Industry wants minister's ear over CCCFA

For all the loan sharks out there charging the 30 % compounding interest rates these changes are great but for mainstream mortgage lending not so much and I think these changes will hinder a lot of responsible quality borrowers from borrowing the basic mortgage.

Banks have always been extremely cautious lenders anyway and the proof is in the extremely low mortgage default stats, it’s just not good responsible business having customers default on their loans.

Prior to CCCFA banks In NZ as responsible lenders already had stringent mortgage lending assessment criteria in place when assessing customers as potential borrowers, LVR/s (loan to value ratios) UMI’s (uncommitted monthly income tests) employment stability, account conduct, spending habits, fixed expenses, expense allowances for numbers of dependents, for larger family’s credit rating, high test rates, income shading, etc etc etc.
Australian banks have been applying this type of criteria for decades and in my opinion have been some of the most stability sound banks in the world, Australasian banks came through the GFC virtually unscathed with low mortgage default rates, all because of this, I think.
After analyzing customers spending habits for 15 years plus now, I see some common themes.

When we don’t have a mortgage to fund our spending habits are not the same as when we are funding a mortgage.
We generally have a lot of surplus income to spend or save as we see fit (discretionary spending) so when a chunk of the UMI (uncommitted monthly income) is now put aside to fund a mortgage our spending habits change.
The mortgage always gets paid first (similar to paying rent), surplus income spending changes too, we tend to purchase retail items more associated with the house (kiwis are great DIY experts) and we have other fixed expenses like rates and insurances, all this before we decide to go out for dinner, and don’t even get me started when kids come along.
So getting back to “’discretionary spending”’.

Customer spending habits are also seasonal, that means we spend more and less at certain times of the year, for example Xmas time or consumer spending goes nuts, after the holidays we see a drop off, there are also differences in winter /summer spending as well, power being one of them,

CCCFA looks more closely at “’discretionary spending”’ and can actually include some of that discretionary spending as ä fix expense”.

Examples of this are
Putting away $ 200 per week savings could be classed as a fixed expense. (which seems a little counterintuitive as showing you have the ability to save shows you can fund a mortgage) .
Donations that are paid monthly. Fixed expense
Eating Uba eats every week. Fixed expense
Afterpay /Laybuy credit facilities that have a nil balance and can be closed but were used previously over a 3-to-6-month period, the average historical payments now become a future expense weather you use the facility or not.
You start to get the point that under the New CCCFA rule changes we seem to be analyzing customers discretionary spending at a very small snap shop in time which may not reflect their true ability to become a responsible borrower.
Maybe once again we have a governing institute dictating policy without understanding the actual on the ground workings of banking and responsible lending and borrowing.

Yes total garbage law. I had an application where client is tithing. Under the stress interest rate and standard expense benchmarks they can't afford same rate of tithing.

Or any tithing at all in fact even though in the real world at applicable interest rate they actually can.

And of course in discussions they agreed would possibly have to cut down in future because the mortgage has to get paid.
Real world discussion.

The bank asked for written confirmation they will cease all tithing. ???

I understand why the bank feels obliged to do this because of the CCFA, they can't knowingly allow a client to go into hardship as defined by the model and the law.

The law of unintended consequences for sure