to illness, increase in expenses due to birth of a new child or arousal of new dependency from, for example, ill close relative, etc.

What solutions does the Report propose?

Solution 1: Forbearance.

This is not a new solution and the Report states that as a part of the “wait and see approach” already adopted by the Government, they are not always appropriate. In other words, one of the solutions presented by the Report is already deemed by the very same Report not to be sufficient. Forbearance is ‘extend and pretend’ type of a ‘solution’ that temporarily reduces the mortgage burden in the hope of short-term return to affordability. It does not deal with the problem of excessive debt carried by the household. Instead it actually exacerbates the problem by accumulating retained interest and extending over time the period of principal repayment, as in the case of forbearance households are mostly excluded from counting their repayments against the principal. It is a very short-term measure (extending the period of forbearance will have a compounded effect of increasing the overall debt level of the household).

As an extension of the Forbearance scheme, the Group notes that Deferred Interest Scheme has already been introduced in the state. The Group fails to provide any meaningful assessment of the scheme claiming that it is too new to allow for such assessment. In reality, deferring interest repayment implies accumulation of higher debt over time through compounding and roll up of interest into the future and has exactly the same shortcomings as the general forbearance scheme discussed above.

Another major issue with both schemes is that they do not alter life-time affordability of the mortgage, which is reflected in their temporary nature. Temporary nature of these schemes, in turn, implies that households entering into these arrangements cannot be expected to meaningfully engage in the economy as savers and consumers. They are suspended in a debt hell limbo for the duration of the scheme and face uncertain future as to their ability to return to normal functioning.

What we need is: conversion of the existent mortgages pool into non-recourse mortgages only for the amount of negative equity. To deliver this, mortgages outstanding should be seen as split between those covering 90% of the current value of the asset (10% cushion provided for future decreases in valuations) and the residual. The 90% current value of the mortgages is recoursed against the value of the home. The excess amount of mortgages outstanding is non-recourse.

Solution 2: Mortgage Interest Supplement.

A measure that provides cash flow support to households that are on public assistance due to unemployment or disability. The Group identifies this scheme as in the need of alteration and suggests that mortgage-to-rent (MTR)schemes (see below) can be used to move long-term recipients of MIS off the temporary measure. This implicitly suggests that the Group sees MTRs as a long-term default option.

Amazingly, the Group provides un-backed and un-specified estimates for writing down the entire pool of negative equity or writing down the most severe negative equity cases (2006-2008 mortgage originations) at €14 billion and €10 billion. The Group states in a blanket fashion that “scheme would not be an effective use of State resources and would not solve the problem”.

Worse than that, the Group has managed to produce not a single meaningful or even token debt relief measures. The Group “examined the proposal to increase mortgage interest relief to 30% for First Time Buyers in 2004-08 but it was considered that this change should not be recommended. The proposal would give increased relief in an indiscriminate manner as it would give benefits to all who took out mortgages in the relevant years, regardless of their economic circumstances. The proposal would cost the Exchequer approximately €120m in a full year and it would not be appropriately targeted at those who need the support.”

This is an extraordinarily bizarre statement. The Group on objective – as stated – included to consider measures “to reduce the drag on the economy from a significant cohort of over-indebted people whose spending is constrained by mortgage debt obligations.” And yet, the Group passed on the only solution they considered to deliver some relief here. Reducing effective cost of mortgages interest financing would have improved significantly many, more stretched, households cash flows, especially for those early into the process of mortgages repayment. In other words, it would have had a compounded effect of reducing interest payments when these payments are the largest proportion of the mortgage itself, potentially improving repayment of capital. The scheme would have had no adverse impact on moral hazard and would have been politically acceptable as a partial compensation for tax increases suffered by the very same households. It is cheap (could be financed for 6 years out of just one unsecured unguaranteed bond repayment by Anglo due this November at €737 million) and effective in reducing the most egregious share of the debt incurred – interest charges. It also could have served as a buffer for future interest rate increases, thus effectively helping more, in the longer term, those on the adjustable rate mortgages who are currently subsidising tracker mortgage holders.

The fact that these considerations were omitted by the Group shows that the Group was not fit for purpose – its members had no sufficient financial insight into the debt issues and mortgages finance to make any reasonable assessment of the situation.

