Indigenous Home Ownership Program Policy September 2016 IHOP Policy - September 2016 i Table of Contents 1 Introduction...................................................................................................................................... 1 2 Strategic Objectives and Purpose ................................................................................................... 1 3 This Document and Related Documents ........................................................................................ 1 3.1 IBA Policies – Corporate Plan ............................................................................................ 2 3.2 Chief Executive Instructions (CEI) ...................................................................................... 2 3.3 Delegations ......................................................................................................................... 2 4 Eligibility Requirements ................................................................................................................... 2 5 Funding and Prioritisation ............................................................................................................... 3 6 Housing Loan Products ................................................................................................................... 3 7 6.1 First Home Buyers .............................................................................................................. 3 6.2 Existing Home Owners ....................................................................................................... 3 6.3 Previous Home Owners ...................................................................................................... 4 6.4 Loans for Customers Living In Remote Communities ........................................................ 4 6.5 Loans to New South Wales Aboriginal Housing Office (AHO) Tenants ............................. 5 IBA Housing Loan Eligibility and Assessment ................................................................................ 5 7.1 IBA Loan Amounts .............................................................................................................. 5 7.2 Assets ................................................................................................................................. 6 7.3 Savings ............................................................................................................................... 6 7.4 Loan Affordability ................................................................................................................ 6 7.5 Housing Loan Terms and Conditions ................................................................................. 6 8 Loan Management and Hardship .................................................................................................... 7 9 Portfolio and Risk Management ...................................................................................................... 7 10 Reporting ....................................................................................................................................... 8 11 Definitions ....................................................................................................................................... 9 12 Version Control.............................................................................................................................. 10 IHOP Policy - September 2016 ii 1 Introduction IBA’s Indigenous Home Ownership Program (IHOP) facilitates increased levels of home ownership among Indigenous Australians by providing affordable home loans, which contribute to a closing of the gap between Indigenous and Non-Indigenous home ownership rates. Through the IHOP, IBA also supports the Australian Government’s initiative to provide strong incentives to Indigenous Australians living in remote areas to relocate and take up work in locations where there are stronger labour markets or pursue educational opportunities. 2 Strategic Objectives and Purpose The IHOP facilitates Indigenous Australians into home ownership through providing access to affordable home loan finance. The program aims to address barriers such as loan affordability, low savings, impaired credit histories and limited experience with long-term loan commitments. IHOP also supports Indigenous Australians in remote communities to overcome the obstacles they experience in taking up home ownership. IHOP provides an entry point into home ownership for Indigenous Australians who have the capacity to service a home loan but do not have the capacity to save the required deposit or meet the loan assessment requirements of other home lenders. By providing the first step into home ownership, customers are able to build equity in their home and are able to transition to other home loan finance to purchase their subsequent home, for example, to accommodate changing family circumstances, or to take advantage of enhanced product features banks provide to higher net wealth customers. The program addresses a unique segment of the market, which is not currently serviced by the home loan finance sector. It complements, rather than competes with, lending products of other home lenders, and facilitates the transition of customers from social/rental housing to home ownership. The program supports customers at all stages of the process of applying for, committing to, and managing the financial impact of buying their home. IBA customer monitoring processes provide an appropriate balance between ensuring that customers have the best opportunity to continue in home ownership where practicable, whilst ensuring that they embrace the obligations and responsibilities of home ownership. This includes appropriate arrears management and loan and customer monitoring arrangements that allow for early intervention and management of arrears cases. While it is desirable for the program to support all Indigenous Australians to pursue their aspirations for home ownership, it is important to recognise that not all have capacity or are ready to meet the obligations for home ownership. There are others who would have the capacity to pursue their home ownership aspirations through accessing loan finance from another lender. 