The Office of the Superintendent of Financial Institutions (OSFI) recently released draft changes to Guideline B-20 for public consultation. The B-20 Guideline establishes OSFI's expectations for prudent residential mortgage underwriting and is applicable to all federally regulated financial institutions.
Mortgage Professionals Canada has provided its formal written submission to OSFI, which can be found here. Our response is based on feedback we received from members and reflects the broad position of the industry. We wish to thank all volunteer members of our Lender and Insurer Committee for their participation and input to our submission.
We express our concern with the proposed new stress test. We question the timing of its introduction and, if deemed necessary, we suggest adjustments that will be better for the market place and consumers. Our submission also responds to the proposed prohibition on co-lending activities, dynamic loan-to-value underwriting practices, and income verification.
We are continuing our discussions with OSFI directly in the lead up to the potential implementation of these changes. Our engagement with the Department of Finance and the Bank of Canada is also ongoing as we advocate for common sense adjustments to the measures that have already been implemented.