What we need is: extended Interest Tax Relief scheme covering all first-time mortgages for principal residences issued in 2004-2008 with extension for 5 more years at 50% of the total interest paid. The cost of this scheme should be in the neighbourhood of €250 million per annum and it should be financed through writedowns of unsecured bondholders in Irish banks.

Solution 3: Introduce New Bankruptcy Legislation.

This is hardly a new solution and as such the Group was expected to provide more robust guidance as to the terms of reform of existent bankruptcy laws. The Group correctly identifies one major part of the problem with existent legislation as: “Given the full recourse nature of mortgages there is no current insolvency option for many mortgage holders who are in difficult or unsustainable mortgages – they could face permanent bankruptcy”. In other words, the problem is in the full recourse nature of the mortgages and the long-term or permanent nature of the bankruptcy.

The Group comprehensively fails to address both sides of the problem in its recommendations.

With respect to the length of the bankruptcy status and associated claim on the debtor income, the group states:

“The group understands that the automatic bankruptcy discharge period under the judicial process could be set as low as 3 years”. In other words, the Group fails to make any proposal as to the length of bankruptcy period. It simply defaults to 3 years as the only option because it is what it being discussed elsewhere.

What we need is a two-tier approach to the bankruptcy reforms:

Tier 1: Emergency level legislation covering mortgages taken prior to 2009 which will have automatic release after 12 months of compliance with court-ordered repayment schedule and zero recourse thereafter. In the case of non-compliance with repayments, the bankruptcy period can be extended to 3 years and then to 5 years. There should be no recourse on assets outside the mortgage, but access to bankruptcy should be granted only to those unable to pay their mortgages through current income as supplemented by a reasonable drawdown of existent assets. For example, a household savings should not fall below 20% of annual pre-tax income so as not to deplete insurance buffer against household loss of income in the future due to illness or unemployment. The households can be required to sell any other property assets they hold if this releases funds to aid repayment of mortgage. The legislation should apply only to primary residences and can be staggered to reduce its applicability to ‘trophy’ homes, so that only part of the family home mortgage under, say, the threshold of €500,000 can be covered by such process.

Tier 2: Long term legislation covering all mortgages taken since 2009 that will include, 3 year term for automatic release, recourse against other assets and restriction on mortgages issued in the state to non-recourse mortgages only, for all new mortgages going forward.

Instead of robust proposal for reforming the bankruptcy law, the Group report produces extraordinarily woolly wish list of non-judicial process proposals for dealing with defaults.

This includes a non-judicial settlement process that is not backed by any compulsion on behalf of the lender to engage in such a process or to deliver any specific targeted means for reducing overall debt burden of the household. Instead of specifically calling for lenders being required to write down some minimum share of debt, or some debt linked to, say, income and affordability metrics, the proposal simply waffles on about “mortgage lenders will need to make allowance within their mortgage solutions, on a case by case basis, to make some funds available to facilitate unsecured debt settlement”.

And there’s more: “Uncertainty exists as to how the courts will deal with an income earning bankrupt – it could require them to make payments to the creditors beyond the discharge period.” Now, this begs a question: why on earth did we need the Group report if all it can tell us is that the courts will decide? And how can the report make a claim that this entire strand of bankruptcy resolution has any whatsoever validity as a tool for alleviating currently draconian bankruptcy conditions if it is left up to the courts to decide?

Another ‘measure’ proposed by the Group is Debt Relief Order (DRO), which will “allow persons with “no assets – no income” to fully write-off unsecured debt within a short period of time”. How? No information is given. How long is the ‘short period of time’? Unspecified. But the Group refers to the UK DRO equivalent of €17,000. So, let’s summarize this ‘measure’ – under DRO, once you are bled dry, the Government will facilitate (legislatively, presumably) an up to €17,000 writedown of your debt alongside the loss of your home, your assets and your income, while levelling you with the very same bankruptcy burdens as above. The whole mechanism would constitute a reasonable measure only in a lunatic asylum.

Solution 4: Mortgage to Rent Scheme (MTR)

This implies converting existent mortgage to a lease with the mortgage holder losing all future claim on equity in the property.

