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NR 2008-58
Contact: Robert M. Garsson
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Comptroller Dugan Tells Lenders that Unprecedented Home Equity Loan Losses Show Need for Higher Reserves and Return to Stronger Underwriting Practices

WASHINGTON — Comptroller of the Currency John C. Dugan said today that accelerating losses in the home equity business show the need to build reserves and to return to the stronger underwriting standards of past years.

Home equity loans and lines of credit grew dramatically in recent years, more than doubling, to $1.1 trillion, since 2002. In part, that's because of the rapid appreciation in house prices, the tax deductibility feature of home equity loans, and low interest rates.

"But another contributing factor was perhaps not so obvious: liberalized underwriting standards," Mr. Dugan said, in a speech to the Financial Services Roundtable's Housing Policy Council. "These relaxed standards helped more people to qualify for loans, and more people to qualify for significantly larger loans."

These relaxed standards included limited verification of a borrower's assets, employment, or income; higher debt to equity ratios; and the use of home equity loans as "piggyback" loans that helped borrowers qualify for first mortgages with low down payments and without mortgage insurance, resulting in ever-higher cumulative loan-to-value ratios.

Consequently, once house prices began to decline in 2007, home equity lenders began to experience unprecedented losses. While losses have traditionally run at about 20 basis points, or two tenths of a percent of loans, they shot up to nearly 1 percent in the fourth quarter of 2007 and to 1.73 percent in the first three months of 2008.

Looked at in dollar terms, losses on all home equity loans, including HELOCs and junior home equity liens, rose from $273 million in the first quarter of 2007 to almost $2.4 billion in the first three months of 2008 - a nine-fold increase. And the largest home equity lenders are now saying that they expect losses to continue to escalate in 2008 and beyond, Mr. Dugan said.

The Comptroller said these loss numbers need to be viewed in perspective. Though accelerating quickly, they are still much lower than the loss rates for other types of retail credit, such as credit card loans.

"It's true that home equity credit was priced with lower margins than these other types of credit, and it's true that the product has become a significant on-balance sheet asset for a number of our largest banks," he said. "Nevertheless, the higher level of losses and projected losses - even under stress scenarios - are what we at the OCC would describe generally as an earnings issue, not a capital issue. That is, while these elevated losses, depending on their magnitude, could have a significant effect on earnings over time, with few exceptions they are not in and of themselves likely to be large enough to impair capital."

For the near term, Mr. Dugan said, the OCC expects national banks to continue to build reserves.

"I can't stress enough how crucial reserves will be in helping the industry manage its way through this situation," he said. "At some banks, the portion of reserves attributable to home equity loans just barely covers 2007 chargeoffs. With losses accelerating, those reserves are simply not going to be adequate, and that's why our examiners are encouraging more robust portfolio analysis and loss reserve levels."

In assessing loan loss reserves for home equity loans, he said, banks need to recognize that they are in uncharted territory. "New product structures, relaxed underwriting, declining home prices, potential changes in consumer behavior - all of these factors make it difficult to predict future performance of home equity loans," he said.

Circumstances have changed fundamentally, and historical trends have little relevance in estimating credit losses. As a result, qualitative factors such as environmental analysis and changing consumer behavior clearly should be factored into the reserve calculation. Likewise, lenders should take into account the very real possibilities that unemployment or interest rates will increase from their quite low current levels.

Mr. Dugan said that while lenders have begun to take steps to improve underwriting on new home equity loans, more needs to be done.

"Even as banks begin to work their way through the current problems, we need to ask some hard questions about home equity product structure and underwriting criteria," he said. "In particular, we need to revisit the problems that landed lenders where we are today - particularly some of the "shortcuts" established in reaction to aggressive competition."

Among the practices that warrant close scrutiny are:

  • The use of home equity lines to finance down payments.
  • The appropriate use of collateral valuation tools, such as asset valuation models, which the Comptroller said must be closely managed, periodically validated, and supported with sound business rules.
  • Income documentation. Although the overt use of stated income has been largely abandoned, some lenders now ask for income information and authorization to verify it, but do not follow through. "This practice is only marginally better than expressly relying on stated income, since it is questionable whether the borrower's belief that income will actually be verified will really induce a higher level of honesty in providing information," Mr. Dugan said. "We need to think carefully about whether anything short of actual verification of income is acceptable from a safety and soundness perspective for most borrowers."
  • The extended interest-only structure that home equity credit lines have in the early years of the loan term. Payment patterns can only be a proxy for a borrower's capacity to handle a given debt level if he or she is asked to make payments that are meaningful. "Interest-only payments reflect a borrower's capacity to pay interest on a debt, but not the debt itself," Mr. Dugan said. "Further, this lack of structured payment discipline encourages borrowers to assume greater levels of debt, often to the limit of their ability to make minimum monthly payments. In contrast, higher payments that reduce principal address both these concerns."

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