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Posts Tagged ‘FSA’

Mortgage Broker Q&A – What is a higher lending charge?

Friday, February 19th, 2010

Question; What is a higher lending charge and how does it affect me as a borrower?

A higher lending charge is a fee lenders may apply to borrowing over a certain percentage of a property value.
For example a lender may choose to impose an extra charge on borrowers who borrow more than 80% of a property’s value, or perhaps more than 85% or 90% etc. Often the fee will be a percentage of the amount over this limit which you borrow.

A typical example would be a 5% charge on all lending over 80% of the property value. In this case if your home was worth £100,000 and you borrowed £90,000 you would pay 5% of the £10,000 over and above the 80% limit which would give a higher lending charge of £500.

Obviously it’s important to check how the fee is calculated as it could be based on the whole loan which would normally mean the fee could be considerably higher than the example above.

Another important consideration is what the lender does with the fee. Some lenders just charge a fee to increase their profit margin on these loans to cover potential losses if they have to sell properties undervalue at auction. However if the lender uses the fee to buy a Mortgage Indemnity Guarantee which would insure the lender against such losses, it’s important to be aware that in the event of you handing back the keys and the property being sold for less than the outstanding mortgage balance the insurer would then have the right to pursue you for their losses under the right of “subrogation”.

The FSA forced lenders to stop referring to these charges as Mortgage Indemnity Guarantee fee’s because it was worried that this gave the impression that such insurance policies would benefit the borrower as well as the lender, so be aware that if you pay this fee or have done in the past it will not protect you from the lender or insurer pursuing you for any outstanding balances should the property have to be sold at undervalue after repossession.

High time APR or Annual Percentage Rate interest calculations were removed from mortgage products

Thursday, November 19th, 2009

One of the most bewildering and confusing items on any mortgage illustration from my point of view must be the Annual Percentage Rate or APR listed on a product. APR was developed to give a comparative measure between various loans to show the overall cost of the borrowing on an annual basis taking into account a much broader range of fees and charges than the loan interest on its own.

Now that’s a good thing where the calculation makes sense, but on mortgage products in its current guise it makes no sense at all.

A simple look at the best buy tables on our website will show you that a product far cheaper during its initial interest rate term may have a much higher APR than a product with a considerably higher rate of interest. The issue is that APR is calculated over the lifetime of the loan and so will also consider the reversion rate of the product after its initial term.

There are several reasons why this is misleading;

  1. 1. Reversion rates are generally variable and not linked directly to bank base rate. In two years time a lender with a previously un-competitive reversion rate may well be leading the market and vice versa – hence it is not a factor that should play a major part in the decision making process.
  2. 2. You would generally regularly remortgage during the early years of your mortgage repayment to ensure a competitive rate of interest so including the reversion rate after the initial mortgage term distorts the picture.
  3. 3. Clever design can skew the figure. Lifetime trackers appear very competitive because they have no reversion rate, and refunding upfront fee’s affects the calculation but could cost a pretty penny if the loan never goes ahead.

APR is a system that was never really designed for mortgage contracts but has become a legal obligation when advertising them due to the confused dual regulatory system between the FSA and the Office of Fair Trading, it makes some sense on unsecured loans and very little in the mortgage market.

It is high time this dual regulation was removed and APR calculations either scrapped on mortgage contracts or replaced with something far more specific to the complex nature a mortgage product.

The end of self cert mortgages?

Monday, October 19th, 2009

I wrote an article some time ago about the FSA’s proposed changes to end self certification and fast track mortgage lending in which I made a big point about how this could leave a lot of people struggling to refinance and cause trouble for the recovery of the housing market.

The FSA last week confirmed that action would be taken, and the press have been making similar observations to my own today about the impact that this could have on our recovery and those borrowers with an existing loan of this type.

But over the weekend I had a realisation and did a u turn on the subject. In reality there are few if any legitimate borrowers who cannot “prove” their income. The point being that “proof” and it’s interpretation is the key point here, because almost all people can show evidence that the income they declare is broadly accurate however they may not be able to prove income in the manner that a normal full status mortgage would require.

For example if you have a business from which you could take far more income than you currently do without running the business into decline that is your prerogative, and if you can show that you can still afford a large mortgage then fine, but you can also evidence that your business has the potential for you to take further income. It may not be satisfactory at your local building society now, but lenders with good product development teams will soon see how to create a new type of product to cater for this market once their appetite comes back.

So if the FSA get this legislation right and don’t dictate or define what proof consists of then there will still be the opportunity for lenders to market products for those with non standard income, priced above full status products as before but simply requiring some evidence to back up that the income declared isn’t total fabrication. This is what’s needed in the market and the FSA just need to be careful not to try and make this legislation so watertight that it chokes the housing market to death.

Think carefully before securing other debts against your home. Your home may be repossessed if you do not keep up repayments on your mortgage or any other debt secured on it. We do not usually charge a fee for mortgage advice although you do have the option to pay up to 1.5% of the loan amount. Some buy to let and commercial loans are not regulated by the Financial Services Authority.

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