3 This Document and Related Documents The IBA Board is responsible for setting the strategic direction of the Indigenous Home Ownership Program consistent with its enabling legislation, the Aboriginal and Torres Strait Islander Act 2005. Consequently the IBA Board has endorsed this document to guide the strategic management of the Indigenous Home Ownership Program. The practical implementation of the IHOP Policy will be managed in accordance with relevant IBA policies, instructions and delegations, which are described below. IHOP Policy - September 2016 1 IBA Policies – Corporate Plan IBA has various policies relevant to delivery of its programs. The following policies are relevant to IBA’s operational management of the IHOP: 3.1 IBA Credit Policy Confirmation of Aboriginality BP01 (9 July 2015) (refer Board Paper 13 June 2014) The IHOP is also subject to IBA’s Corporate Plan. 3.2 Chief Executive Instructions (CEI) CEIs provide staff with detailed instructions for the effective management of IBA’s business. The following CEIs provide relevant instructions in respect to the management of the IHOP: Customer Application and Verification Requirements Customer Eligibility and Housing Loan Assessment Housing Loan Funding and Prioritisation Loan Management and Hardship Further detailed procedures are provided to IBA staff to facilitate the effective administration of the program. 3.3 Delegations The IBA Board has delegated to the Chief Executive Officer appropriate powers to enable the effective day to day administration of the IHOP. The Chief Executive Officer has by a delegation instrument (IBA Management and Accountability (Chief Executive Officer to staff) Sub Delegation Instrument) provided a range of sub-delegations to IBA staff to enable them to undertake the necessary functions to enable the practical delivery of the IHOP. 4 Eligibility Requirements The IHOP is primarily focused on first home buyers who would otherwise not qualify for home loan finance from other home lenders. To be eligible for consideration by IBA for an IBA Housing Loan, customers must: be of Aboriginal or Torres Strait Islander descent supported by documentation that is acceptable to IBA be an Australian resident be at least 18 years of age have the legal capacity to enter into a Loan Agreement intend to reside in the home being acquired. In providing home loan finance IBA seeks to ensure: the applicant has a capacity to meet required housing loan payments and has sufficient income to meet ongoing home ownership expenses, which includes property maintenance, rates and insurance the applicant understands the full nature of the home loan including their obligations in respect making loan repayments when due and the potential consequences if they default on their payments or other home loan obligations there is a willingness of the applicant to meet their loan obligations if the applicant is purchasing a property on community titled land the conditions and land tenure arrangements are conducive for successful home ownership outcomes. IHOP Policy - September 2016 2 IBA will not provide home loan finance to applicants who are: 5 able to fund the purchase of their home through the commercial home finance sector currently bankrupt or have been discharged from bankruptcy less than 2 years purchasing an investment property or property that may be used for business purposes, including hobby farms, bed and breakfast establishments or other commercial properties. Funding and Prioritisation The level of funding available for housing loans is limited to the capital that IBA receives from loan repayments, loans that are discharged early and additional capital injections. In line with the IHOP funding parameters IBA prioritises its lending to customers based on circumstances and the housing market in which they are seeking to buy a home. This includes prioritising customers with lower incomes, those living in Remote Locations and First Home Buyers. 6 Housing Loan Products IHOP lending products are specifically tailored to address a unique segment of the market, which is not currently serviced by the home loan finance sector. Housing loan products are primarily for Indigenous first home buyers. Loans may also be provided to existing or previous home owners where this is necessary to allow them to continue in or re-enter home ownership. 6.1 First Home Buyers Housing loans available to first home buyers for the following purposes: Purchase a home – to purchase an established residential property, including buying an apartment or project home. IBA will only consider providing housing loans for off-the-plan purchases or the purchase of unregistered land, such as purchasing a brand new home or unit before it is built, if the purchase can be completed within a six-month period. Construct a home – to construct a home, including where necessary the purchase of land. The house is to be built by a registered licensed builder under a fixed-price contract. Purchase and upgrade a home – to purchase an existing residential property and undertake repairs and renovations. All works must be undertaken by a registered licensed builder under a fixed-price contract. Purchase residential land – provides an opportunity for customers with limited current capacity to repay a loan to start on the path to home ownership by purchasing a block of land upon which a home can subsequently be built. Fee Finance – a loan to assist customers meet some or all of the costs associated with buying a home offered in conjunction with an IBA housing loan. This includes government stamp duty and other establishment costs. 