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Regulator is wrong to blame non-banks

Posted on November 2nd 2009


The recent Mortgage Market Review singles out non-banks or high-risk lenders, as they are referred to, as the source of the expansion of loans with multiple high-risk characteristics.

Exact has analysed and re-underwritten over £4bn of non-conforming loans over the last 18 months and I agree with the Financial Services Authority on risk layering being a systemic cause of arrears.

I also agree that the next generation of non-bank lenders will require sustainable business, funding and capital models.

But I disagree that non-banks drove the growth in this type of lending. Risk layering was prevalent across the industry and since the early 2000s deposit-taking lenders have dominated this sector.

Exhibit 3.2 on page 33 of the FSA’s paper takes a simplistic view of the non-conforming market, looking at the number of lenders rather than the volume originated.

This view shows that of the 20 lenders in the sector with arrears rates of over 5%, one was a building society/bank, seven were subsidiaries of banks or societies and 13 were non-bank lenders.

But looked at on a volume basis it can be seen that most of these types of products were originated by deposit-taking firms.

At the peak of the market only a handful of non-bank lenders even made it into the top 30 lenders.

With the economy desperately needing liquidity, I hope that the FSA can give assurances that a witch-hunt will not prevail.


Intermediary Mortgage Lenders Association Association of Mortgage Internmediaries Financial Services Authority