For those of you that have a Lo Doc loan currently, you should be aware that many lenders are beginning to place restrictions on lending under this Lo Doc policy. Not that that means that your current loan will change, but future lending under this policy may become more and more restrictive.
It’s my opinion that Lo Doc loans will revert back to a “rate for risk” basis – ie. significantly higher interest rates for this type of lending, as they were when they first entered the market some years ago. A lack of losses by the big lenders and Mortgage Insurers (buoyed by a booming property sector and financial “good times”) encouraged competition in the market, and most of you will have been able to access Lo Doc loans at rates very close to, if not exactly the same as, standard loans – I believe that this will change significantly in the near future for new loans.
ANZ yesterday announced that at the end of this week they will be restricting lending on Lo Doc loans to 60% of the security value, down from 80%, and Suncorp has imposed lower loan limits and restricted the purpose of lending for Lo Doc loans, and restricted the lending institutions that it will refinance from.
CBA Colonial last week announced that they will no longer offer their Professional Package discounts to Lo Doc loans when lending is over 60% of the security value – And I think this is a trend that’s set to continue.
Other changes that have not been announced, but that I predict will be put in place over the coming 12 months, could be:
- ABN and GST registration (when you’re declaring over $75,000 gross income annually) must be in place for a minimum of 2 years (at present there are some lenders who have some policies outside these parameters, but I believe that this will become the norm.)
- Evidence of Equity in other assets – The Asset and Liability section of applications will be required to show significant interest in other assets, to support the income that the borrower(s) are claiming to earn.
- Restricted loan to value ratios (i.e. 60% down from 80% such as ANZ has put in place already.)
- Restrictions on post codes or areas where Lo Doc lending will be available.
- Increase in rates and fees for this type of loan.
- Removal of rate discounts and “package” offers
- Servicing calculators will get tougher (how much your income allows you to borrow will get tougher.)
There’s no doubt that losses in Australia on this type of lending has been almost insignificant when compared to the US Sub Prime market (Lo Docs in Australia aren’t really even considered “sub prime”), however lessons have been observed and while it will no doubt be extremely inconvenient for many borrowers, we have to consider that it is a prudent move to protect the Australian Property Market and Housing Sector from US style over supply and crash.
There is no doubt some borrowers who have worked the overly permissive Lo Doc policies of the last few years to their advantage, when under normal loan approval terms they may not have qualified for a loan. Unfortunately for those of us who have had a genuine need for Lo Doc loans and have not “stretched” the truth will be the ones inconvenienced the most.
So, if you intend to do any lending on a Lo Doc basis in the near future, I would consider your needs carefully and perhaps “get in” before you find that the goal posts move. Of course any lending should be considered carefully and you should be sure to borrow only within your means to repay, and ensure that the income you declare is an accurate reflection of your actual earnings, which you believe to be consistent, and expect to be ongoing.
Alternately, many of us, (and I include myself in this as I’m self employed too) may just have to get those Tax Returns up to date and accept that the banks look at the Taxable Income figure when determining your borrowing capacity (Yes, the figure that you pay your accountant so much money to get as low as legally possible!), or forego some of the deductions in order to keep your “Taxable Income” higher – The focus may move to prioritising whether it’s more important for you to pay less tax, but borrow less also, or pay slightly higher tax, in order to maximise your borrowing capacity.
So, in essence, I think Lo Docs will always exist in some capacity, however the terms will certainly cease to be as generous as they have been in the past.
Again, I would stress that this doesn’t mean that the terms of any of your current Lo Doc loans will change, but you should expect any future Lo Doc borrowing to be more restricted, and perhaps unsuitable or unattainable for your circumstances.
If you have any questions or concerns about your current or future lending, then please contact me to discuss your individual circumstances – I’m here to help ! 1300 133 193