6.2 Existing Home Owners Housing loans to support customers who already own a home to remain in home ownership: Home Improvements – to fund home improvements, routine maintenance and repairs to an existing home: to accommodate changes in the number of family members for medical or related health reasons IHOP Policy - September 2016 3 to assist a family cope with local environmental conditions such as excessive heat or cold to repair or replace worn out or obsolete items of domestic infrastructure to prevent harm or danger to the family members. Refinance Loans – to refinance a loan from another lender where, due to an unforeseen or unexpected circumstances (for example, the death or invalidity of a spouse resulting in a significant reduction in income), the customer may lose their home. People adequately housed and repaying loans without difficulty are not eligible for a refinance loan. Property Settlement – to enable the Indigenous party to continue in home ownership where there has been a relationship break-down and there is a formal agreement for the Indigenous party to buy the other party’s equity interest in the home. 6.3 Previous Home Owners Housing loans to customers who are previous home owners who require assistance to re-enter home ownership: Previous Home Owners – where the applicant had to sell their previous home for one of the following reasons and their current financial circumstances precludes them from borrowing from a other home lender: change of location to take up employment or educational opportunities medical grounds inadequate family accommodation changed living arrangements due to a permanent relationship breakdown financial hardship that necessitated the sale of the previous home. 6.4 Loans for Customers Living In Remote Communities Housing loans to assist customers who live in a Remote Location, buy their own home. Remote Indigenous Home Loan – tailored housing loans for first home buyers who are a: customer who lives in a Remote Location community; or Remote Location Mobility Applicant. Remote Indigenous Home Loan products mirror those available to first home buyers, and existing and previous home owners, but have some additional concessions in recognition of the specific home ownership barriers that exist in these locations. First home buyers who are eligible for a Remote Indigenous Home Loan (RIHL) may also be eligible for tailored funding support of up to $33,000 to assist with establishment costs, repairs and maintenance, property insurance and rates. Loan Establishment Costs - Funds are available to meet up-front loan establishment and incidental costs of purchasing a home, to a maximum of $13,000 per application. The types of expense that are eligible to be paid are: legal fees for creation and registration of a lease, IBA mortgage security and advice on any relevant building contract pest and building reports IHOP Policy - September 2016 4 independent financial advice in respect of the financial aspects of the loan, including repayments, affordability independent legal advice about loan terms and conditions, general loan obligations and consequences of default house insurance for the first year property valuation costs including subsequent fees associated with progress payment inspections for new constructions or major renovations pest control project manager costs for new constructions or renovations other costs associated with the applicant getting into home ownership. Remote Indigenous Home Buyer Grant - A grant of $20,000 may be available to applicants with Total Gross Incomes of up to 100% of IIA. The grant may be used for the following home ownership expenses: minor house renovations, repairs and maintenance essential costs such as rates and insurance other costs associated with completing the home purchase not met under Loan establishment costs. Remote Location Mobility Applicants will remain eligible for this grant if their Total Gross Income does not exceed 100% of IIA at the time of their loan application. Eligible applicants who do not need to utilise the full $20,000 at the time of property purchase will have the unexpended amount of the grant credited to their loan account and IBA will, over the life of the loan, consider requests for a redrawal for this amount, or part thereof, to pay for essential home ownership expenses. In the event the security property is sold within 3 years of property settlement, either by mortgagee sale or sale by the owners, the Remote Indigenous Home Buyer Grant is to be repaid in full. 6.5 Loans to New South Wales Aboriginal Housing Office (AHO) Tenants Housing loans offered to NSW AHO tenants to enable them to purchase the home that they currently rent. IBA AHO housing loans mirror those available to first home buyers and previous home owners. Applicants who are eligible for an IBA AHO housing loan may also be eligible for an establishment cost grant (funded by the AHO) of up to $2,500 to assist them with establishment costs such as legal and conveyancing fees, valuations, building reports and pest control inspections. 7 IBA Housing Loan Eligibility and Assessment An applicant’s eligibility for an IBA housing loan and the amount of the purchase price that IBA will fund is determined based on specific eligibility requirements, which are determined based on the applicant’s income, assets, savings, and their ability to afford loan repayments and meet home ownership obligations. If the applicant is not able to meet eligibility and assessment criteria, IBA will not provide a customer with housing loan finance. 