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OPINION: Proposed mortgage regulations threaten access to homeownership for young Canadians

Earlier this year, the Office of the Superintendent of Financial Institutions (OSFI) announced its launch of public consultations on three new mortgage underwriting regulations intended to go beyond the existing minimum qualifying rate—otherwise known as the mortgage stress test—which would further restrict access to mortgage financing. 

OSFI’s intention behind this proposal is to impose even more restrictive access to mortgage financing in an effort to help mitigate risk for federally-regulated financial institutions against potential consumer default.

OSFI’s proposed changes

 

These proposed regulations, which include loan-to-income and debt service restrictions, plus an even stricter interest rate affordability stress test, have the potential to cause more harm than good in the current economic environment. 

It is clear that homeowner indebtedness is already moving in the right direction, considering that in 2022, unit sales declined and home prices fell, with consumers responding to higher borrowing rates. 

“For OSFI to place new hurdles in the path of young Canadians’ pursuit of home ownership now…would be turning a blind eye to the macro-economic environment, and unnecessarily cruel.”

 

The mortgage stress test has proven to be an effective tool to ensure Canadians can meet their obligations to a lender in the event that interest rates increase, as they have this past year. 

The legislation was introduced in 2018 when borrowing costs were very low, and rates were highly likely to rise. For OSFI to place new hurdles in the path of young Canadians’ pursuit of home ownership now, in an environment where rates are high and likely to fall, would be turning a blind eye to the macro-economic environment and unnecessarily cruel. 

Further, such a move could do more harm than good, forcing families into the unregulated B-lender market. Despite a year of rapidly-rising interest rates, we see that the number of Canadian homeowners who have failed to meet obligations to their financial institutions remains exceptionally low. 

 

“…The stress test hurdle should be lowered, not raised.”

 

Earlier in April, the central bank chose to hold the overnight lending rate for the second consecutive month, signalling that rates are stabilizing and could start to go down later this year or in early 2024. At a time when we do not expect the cost of borrowing to rise dramatically in the short or medium term, the stress test hurdle should be lowered, not raised. 

There is minimal evidence that supports the need for additional regulations when it comes to the lending process. Given major banks already have tight restrictions which are designed to protect Canadian consumers from default or foreclosure, putting further measures in place will not make a material difference to Canada’s already low default rate. 

 

“Implementing stricter regulations poses the risk of pushing more homebuyers into the unregulated B-lender market.”

 

It will, however, affect young Canadians, especially those who are attempting to buy their first home. Asking our largest banks to serve fewer people in this demographic seems counterintuitive at this moment. 

Access to financing is critically important, and as much as possible, loans should be provided by regulated financial institutions. Implementing stricter regulations poses the risk of pushing more homebuyers into the unregulated B-lender market. 

The real estate sector is one of Canada’s largest industries. Already reeling from the record pace of interest rate hikes, an aggressive push to restrict Canadians’ ability to secure a mortgage could trigger a broader depression of the housing market and force the economy into a recession. 

 

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