The problem is that, as the Group states: “The group recommends the introduction of two mortgage to rent (MTR) schemes aimed at those people who would qualify for social housing if they lost their home and where their house is appropriate to social housing”

So explicitly, there is no cover for anyone who does not qualify for social housing. In brief – you are either broke or you are not covered. Which automatically means the scheme does no work to alleviate constraints on future savings and investment, pensions provision, education investment etc.

“The schemes should be subject to an initial review after 12 months and a value for money review after 24 months” In other words, the scheme is non-permanent and cannot be considered a solution to the long term problem. It is simply ‘extend and pretend’ type of a solution with the worst possible outcome – all future uncertainty is loaded onto the mortgage holders.

A person entering the scheme, in effect, surrenders any legal claim on the asset and any leverage for dealing with the default-related loss once he/she signs the papers as the state can simply deny the benefit in 12 months or later.

Worse than that, “There may be a mortgage shortfall that will still need to be dealt with” in other words, the negative equity component of the mortgage remains unaddressed, i.e. it remains the liability of the original borrower. This provision is simply mad, given the Group set out to resolve the problem of defaulting mortgages.

Solution 5: Trade-down Mortgages (TDM)

Trade down mortgages is in itself not a solution to the debt crisis, but an affront to those currently struggling under the weight of debt. It ignores the fact that majority of those heavily indebted (relative to their incomes) are younger families who bought their first homes – small, usually out of town, lower-end-of-the-market dwellings trading down from which is an equivalent to telling them to pitch a tent in a bog and call it a “more modest home”.

Worse, the proposal admits that the scheme would increase, not decrease, the overall debt burden carried by the mortgage holder as LTVs are going to rise and not just by the amount of negative equity carried over, but also by the closing costs which the Group has no grace to advocate forgiveness for. Negative equity is then crystallized into real debt. In medical terms, it is like advocating cutting both limbs for a patient with one gangrened arm!

The Group’s brain-dead - and I cannot call it any other – ‘logic’ is such that they actually state: “While the increased LTV is relevant, so long at the mortgage holder can afford the new mortgage and the ratio is not so high as to be a disincentive to the mortgage holder, it is a secondary factor”. In other words, higher debt is a secondary issue from the Group’s point of view, despite the fact that it clearly contradicts their own objective of reducing the negative debt effects on the economy.

What we need here is an explicit cap on carry over of negative equity under TDM scheme. In other words, cap the amount of negative equity to be carried to new ‘smaller’ dwelling mortgage to not exceed 10-20% of the total new loan, with additional ceiling on combined new mortgage not to exceed 110% of the current value of the new property bought. This will provide both an incentive to engage in trade down for the household and a finite cap on debt limits. It will also reduce future default risk for lenders.

Solution 6: Split Mortgages (SM)

Split mortgages proposal allowing the household to split existent mortgage into ‘affordable’ part to be subject to continued repayment and the ‘unaffordable’ part to be either warehoused until repayment environment (income) improves or until the mortgage holders is forced into other types of arrangements.

This, of course, presents a number of problems. Firstly, it is another extend-and-pretend measure not dealing with debt overhang, as the overall level of debt carried by household remains identical to pre-restructuring. Secondly, it introduces an incentive for the banks to hold mortgagees in constant fear of foreclosure, especially if the property prices rise or if the banks find capital to writedown the foreclosed mortgage. Thirdly, there is no provision for the interest rate relief in the scheme, implying that interest rate will roll up on both sides of the split mortgage. This means, the banks can ‘warehouse the principal’ while forcing households to pay interest on full amount of the mortgage. In other words, effective interest rate payable on mortgages will rise and the present value of the lifetime debt will rise as well.

The Group failed to see any of these possibilities in their report.

What we need here is a New Beginning type of a solution with added caveat that the warehoused part of the loan does not involve roll up of interest for 3 years and that the part of the loan due for continued repayment be structured in such a way as to payments covering at least 50:50 the interest due on overall mortgage and repayment of the principal. In other words, at least every €1 of each €2 of repayment has to be used to reduce principal amount under mortgage. Furthermore, we need protection of borrowers from increases in the interest rates, with warehoused mortgage converted to fixed rate or tracker mortgage at inception.

