From the Financial Times – Lessons for the American housing market

Written by a senior lecturer at Harvard Business School and author of Too Big to Save? How to Fix the US Financial System, this article is interesting in the way that it lays out a series of lessons to the American public, while at the same time making a reasonable argument as to why our Canadian housing market has survived.

People like Garth Turner would love to have you believe that our credit practices are the similar to that of out American counterparts. He uses phrases such as “Canada’s version of sub prime” to scare the heck out of potential buyers and support his “the sky is falling” real estate predictions. The fact is that our credit practices are completely different, and Robert Pozen recognizes this. Garth, pay attention!

Take a look at the three reasons Pozen thinks our system is better.

First, Canadian banks routinely require home purchasers to make down-payments of at least 20 per cent of the purchase price of their home. Even in the government programmes to help low-income families buy their first homes, the minimum down-payment is still 5-10 per cent of a home’s price. With substantial personal net worth at risk, Canadian homeowners are very reluctant to default on their mortgages.

Second, in Canada, when a homeowner defaults on a mortgage, the homeowner is personally liable for any deficiency that remains after a foreclosure and sale of the home. Suppose a Canadian buys a luxury apartment for $800,000 with a $640,000 mortgage, and later defaults on that mortgage. If the bank forecloses on the mortgage and sells the apartment for only $600,000 the Canadian will be personally liable for $40,000 (the $640,000 mortgage minus the $600,000 sale price).

Third, Canada does not provide a tax deduction for interest paid by homeowners on their mortgages. By contrast, US law allows Americans to deduct the interest on the mortgages for their principal residence as well as for their vacation homes. Moreover, US law allows homeowners to deduct the interest on ”home equity” loans. These loans are typically second mortgages used to pull out some of a home’s equity built up over the years