7.1 IBA Loan Amounts IBA may provide a loan for all or part of the funds required for the purchase of the home. The proportion of the purchase amount to be loaned by IBA will depend on the applicant’s Total Gross Income and the amount the applicant is able to obtain from another lender. IHOP Policy - September 2016 5 7.2 Assets Applicants with net assets of $200,000 or more, (including savings, cars, trusts, businesses, and other assets, but excluding preserved superannuation) which could be reasonably restructured to facilitate the purchase of a home will be assessed on this basis. 7.3 Savings IBA has lower deposit requirements than many other home lenders. The minimum deposit requirement increases depending on the applicant’s Total Gross Income or whether they are a current or previous home owner. Applicants are required to contribute the maximum funds they have available towards the deposit (even where this amount is greater than the minimum deposit requirement determined for the applicant), after meeting the costs associated with their home purchase, including any first home owners assistance they receive from their state or territory government. 7.4 Loan Affordability An applicant’s capacity to afford a housing loan is assessed by reference to the proportion of an applicant’s Total Gross Income that is required to meet proposed housing loan repayments and consumer debt. Applicants must also have sufficient income to meet other home ownership obligations after meeting general living costs and expenses. 7.5 Housing Loan Terms and Conditions The terms and conditions applicable to IBA Housing Loans depend on the individual circumstances of the applicant and the relevant IBA Housing Loan product. Interest Rates IBA applies different commencing interest rates for applicants depending on whether the applicant is a first home buyer, previous or existing home owner. First home buyers are eligible for a reduced commencing interest rate, which is set depending on the applicant’s Total Gross Income and whether they obtain some of the funds required to purchase their home from another lender. The interest rate on loans with a reduced commencing interest rate graduate to the IBA Home Loan Rate in increments after an initial period, protecting the customer from potential market interest rises during the early period of their loan. Loans to previous or existing home applicants are generally assessed at the IBA Home Loan Rate which is generally adjusted in line with market interest rate movements. Customers who temporarily move elsewhere and rent out their home will be charged the IBA Leased Home Loan Rate. Interest Rate Adjustment The interest rate on loans is adjusted according to interest rate settings applicable to the loan, including the: (a) scheduled increases of interest rates for loans which are approved at reduced commencing interest rates; and (b) changes to interest rates on loans which are subject to changes in the IBA Home Loan Rate or IBA Leased Home Loan Rate. Interest calculation and debit Interest on housing loans is calculated on the outstanding daily loan balance. Interest is debited to the loan account at regular intervals. IHOP Policy - September 2016 6 Loan Terms IBA’s standard loan term for first home buyers and previous and existing home buyers is 32 years, but the term may vary depending on the customer’s circumstances. The maximum loan term is 45 years. Where practical, loan terms are set so that the monthly repayment will be the maximum they can afford, taking account of their overall living expense. As the loan progresses, customers may make additional repayments or maintain their repayments at a higher level, enabling them to repay their loan sooner. The maximum loan term for Purchase of Residential Land and Fee Finance loans is 10 years. Repayments IBA loan repayments are determined based on the amount of the loan, the applicable interest and term of the loan. 8 Loan Management and Hardship Loan accounts are to be monitored and managed to ensure that borrowers comply with the terms and conditions set out in IBA’s loan agreement and security document. This includes monitoring and/or managing the following: (a) (b) (c) (d) (e) (f) (g) (h) (i) compliance with IBA housing loan repayments; financial hardship; arrears management and loan defaults; compliance with other lenders’ loan conditions; payment of local government and municipal council rates and taxes; maintenance of home insurance; review of loans with extended repayment terms; factors impacting security; and shortfall after sale and write-off of residential loan balances. IBA may agree to provide hardship assistance where hardship is evident and it is expected that the borrower will be able to resolve the hardship within a reasonable period. Hardship assistance may include: varying the loan instalment negotiating a loan repayment plan deferring loan instalments reducing interest rate increasing the loan term writing back arrears IBA will issue default notices and exercise its power as mortgagee to take possession of a property and to sell the security property to recover all monies owed where customers are assessed as not eligible for hardship assistance and do not comply with IBA’s housing loan repayment and their other home ownership obligations. 