Risky Reverse Mortgages

The Consumer Financial Protection Bureau released a report, Snapshot of Reverse Mortgage Complaints:  December 2011-December 2014. By way of background,

Reverse mortgages differ from other types of home loans in a few important ways. First, unlike traditional “forward” mortgages, reverse mortgages do not require borrower(s) to make monthly mortgage payments (though they must continue paying property taxes and homeowners’ insurance). Prospective reverse mortgage borrowers are required to undergo mandatory housing counseling before they sign for the loan. The loan proceeds are generally provided to the borrowers as lump-sum payouts, annuity-like monthly payments, or as lines of credit. The interest and fees on the mortgage are added to the loan balance each month. The total loan balance becomes due upon the death of the borrower(s), the sale of the home, or if the borrower(s) permanently move from the home. In addition, a payment deferral period may be available to some non-borrowing spouses following the borrowing spouse’s death. (3, footnotes omitted)

The CFPB concludes that

borrowers and their non-borrowing spouses who obtained reverse mortgages prior to August 4, 2014 may likely encounter difficulties in upcoming years similar to those described in this Snapshot, i.e., non-borrowing spouses seeking to retain ownership of their homes after the borrowing spouse dies. As a result, many of these consumers may need notification of and assistance in averting impending possible displacement should the non-borrowing spouse outlive his or her borrowing spouse.

For millions of older Americans, especially those without sufficient retirement reserves, tapping into accrued home equity could help them achieve economic security in later life. As the likelihood increases that older Americans will use their home equity to supplement their retirement income, it is essential that the terms, conditions and servicing of reverse mortgages be fair and transparent so that consumers can make informed decisions regarding their options. (16)
Reverse mortgages have a number of characteristics that would make them ripe for abuse: borrowers are elderly; borrowers have a hard time refinancing them; borrowers can negatively affect their spouses by entering into to them. Seems like a no brainer for the CFPB to pay close attention to this useful but risky product.

Home Equity Insurance: Only Good in Theory?

Smith and Harper have posted Home Equity Insurance & The Demise of Home Value Insurance Corporation to SSRN.  The abstract reads,

This study uses the demise of the Home Value Insurance Company (HVIC) to explore whether the concept of home equity insurance is implementable. Shiller, R. and Weiss, A. (1999) and Goetzmann, W., Caplin, A., Hangen, E., Nalebuff, B., Prentce, E., Rodkin, J., Spiegel, M. and Skinner, T. (2003) have provided a platform to evaluate this concept by questioning whether a product that allows homeowners to transfer the risk associated with a decline in housing prices should be structured as insurance. This study explores the cost associated, in the U.S. Real Estate Market, with this risk transfer process in the pre- and post-mortgage crisis periods by simulating the cost of insurance using the theoretical pricing of ATM (at the money) put options based upon the Black Scholes Option Pricing Model from 1989 to 2013. As the U.S. Housing Market transitioned from the pre-crisis to the post-crisis periods the hypothetical breakeven cost of insurance increased from 0.60% to 20.85% of the starting value of the index. The demise of HVIC seems to be a cautionary tale: Given the recent changes in the underlying dynamics of the U.S. Real Estate Market it does not seem prudent (for insurers) to use insurance contracts to transfer the risk associated with a decline in the value of U.S. Residential Equity Wealth.

This is all a bit technical, but basically it is an investigation of a clever idea that did not seem to pan out. Robert Shiller and others proposed that home owners could insure against a decrease in the value of their home.  But a company based on that proposal failed in its first year of operation. The article finds that the cost of such insurance would be unsustainable. I am not sure that this article definitively demonstrates that this concept is impossible to implement, but it certainly raises a lot of questions that would need to be answered if someone were to want to give it another go.

Gimme More Mortgage Data!

People are always talking about the value of data about web browsing habits. They don’t talk nearly enough about the value of data about mortgage shopping habits. Regulators and researchers do not know nearly enough about how borrowers and lenders interact in the mortgage business — and the stakes are high, given that a home is often the biggest investment that a household ever makes. The Consumer Financial Protection Bureau is seeking to make some modest improvements to the federal government’s existing data collection pursuant to the Home Mortgage Disclosure Act (HMDA) through a proposed rule.

