Oireachtas Joint and Select Committees

Thursday, 27 November 2014

Joint Oireachtas Committee on Finance, Public Expenditure and Reform

Mortgage Insurance Schemes: Discussion

11:45 am

Mr. Michael Bennett:

Okay. Mortgage insurance would be a contractual relationship between the lender and the insurer and the loan agreement is a contractual relationship between the lender and the borrower. To the extent that there are disclosures of information in respect of costs and illustrations one might see in other insurance products, that would be an issue for the regulator. I do not think we as an insurer who is now a party to the agreement could dictate it.

In respect of due diligence, most insurers operate under a delegated underwriting authority but perform periodic evaluations and loan file audits to assess underwriting criteria, including the accuracy of appraisal values. My experience is that for high LTV lending, a full appraisal whereby an appraiser visits the property, rather than a drive by appraisal or a view of comparable properties on a website, would be the most appropriate. We would be happy to provide coverage to State banks. In terms of the pricing and whether it varies by loan attributes, it does not vary by health and that is not a criterion this is considered by even the lenders. They consider the sustainability of income and affordability. In terms of age, the only caveat I would add is that the borrower must be have sufficient income for the term of the mortgage. Therefore, there is usually is a limitation on lending into retirement but there is not a differentiation between someone who is aged 35 and someone who is aged 40, apart from their being able to sustain the mortgage for its term.

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