9 Portfolio and Risk Management IBA has statutory obligations of accumulating and preserving its substantial capital asset for the benefit of Aboriginal and Torres Strait Islander people. Delivering the program on this commercial footing requires IBA to operate according to sound business principles. Accordingly, the program should seek to make a positive return on the Australian Government’s capital investment and adopt appropriate risk and portfolio management practices. IHOP Policy - September 2016 7 IBA accepts a higher level of risk than other home lenders by virtue of the characteristics of the loans made by the IHOP. These risks are evident in the composition of IBA’s loan portfolio which has: large concentration of high loan to value (LVR) loans high level of arrears (relative to other home lenders) loan terms exceeding 30 years loans provided at concessional interest rates high concentration of first home owners high concentration of customers in regional locations high proportion of construction loans. IBA manages these risks by having appropriate lending policies and processes and employing experienced staff to oversee lending activities. From a financial perspective, IBA’s loan receivables are considered riskier than those of other home lenders. IBA accepts a lower rate of return than other home lenders would accept given the same level of risk. These risk and return characteristics are reflected in the fair valuation of its housing loan portfolio and through the monthly provisioning of doubtful debts. IBA reports on the composition of its loan portfolio, including characteristics such as arrears, geographic concentration and loan to valuation ratios, and reports on the fair valuation of its loan receivables based on current market benchmarks on a monthly basis. Significant changes in the risk profile are reviewed with a view to informing potential changes to policy settings where necessary. IBA also conducts stress testing of its portfolio on an appropriate basis to ensure that the Board is adequately apprised of the risks to the asset base from significant market events, such as a significant decline in property prices combined with higher levels of unemployment. The acceptable credit risk tolerances for the IHOP are as follows: Indicator Loan Serviceability Loan repayments less than 35% of total gross income Concentration Risk Home lending for “construction” Security Coverage Loan to Value Ratio Loan Receivables Provision for doubtful debt (PDD) Balance of loans – 30+ days past due Balance of loans – 90+ days past due Tolerance > 90% of number of new loans per annum < 35% of number of new loans per annum < 90% weighted average of the Active Loan Portfolio Balance < 0.5% of Total Loan Portfolio Balance < 10% of Active Loan Portfolio Balance < 5% of Active Loan Portfolio Balance 10 Reporting IBA’s performance in meeting the strategic objectives and purpose of the program will be managed through the regular monitoring and reporting of the characteristics of loans that are made through the IHOP and the composition of the IHOP loan portfolio. This will include the formal reporting arrangements associated with: IHOP Policy - September 2016 8 (a) (b) (c) (d) (e) portfolio budget statements annual report corporate plan regular CEO reports to the Board annual review of IHOP Policy. 11 Definitions Term IBA Home Loan Rate Definition The standard interest rate for owner-occupied housing loans. The IBA Home Loan Rate is set by reference to the average of a ‘basket’ of standard variable home loan rates for owner-occupied properties offered by a range of other home lenders. IBA Leased Home Loan Rate The standard interest rate for non-owner occupied properties. The IBA Leased Home Loan Rate is benchmarked to the IBA Home Loan Rate plus a margin. IBA Income Amount (IIA) A reference benchmark used to determine the income tiers for determining the loan terms applicable by reference to the applicant’s Total Gross Income. The IIA is adjusted annually by reference to the latest available National Average Weekly Male Earnings (NAWME) statistic calculated by the Australian Bureau of Statistics. The Indigenous applicant who is an existing or former home owner. A housing loan made to a A customer who lives in a Remote Location community, or Remote Location Mobility Applicant Remote Indigenous communities that lack a significant history of home ownership and include: locations where land title is held communally locations which have mixed land tenure arrangements locations on land which is partly owned under community title and is not Commonwealth land, or other nominated remote communities under the Remote Indigenous Housing Strategy including Torres Strait Islander communities. An applicant who is eligibility for IBA housing loan finance and may be eligible for tailored funding support for up to five years after moving (after 1 August 2015) from: a Remote Location; or an outstation or small discrete Indigenous community. Income from wages, salary, allowances; Centrelink benefits; and interest income, dividends and other assessable income. Previous Home Owner Remote Indigenous Home Loan (RIHL) Remote Location Remote Location Mobility Applicant Total Gross Income IHOP Policy - September 2016 9 12 Version Control Approval BM76 6 July 2012 BM85 5 December 2013 BM92 12 February 2015 BM95 9 July 2015 BM98 23 March 2016 BM99 6 May 2016 BM101 15 August 2016 Board Policy Number BP09 BP09 Title Indigenous Home Ownership program policy July 2012 Indigenous Home Ownership program policy January 2014 Commencement Date 9 July 2012 1 January 2014 BP09 Indigenous Home Ownership program policy March 2015 1 March 2015 BP09 Indigenous Home Ownership program policy August 2015 Indigenous Home Ownership Program policy July 2016 Indigenous Home Ownership Program policy July 2016 Indigenous Home Ownership Program policy September 2016 1 August 2015 BP09 BP09 BP09 IHOP Policy - September 2016 1 July 2016 1 July 2016 1 September 2016 10
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