Overall, therefore, the Keane report utterly and comprehensively fails to deliver any new and/or meaningful measures for dealing with the crisis. The Report is extremely weak on analytical details (using nothing more than publicly available data from the CB of Ireland, without even applying CBofI own model for dynamics of future mortgages distressed available from the PCAR/PLAR exercises). It is a lazy, write-off piece of work by people who appear to have no understanding of the realities of the problems they discuss.

The failure of this report is so comprehensive and represents such a direct affront to the nation burdened with unprecedented debt overhang that the entire report must be binned – publicly and irrevocably – by the Government and a new, independent and broadly authorized commission should be set up to produce real measures aimed at alleviating both problems:

Problem 1 – financial sustainability of currently distressed borrowers, and

Problem 2 – overall debt overhang in the household economy.

Some of the possible measures aiming at dealing with the above problems are already outlined in my comments above. More proposals will follow on this blog in the future. Stay tuned.

29/08/2011: Mortgages Arrears - 2Q 2011 data

The Central Bank of Ireland today published the latest data on mortgage arrears and repossessions for 2Q 2011. Per CBofI data (note, much of the analysis is my own):

• At the end of June 2011 there were 777,321 private residential mortgage accounts held in the Republic of Ireland to a value of €115.089 billion.
  
• 55,763 accounts (7.2% of total) were in arrears for more than 90 days, up from 49,609 accounts (6.3% of total) at the end of 1Q 2011. Accounts in arrears have balances of €10.838 billion as of 2Q 2011, up on €9.599 billion a quarter before. Thus percentage of outstanding amounts that represent mortgages in arrears of 90 days and over is now 9.42% against 1Q 2011 percentage of 8.28%.
• Percentages of loans in arrears more than 90 days have risen from 5.1% in 3Q 2010 to 5.70% in 4Q 2010 to 6.30% in 1Q 2011 and to 7.20% in 2Q 2011. Hence, the increases here are accelerating as of last quarter.
• Percentages of loans volumes in arrears 90 days or more have risen from 6.64% in 3Q 2010 to 7.39% in 4Q 2010 to 8.28% in 1Q 2011 and to 9.42% in 2Q 2011. Again, increases here also accelerated, with 4Q2010 on 3Q2010 rising by 0.75pp, 1Q 2011 on 4Q 2010 rising by 0.89pp and 2Q 2011 on 1Q2011 rising by 1.14pp.
  
• 69,837 residential mortgage accounts were categorised as restructured at the end of 2Q 2011, up from 62,936 restructured accounts at the end of 1Q 2011.
• Of the restructured mortgages total, 39,395 are not in arrears and are "performing as per the restructured arrangement"
  
• 30,442 of restructured mortgages "have arrears of varying categories (arrears both less than and greater than 90 days)"
  
• Therefore, 95,158 accounts are either in arrears greater than 90 days or have been restructured and are not in arrears as at the end of June 2011.
  
• Arrangements whereby at least the interest only portion of the mortgage is being met account for over half of all restructure types (52%).

Now, let me run though the figures in more aggregate detail. Take together all loans that are in arrears 90 days or more, plus repossessions and loans that are restructured, but are not in arrears. Clearly, these loans represent some indication of mortgages either at risk or defaulted. Let's call these such.

• In 2Q 2011 a total number of 95,967 mortgages were either at risk or defaulted, up on 86,963 mortgages in 1Q 2011.
• Between 1Q 2011 and 2Q 2011, the number of mortgages at risk or defaulted has risen by 9,004, which is a faster rate of increase than in the period between 4Q 2010 and 1Q 2011 when the rise was 6,665 mortgages.
• In 2Q 2011, the percentage of all mortgages that were at risk or defaulted was 12.35%, up on 11.11% in 1Q 2011 and 10.21% in 4Q 2010.
• In 2Q 2011 a total volume of mortgages at risk or defaulted was €17.493 billion, up on €15.774 billion of mortgages in 1Q 2011 and on €14.525 billion in 4Q 2010. Also, note that the rate of these mortgages increases is accelerating as well.
• In 2Q 2011, the percentage of all mortgages value that was at risk or defaulted was 15.20%, up on 13.60% in 1Q 2011 and 12.45% in 4Q 2010.