Under this proposed rule,

financial institutions generally would be required to report all closed-end loans, open-end lines of credit, and reverse mortgages secured by dwellings. Unsecured home improvement loans would no longer be reported. Thus, financial institutions would no longer be required to ascertain an applicant’s intended purpose for a dwelling-secured loan to determine if the loan is required to be reported under Regulation C, though they would still itemize dwelling-secured loans by different purpose when reporting. Certain types of loans would continue to be excluded from Regulation C requirements, including loans on unimproved land and temporary financing. Reverse mortgages and open-end lines of credit would be identified as such to allow for differentiation from other loan types. Further, many of the data points would be modified to take account of the characteristics of, and to clarify reporting requirements for,different types of loans. The Bureau believes these proposals will yield more consistent and useful data and better align Regulation C with the current housing finance market. (79 F.R. 51733)
This seems like a reasonable proposal. It increases the amount of information that is to be collected about important consumer products such as reverse mortgages.  At the same time, it releases lenders from having to determine borrowers’ intentions about how they will use their loan proceeds, something that can be hard to do and to document well.
There is more to the proposed rule than this, so take a look at it and consider commenting on it. Comments are due by October 29, 2014.

Risky Cash-Out Refis

Anil Kumar of the Dallas Fed has posted Do Restrictions on Home Equity Extraction Contribute to Lower Mortgage Defaults? Evidence from a Policy Discontinuity at the Texas’ Border to SSRN.  The abstract reads

Given that excessive borrowing helped precipitate the housing crisis, a key component of a policy agenda to prevent future meltdowns is effective regulation to curb unaffordable mortgage debt. Texas is the only US state that limits home equity borrowing to 80 percent of home value. Anecdotal reports have long suggested that home equity restrictions shielded Texas homeowners from the worst of the subprime mortgage crisis. But there is, as yet, no formal empirical investigation of these restrictions’ role in curbing mortgage default. This paper is the first to empirically estimate the impact of Texas home equity restrictions on mortgage default using individual and loan level data from three different sources. The paper exploits the policy discontinuity around Texas’ interstate borders induced by the home equity restrictions to identify the causal effect of home equity extraction on mortgage default in a border discontinuity design framework. The paper finds that limits on home equity borrowing in Texas lowered the likelihood of mortgage default by about 2 percentage points with a significantly larger impact on mortgage borrowers in the bottom quartile of the credit score distribution. Estimated default hazards for mortgages within 50 to 100 miles of the Texas’ border decline sharply as one crosses into Texas. Overall, the paper finds evidence that Texas’ home equity restrictions exert a robust negative impact on mortgage default.

This is a really important paper asking a really important question.  If its findings are confirmed, it brings us back to that age-old question of paternalism in consumer financial protection: should we limit a consumer’s choice if that choice is consistently shown to have harmful effects?  I am not sure where I come down in this particular case, but I wonder if some version of Quercia et al.‘s benefit ratio could help measure the costs and benefits of such a rule. The benefit ratio compares “the percent reduction in the number of defaults to the percent reduction in the number of borrowers who would have access to [a certain type of] mortgages.” (20) I am not sure whether access to cash out refi mortgages is of the same import as purchase mortgages or even plain old refis, but the concept of the benefit ratio might still make sense in this context.

Tax Incentives for Sustainable Homeownership

Harris, Steuerle and Eng have published New Perspectives on Homeownership Tax Incentives in Tax Notes. The report presents

three tax reforms designed to promote homeownership that are fundamentally different from earlier proposals. Many of those earlier proposals would convert existing deductions into credits but would mistakenly, in our view, perpetuate flaws in the current system — namely, the failure to adequately promote the accumulation of home equity. The reforms examined here instead share the common characteristic of subsidizing homeownership through a channel other than the deductibility of mortgage interest, which is the largest tax expenditure for housing. These reforms include a first-time home buyer tax credit, a refundable tax credit for property taxes paid, and an annual flat amount tax credit for homeowners — all largely paid for by restricting the home mortgage interest deduction to a rate of 15 percent. Although far from perfect, these reforms would provide a better and more efficient allocation of housing subsidies and ultimately provide a somewhat larger incentive for wealth accumulation than current policy does. Our simulations show that relative to existing incentives, each policy would raise home prices and make the tax code more progressive. (1315)

This report has some drawbacks, such as overstating the case that empirical studies reinforce “the notion that homeownership improves American communities.” (1315) In fact, the empirical literature is decidedly ambiguous about the spillover and wealth accumulation effects of homeownership, particularly when the last few years are taken into account (I discuss these ambiguities here).

But the report also presents some creative ways to change the incentives that are found in the tax code. They argue, for instance, that it is better to incentivize the accumulation of home equity than unfettered mortgage borrowing. And they make proposals that would do just that.  Worth a read.