Equity Release Council’s Response to Dowd Report Confirms its Central Message

Kevin Dowd 13 August 2018

I welcome the Equity Release Council’s response to my report, “Asleep at the Wheel: The Prudential Regulation Authority and the Equity Release Sector,” which the Adam Smith Institute published last Tuesday, 8 August. The ERC’s response confirms (I presumably, inadvertently) my central point that the industry are not valuing the No-Negative Equity Guarantees (NNEGs)1 in their Equity Release Mortgages (ERMs) properly, and their response does not dispute my second claim that the degree of under-valuation is material. Their response also suggests a remarkable degree of misunderstanding about the regulatory system – one suspects that they are a victim of industry propaganda.

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Trust in Just?

Kevin Dowd 13 August 2018

Yesterday’s (12 August) Sunday Express on my Equity Release report, Asleep at the Wheel: The Prudential Regulation Authority and the Equity Release Sector, had some interesting comments from Steve Lowe, a director at specialist retirement group Just.

He said that I had not shown how I had arrived at the numbers cited in my report, so it is impossible to say if they are correct.

Actually, I did explain my numbers: the model calibrations and my justifications for them are explained on pp. 29-33 of my report.

Still, I grant that I can’t prove that my numbers are correct. It is possible that other people could come up with alternative calibrations that are better than mine or come up with an alternative model that is better than my model.

I explained my numbers and my model to give others an opportunity to say how they would improve on what I have done, and no-one has yet tried to do so.

But one thing I can prove is that the approach used by the industry is incorrect.

How do I know that the industry are getting it wrong? Because (1) the NNEG is a form of option, and (2) because the industry repeatedly confirms that it uses a variable – either the trend rate of growth of house prices or the expected or the actual rate of growth of future house prices – that option pricing theory says is irrelevant to correct option pricing. So if the industry is basing its NNEG valuations on a variable that does not affect correct option pricing, then it must follow that the industry is not valuing its options correctly.

And by its own admission, though not quite in those words

Mr Lowe goes on to say: “However, we agree firms should be prudent and set aside sufficient resources to allow for shocks in the economy.”’

Of course firms should be prudent but I have two questions for Just:

My results suggest that the companies are (greatly) under-valuing their NNEGs. Now I would like to believe that Just is valuing its NNEGs properly, so perhaps they can do what I have done and show how they arrive at their numbers so people like me can verify them. After all, if their numbers are correct, it can only help to have them externally verified.

By “setting aside sufficient resources to allow for shocks” I understand Mr. Lowe to be suggesting that companies should be well-capitalised, and if that is what he meant then I agree. But in that case, can (or how can) Just assure us that the company is well-capitalised now, before any shocks hit the economy.

I would like to trust Just but as the saying goes, trust but verify.

The UK Equity Release Industry is Undervaluing its Guarantees

Kevin Dowd

13 August 2018

Most UK Equity Release mortgages1 involve a no-negative equity guarantee (NNEG) by which the lender guarantees that the borrower (or their estate, if they have passed away by then) will never need to pay back more than the value of their house when the loan is repaid.

The valuation of these NNEGs has suddenly become a hot issue in light of this week’s two reports – Howard Mustoe’s BBC story “Home equity release may cost pension firms billions” and my report, “Asleep at the Wheel: the Prudential Regulation Authority and the Equity Release Sector” – and a BBC Radio 4 programme “The Equity Release Trap” aired last Tuesday (8 August 2018) at 8 pm.

These reports and some of the reaction to them show that there is considerable confusion about the valuation of these NNEG guarantees.

There shouldn’t be.

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Hidden in plain view

All investors accept, or should accept, the importance of corporate transparency. The purpose of governance structures, including statutory reporting supported by independent external audit, is to ensure that minority shareholders receive reliable information about the value of firms and that company managers do not cheat them. Management should also be motivated to maximize firm value rather than pursue personal objectives (Bushman and Smith, citing Black 2000).

In my previous post I puzzled about what impact the current PRA proposals on Equity Release valuation would have on the capital of Just Group, finding that their own figures suggest a hit of nearly £1bn, in fact over £1bn if we add on the PRA expectation of a minimum 1% deferment rate. Where is this number to be found? Just’s regulatory report states that the regulatory capital has gone up, not down.  Altissimum est negotium et maioris egens inquisitionis. Let us investigate this deep mystery further!
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The ermpire strikes back

The equity release lobby has begun to respond to the Adam Smith Institute report. All the indications are they haven’t actually read it. Robert Sinclair of the Association of Mortgage Intermediaries has dismissed the parallel drawn between equity release and the Equitable Life affair, saying that Equitable Life was based on two different scenarios: they were invested badly and there were guaranteed annuities which they couldn’t afford to repay’. Did you say ‘guarantee’, Robert? The summary of the ASI report, i.e. the bit you don’t have to read very far to get to, says ‘This scandal is similar in nature to the Equitable Life scandal of nearly two decades ago – it involves the under-estimation of opaque long-term guarantees’.

Sinclair adds: ‘The risk is the gap between the current valuation and the longevity risk which is a judgement on how much house prices rise.’ He clearly hasn’t read either the ASI report, or the PRA’s own consultation document on equity release, CP 13/18, for neither is about risk management, but read on.

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Just what is the value of Just?

The share price of Just Group has been in freefall since 24 July following a statement by the firm about proposals by the Prudential Regulation Authority (PRA) which, if implemented, would result in a ‘reduction in its regulatory capital position’.

The proposals concern the valuation of the ‘no negative equity’ guarantee embedded in equity release mortgage assets. The PRA is fretting that firms are undervaluing them. But how much is the undervaluation, and how much would the reduction in capital be? Analysts have been scratching their heads for weeks. One estimated a loss of no more than £50m, another thought it could be as much as £500m.

Nobody seems to know. How large is the impact, and why is it so difficult to tell from regulatory reports, given the more transparent, risk-based and dynamic era of supervision ushered in by the Solvency II insurance capital regime?

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I would refer you back to the Equitable

Transcript of the Treasury Select Committee hearing, 11 July 2018, on Equity Release, 15:19:50.

Witnesses: Sam Woods, Deputy Governor for Prudential Regulation and Chief Executive Officer of the Prudential Regulation Authority , Sarah Breeden, Executive Director, International Banks Supervision, Bank of England, and David Belsham, External member of the Prudential Regulation Committee.

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Welcome to Eumaeus!

Nothing to see right now, but this is something about Eumaeus and what it is here for. It’s pronounced ‘You-my-us’.

This is us.

Following the Dowd report ‘Asleep at the Wheel’, our first post will be on August 8th, lifting a bit more of the lid on the strange world of insurance valuation.

We hope to see you again soon.