November 27, 2017
On January 1, 2018, our regulators will implement a sixth round of mortgage rule changes as part of their ongoing attempts to slow our economy’s rate of mortgage debt accumulation. While I agree in principle with their instincts and with their earlier changes, I take issue with their most recent methodology. For example, in a recent post I criticized the decision to use an average of the posted rates at the Big Six Banks to set the stress-test rate, because posted rates aren’t actually used for lending and because relying on rates from a sub-group of lenders effectively means that the regulator is delegating de facto control over consumer access to mainstream borrowing. I also questioned whether 4.99% was the right rate to use and called on our […]