Let me sum the above up: in 2Q 2011, the value of mortgages that were either in arrears 90days and over or were restructured and not in arrears accounted for 15.2% of the entire mortgages pool in Ireland.

Here's the summary:

Note that in the above table, the rates of risk increases are outpacing the rate of households deleveraging almost 15 times to 1.

We sooooo obviously don't have a mortgages crisis on our hands, that it all looks rather sustainable, ...if you stick your head deep into the sand bank... kinda like this...

Economics 02/06/2010: Central bank data analysis

Latest monthly data from the CB is out and here are a couple of updates on series I've been covering before.

First harmonized competitiveness indicators (EU-wide data update coming soon):
Notice some serious progression on competitiveness front is finally starting to take place. This is good. The trend is also good - strong downward trajectory in the series since November 2009. Accelerating again since March. Data lags should not be this significant, so I will be keeping a watch on earnings data from the CSO.

For all the good news, so far we are still in the zone of low competitiveness, down to March 2006 level and well above the period when Ireland Inc was performing at much stronger rates in the 1990s. Remember, these are real indicators, so price levels changes since the 1990s are factored in already.

Private sector credit. First the totals:
We are back to August 2007 levels and the fall rate is slowing down. Year on year change, subsequently, is flat at -9.3% same as in March. Too early to call it a recovery or even a full stabilization, as seasonality suggests that we might see some trend reversal in the short run. Remember, these are declines on already bottom-hitting 2009!

Next: mortgages.
Levels are down to July 2008 and the rate of decline is -1.6% yoy, compared to -1.4% in March. This, however, can be due to a significant declines in mortgages due to write-offs of defaulting loans. In addition, this deterioration rate might be also masking the fact that pretty much anyone in distress who could have done so has already re-negotiated their mortgages in 2009. Thus, only the really tough cases are still sitting out there.

The data on actual new borrowing is below. At the aggregate levels, there is no turn around in household investment, which, of course, is the main leading indicator of recoveries. Also worrisome is the fact that there is no deleveraging of mortgages debt.

Private sector credit outside mortgages is dynamically virtually identical to the total private sector credit figure reported above. Year-on-year changes seem to be reflective of some seasonal effects, with improved rate of contraction in April. General trend is for flatter rates of decline overall since about January. This means little, however, as we need a term structure decomposition of credit in order to tell if this is really a flattening of the downward trajectory or simply restructuring of non-performing lines of credit.

Now, let's take a look at actual changes in rates and volumes in PS credit. First, new loans:
Notice that both for corporates and households, longer term rates are moving up, while shorter term rates are moving down. This likely reflects banks' and interbank credit markets' expectation for a steepening in the interest rate curve, plus some easing in wholesale cost of credit in March. Also note that mortgage rates for new, and especially for fixed rates, mortgages are rising. Hardly a robust support for the housing market.

On corporate investment side, sizable declines for short term maturity loans - operating capital, and reasonably improving environment for larger investment-suitable loans with longer term fixes.

On volumes side, there is a worrisome increase in all shorter term loans - a sign that both companies and households are reliant increasingly on short bank finance for operational and short-term credit. This might mean two things:

1. These increases might reflect increase in supply against a pinned up demand; or
2. These increases might be consistent with increased cash flow pressure on companies (if non-payment and defaults by clients is rising) and households (if arrears are building up on the side of unemployed and underemployed after the households have gone through their savings and redundancies).

We can't tell which one of these forces is operative here. But it does not look to me like operational demand is rising naturally. Remember, so far we only have strong exports performance across the economy. This means you would expect an increase in trade credits (short-term). Most of trade finance in Ireland is actually not done via Irish banks, but through MNCs-own global arrangements. Apart from exports, it is hard to see where organic demand for short term loans would come from.

An even more interesting picture is emerging when we look at existing clients:
Notice how all of the rates changes (except for 5 year plus maturity corporate loans) are trending up? Are the banks ripping off their existent client base to beef up their margins? Well, lets put these changes side by side:
Notice that the above table comparisons are really only loose approximations. But there is a remarkable regularity with which existent loans holders are being loaded with the almost opposite type of changes in rates charged as compared with new clients.