The Approach of the Banking Regulator



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Surveillance of Mortgage Credit The Approach of the Banking Regulator Workshop on Real Estate t Prices and Financial Stability 25th April 2014 Central Bank of Chile Eric Parrado Chairman Superintendency of Banks and Financial Institutions of Chile

Agenda A basic reminder from 1863 Mortgage Credit Market: Overview Features of Mortgage Credit in Chile: Structure and Risk Profile Regulation: Ongoing Improvements 2

A basic advice from Hugh McCulloch (letter to banks, 1863) Principles: Let no loans be made that are not secured beyond a reasonable contingency Do nothing to foster and encourage speculation Give credit facilities only to legitimate and prudent transactions Distribute your loans rather than concentrate them in a few hands I believe that these basic principles hold true today These words are certainly a good reminder to strengthen credit risk provision s regulation 3

Mortgage Credit Market: Overview

Past Lending Credit Booms? IMF Lending Booms definition, y = Annual Changes of (Credit/ GDP) Rules: i) [ y > 10% and y-trend(y) 1,5 σ(y) ] or ii) Annual Variation (y) > 20% Application on Chilean Banking System (1978-2011): Hypothetical Episodes The last hypothetical mortgage credit boom was in 2009. However, this can be explained by the reduction of GDP rather than increase of credit given the global crisis Source: Acosta, F., Poblete, D.; 2013, Identificación de Booms Crediticios y Riesgos en la Cartera Hipotecaria Residencial, Nota Técnica. SBIF 5

According to Chilean development mortgage loans should grow even more 120 Ratio loan mortgages over logarithmic GDP per capita, 2012 Netherlands 100 Denmark Loan mortgages ov ver GDP 80 60 40 20 Bulgaria Romania Turkey Chile Portugal Malta Cyprus Spain Croatia Estonia Greece France Russia Slovenia Czech Republic Italy UK Belgium Ireland USA Finland Germany Austria Sweden Norway Luxembourg 0 8,7 9,2 9,7 10,2 10,7 11,2 11,7 6 Source: SBIF and European Mortgage Association Logarithmic GDP per capita

Mortgage loans have grown steadily due to better funding conditions, financial market deepening and macroeconomic stability 14 12 10 8 6 4 2 0 22 Annual growth rate of GDP and loans 2008 2010 2012 feb 13 apr 13 jun 13 aug 13 oct 13 dec 13 feb 14 Total loans mortages loans GDP/IMACEC Bonds interest t rates (UF) 4,0 10 years 3,5 20 years 3,0 2,5 2,0 1,5 1,0 0,5 00 0,0 2008 2009 2010 2011 2012 2013 2014 Source: SBIF and Banco Central de Chile 7

Since 2003 banks have intensively used their own resources to finance housing credit Types of finance for housing Source: SBIF. 8

Mortgage credit growth is associated to economic conditions instead of lower rates and/or longer term Mortgage interest rates (UF) and term 6,0 350 int terest rate s 5,5 50 5,0 4,5 4,0 3,5 300 250 200 150 Interest rate 100 Term 50 3,0 0 2007 2008 2009 2010 2011 2012 2013 2014 Source: SBIF 9 Months

Share of Mortgage Loans 125% 100% 75% 50% 25% 0% Market Share 13% 10% 87% 90% 2000 2013 Banking Non-Banking Source: SBIF and Banco Central de Chile 10

Main Features of Mortgage Loans in Chile: Structure and Risk Profile

The banking sector has been cautious in granting 2 or more loans to one debtor Stock distribution of number of mortgage loans by debtor (% of total amount) Period \ N of personal credit 1 2 >=3 Total 2009 78,8 17,6 3,6 100 2010 81,1 15,2 3,8 100 2011 80,9 15,0 4,1 100 2012 79,8 15,6 4,6 100 2013 77,8 16,8 5,4 100 2014 77,0 17,1 5,9 100 Flow distribution of number of mortgage loans by debtor (% of total amount) Period \ N of personal credit 1 2 >=3 2009 97,97% 1,91% 0,12% 2010 97,44% 2,13% 0,43% 2011 97,80% 1,58% 0,62% 2012 97,35% 1,46% 1,19% 2013 97,86% 1,63% 0,51% 2014 97,41% 2,01% 0,57% 12 Source: SBIF

LTV and Debt to Income Ratio The new loan LTV evolution, reported by banks during 2013, is largely explained by medium size banking cluster LTV by banking cluster Debt to Income (DTI) by banking cluster Source: Reported ed by the banks Source: Reported by the banks The DTI Ratio (reported by banks) proved to be stable throughout 2013, converging to prudential levels 13

Regulation: Ongoing Improvements

LTV as a Granting Standard and Prudential Tool (1/2) Some international regulators agree that LTV s is one of the main risk factors: USA (FED, 2008, Risk-Based Capital Guidelines; Capital Adequacy Guidelines: Standardized Framework; Proposed Rule and Notice ) Australia (APRA, 2012, Prudential Standard APS 112 ) Supported by empirical evidence: IMF, 2011, Housing Finance and Financial Stability-Back to Basics?, Chapter 3, Global Financial Stability Report, April 2011. Haldane, A., Hall, S., Pezzini, S., 2007, A new approach to assessing risk to financial stability, paper N 2, Financial Stability Report, Bank of England. Whitley, J., Windram, R., Prudence, C., 2004, An empirical model of household arrears, working paper no. 214, Bank of England. 15

LTV as a Granting Standard and Prudential Tool (2/2) Chilean s banking residential mortgage g portfolio. A preliminary SBIF estimation for the Long-Run probability of default (PD): Sources: SBIF 16

Regulation Ongoing Improvements: Pillars (1/2) Reinforce the banking credit risk provision regulation: Expected loss approach in line with Basel II: improvements to the current banking regulation (2011) Additional prudential standards to compute the mitigation effect in the guarantees, both real and financial collaterals Our ultimate goal is to strengthen the Chilean financial stability and this effort has no intention to control an hypothetical real state price boom. This is a regular process for the SBIF with a focus on improvement of credit risk provision regulation 17

Regulation Ongoing Improvements: Pillars (2/2) New Minimum Standards for Internal Models provisioning: An stricter regulation for Internal Models defining minimum standards d (Public Consultation ti has been closed on Feb to Apr 2014). It is expected thatt some banks will migrate to the Standard d Model, at least in the short-medium run. This may create a moderate increase in provisions. 18

Standard Models to Residential Mortgage Loans The Standard Models stood in public consultation for Banks (Dec-03 to Mar-2014). PD and LGD parameters depending on prospective risk factors of default, like: delinquency, LTV and original credit value. LTV is a fundamental risk factor within the banking s Standard Models for lining up the loan granting process with prudential standards and stimulate the mortgage guarantees active management. 19

Regulation Ongoing Improvements: Objectives The ongoing improvements lines-up the local regulation to international standards. The new regulation for the Standard Models has the following objectives: Credit Risk Provisions based in the Expected Loss Distribution Credit risk management procedures to differentiate borrower's depend on its inherent risk or its residual risk (ex: by guarantees) Credit risk's provisions integrated with the end-to-end loan granting process Use of Standard Model when Internal Models clearly posses deficiencies 20

Final thought Let no loans be made that are not secured beyond a reasonable contingency LTV helps to support that as a granting standard and prudential tool 21

Surveillance of Mortgage Credit The Approach of the Banking Regulator Workshop on Real Estate t Prices and Financial Stability 25th April 2014 Central Bank of Chile Eric Parrado Chairman Superintendency of Banks and Financial Institutions of Chile