Understanding
APRs
November 2004
Ray Boulger discusses some of the problems with quoting typical
rates
A recent MORI survey commissioned by the
Institute of Financial Services found that 80% of people were unable to
identify APR as being the “interest rate and other costs of a
loan.” This suggests that at their meeting last
month, when they criticised the banks for high APRs on credit cards, the
Treasury Select Committee should also have had a target closer to home -
the umpteen Ministers of Education we have had over many years who have
only educated 20% of people in basic financial matters. Another survey
suggests only 40% of people understand percentages but I hope whoever
calibrated the results of both surveys wasn’t one of the other 60%! As the
APR is a percentage it is hardly surprising so few people understand it.
If APRs were better understood it would be
more difficult for financial institutions to seduce customers to borrow on
very high interest rates. Notwithstanding this, rather than focus their
attention on something which only 20% of people understand, the Treasury
Select Committee might have been better off spending more time questioning
the legality of fees such as late payment charges, typically around £20 -
£25, which most people do understand.
Barrister Richard Colbey wrote in the
Guardian a few weeks ago that these charges are legally void unless they
reflect the loss suffered by the party enforcing them and as such are
unlikely to be enforced by the courts. Perhaps it would have been
unreasonable to expect MPs on the Treasury Select Committee to have known
this - after all they only make the laws!
APRs are very useful with some types of
borrowing, but with mortgages they are worse than useless in most cases.
When the Consumer Credit Act covered mortgage advertising it was a legal
requirement for lenders and brokers to mislead potential borrowers when
quoting an interest rate on a product by also quoting an APR. The FSA has
made matters worse by prescribing that the new Key Facts Illustration must
include a statement saying “the overall cost for comparison is X.X% APR.”
On the other hand some aspects of the new financial promotion rules will
be helpful to consumers. If a promotion includes the initial mortgage rate
it must also include, at least as prominently, all other interest rates
applying to that mortgage. This is likely to result in the demise of
adverts promoting mortgages with a cheap short term rate, coupled with
extended early repayment charges locking the borrower in to a much higher
rate for years afterwards.
Moving back to APRs, the main reason the
vast majority are grossly misleading is that they are normally based on a
25 year term, whereas the average life of a mortgage is now only 4 - 5
years, although 25 years is still the most common initial term. Another
significant problem is that cashbacks must be ignored. One result of this
is that two otherwise identical remortgages, one with a free valuation and
free legals and the other a refund of valuation fee and a cashback to
cover the legal costs, will have different APRs, unless the rounding to a
single decimal place eliminates the difference.
A more serious problem from ignoring
cashbacks naturally arises with cashback mortgages. Compare client
specific APRs for two mortgages with a 10 year term and with an identical
SVR. One mortgage has a 10% cashback and the other has a 0.5% discount for
10 years. The APR on the discount mortgage will be 0.5% less than the APR
on the cashback mortgage, although even the Treasury bureaucrats who
agreed the basis for APR calculations could probably work out that a 10%
cashback on day 1 has more value than a total discount of 5% spread over
10 years. Factoring in the discounted cash flow benefit of receiving the
cashback up front enhances the benefit further.
Typical APRs must be calculated on the
basis of similar mortgages sold by the lender or broker over the previous
year. A broker whose typical mortgage was £300,000 on a 70% LTV might have
a different APR for the same mortgage from a broker whose typical mortgage
was £75,000 at 90% LTV, primarily because of the different percentage
impact of fees. The lender could well have yet another different typical
APR for the identical mortgage.
Lenders will know what the actual typical
life is of their
mortgages,
in addition to the initial term, although obviously this will vary with
the product. However, brokers will only know the typical life of a
proportion of their mortgages. Nevertheless, as APRs are meant to be
typical, one way of giving them some value would be to calculate them over
the typical life of the mortgage being advertised. If the typical life of
a 2 year tracker or fix, without any amendment to its original terms, is 3
years an APR calculated over that period, assuming a final payment in
month 36 of the outstanding amount and amortising the costs over that
period, would have some value.
Meanwhile it remains a legal requirement
for authorised firms to mislead potential clients in their financial
promotions by quoting an APR calculated on completely fictitious
assumptions. This seriously conflicts with the FSA’s requirement for all
financial promotions to be “not misleading.” A partial saving grace is
that as 80% of people are unable to identify APR as being the “interest
rate and other costs of a loan” only 20% of people seeing an advert will
be mislead by the APR!
A final thought. If a mortgage adviser has
a senior FSA official as a client is it safer to recommend the mortgage
which actually offers the best value for that client’s requirements or
would it be more prudent to recommend the mortgage which meets the
client's requirements with the lowest APR in “the overall cost for
comparison” figure in the KFI? After all, what other use is there in
having a figure for the "overall cost for comparison” on the KFI! Come to
think of it, why not outsource all mortgage advice to an overseas call
centre that could email clients a selection of KFIs for mortgages that
meet their requirements and tell them the one with the lowest APR must be
best!
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