2011年-FSB全球金融稳定委员会_Principles_for_Sound_Residential_Mortgage_Underwriting_Principles_12页_205kb

FSB Principles for Sound Residential Mortgage Underwriting Practices Summary

I. Introduction

The Financial Stability Board (FSB) published a consultation paper in October 2011 outlining principles for sound residential mortgage underwriting practices. These principles aim to establish a framework for jurisdictions to set minimum acceptable underwriting standards, ensuring financial stability and protecting borrowers and investors. The FSB acknowledges that underwriting practices vary across countries due to differences in real estate markets, cultural factors, and socioeconomic policies, and therefore, the principles should be implemented according to national circumstances.

The report emphasizes the importance of sound underwriting practices at the time of loan origination, as weak practices can have global repercussions through securitization. It also notes that while the principles apply generally to individual loans secured by residential property, they may not be suitable for all niche financial products. The FSB recommends that jurisdictions apply all relevant principles and ensure that lenders adopt robust and effective affordability assessments.

II. Core Principles

1. Effective Verification of Income and Other Financial Information

• Borrowers' income and financial information must be verified and documented.
• Lenders should collect sufficient income history and consider variability in income, especially for self-employed individuals.
• Documentation of the verification process must be maintained for a number of years and be available to supervisors.
• Incentives should align with accurate financial representation, and lenders should have recourse in case of borrower misinformation.

2. Reasonable Debt Service Coverage

• Lenders must assess the borrower's ability to service and repay the loan without undue hardship.
• Assessments should include income, assets, living expenses, and other financial obligations.
• Repayment capacity should be based on realistic economic limits, not on temporary income increases.
• Lenders should consider future negative outcomes, such as reduced income or increased interest rates, and use the highest expected payments in calculations.
• Borrowers must be provided with clear, comprehensive information about loan terms, costs, and risks.

3. Appropriate Loan-to-Value (LTV) Ratios

• LTV ratios should reflect the borrower's initial equity and be based on a prudent assessment of the property's value.
• Lenders should ensure that down payments are drawn from the borrower's own resources.
• LTV ratios should not be used as a substitute for assessing repayment capacity.
• Jurisdictions may impose or incentivize LTV limits based on national circumstances.
• Lenders should avoid relaxing LTV ratios during property market booms.

4. Effective Collateral Management

• Collateral management includes property appraisal, legal enforceability, and risk mitigation.
• Lenders must ensure that the collateral is properly insured and that the property's value is accurately assessed.
• Appraisal methods should be realistic and substantiated, and not reflect expected future appreciation.
• Appraisers should be independent and meet professional standards.
• Onsite inspections may be required, but exemptions can be made if the risk is lower than standard.

5. Prudent Use of Mortgage Insurance

• Mortgage insurance should not replace sound underwriting practices.
• Lenders must conduct independent assessments of repayment capacity and property value.
• Mortgage insurers should also follow prudent underwriting standards.
• The use of mortgage insurance transfers credit risk to insurers, particularly for high LTV loans.
• Jurisdictions should ensure that mortgage insurance is an effective risk transfer mechanism and that captive insurers are appropriately regulated.

III. Implementation Framework

• The FSB Principles should be supported by an effective implementation framework that allows for coordinated application of underwriting standards.
• Jurisdictions should ensure that the framework includes mechanisms to monitor and supervise underwriting practices, including the ability to collect and analyze data.
• Lenders should apply more conservative underwriting criteria in high-risk situations, such as asset price bubbles or investment properties.
• Absolute minimum standards may be imposed in certain cases, such as LTV ratios above 100% or reliance on stated income without verification.
• Compensatory tightening in one dimension can offset easing in another, such as lower LTV ratios for loans with prolonged foreclosure processes.
• Supervisors should identify and monitor high-risk loan groups and may demand tighter standards in case of material weaknesses.

IV. Supervisory Tools and Powers

• Supervisors should have the authority to monitor and supervise mortgage underwriting practices.
• They should be able to collect data and require lenders to track portfolios and originations according to underwriting standards.
• Periodic reviews of the underwriting framework should be conducted to respond to changing trends and avoid amplifying cycles.
• Supervisors should disclose assessments of underwriting practices, including entities not subject to prudential regulation, when significant changes are detected.
• Oversight should be tailored to the importance and risk profile of different types of lenders.