Changes to rent controls announced - thread for clarifying

People keep saying that outside foreign capital is required to build apts. Yet every CU and bank in the country is flooded with deposits. Can anybody reconcile these two statements?

Yeah its a common misconception that deposits equal scale and ability to lend - banks in Ireland have excess deposits but dont confuse that with excess and/or abundant shareholder/tangible equity for development lending and dont confuse the low deposit rate your getting on your savings with the profitability or return on equity available lending into the development space.

What limits lending inside of banks is really their tangible or shareholder equity and then the risk weights attached by regulators to the proposed lending to be done which influences the return on equity. The riskier the lending the more capital required. The more capital required the lower the return on equity that can be achieved on the banks equity. Now banks need deposits too to balance their assets and liabilities - ideally this comes from low cost deposits which enhances the return on equity the banks achieves on its own tangible equity (deposit costs being an input to net interest rate margin)...but banks can get deposits from overseas via bond sales etc....deposits are always abundant in some sense, regulatory capital is always scarce.

I can expand further lots of moving parts to this - but two keys issues to reflect on:

(1) I outlined above how producing apartments is currently a non-economically viable activity due to Irish build costs intersecting with the current gross yields demanded by PRS investors (a function of rates but also perceived risk to investor cashflows) the math of which makes building incremental apartment supply a non-starter. Banks do not lend into guaranteed money losing activities so before we even get to whether they have abundant deposits or abundant shareholder equity there needs to be a business case for apartment assets to be constructed such that loans could be even written against them. The business case does not exist for a developer to produce an apartment building and as such no developer would walk into a bank to seek a loan to do so as the upside down math would become apparent in the first 15 minutes - remember above €52m sales price needed to build and where the market will only pay €37m for it.

This is a not a good loan candidate for a bank before we even get to its relative attractiveness to other things a bank could do with its shareholders equity capital.

(2) Lets say the business case existed to construct an apartment complex. OK. The developer can show an end purchaser willing to pay build cost plus 15% developer margin - you're seem to be assuming that because banks have abundant excess deposits they have ample scope to lend?

Two issues....number one banks lending scope is ultimately limited by their tangible equity not deposits and their desire to consume regulatory shareholder capital activity is a function of the profitability of that underlying lending. Development lending is deemed by regulators to be very risky and as such it has very high risk weights which means more and more of the banks scarse shareholder equity gets consumed in making these loans - the shareholder equity capital required to be put aside to write €1 of a development loan is multiples maybe three to four times the level of that required to write a €1 loan to a prime mortgage customer. Yes higher lending rates can be achieved lending to risky developments but that is only half the story - the other half is that this lending consumes regulatory capital, as I said, three to four times that of mortgage lending due to post-GFC regulations....short version lending to developers is not a very good business for the banks....end point concentrated, high risk, and not markedly higher returns relative to other loans you could make due the high consumption of your regulatory capital......regulators to a certain extent put the banks out of the development finance business post-GFC with all the new RWA rules.

What can be done about it.

My prescription to the above problem is simple one......the Irish government could fix this bank development lending viability issue overnight & "mobilize" the excess deposits in Irish savings accounts.....and that would be to engage with the pillar banks and provide SRT's (Synthetic Risk Transfers) for new development lending (apartments/homes)....such SRT's would see the banks take the first, pick a number, 15% tranche of losses on any development lending they might do with the State taking the next 35% of losses with the bank back on the hook for the final 50%.....I'm not sure what the number is....but in doing so you'd restore the attractiveness of development lending such that it might compete with mortgage lending in terms of RoE's.....regulators due to the SRTs would assign lower risk weights to such lending and therefore the scope to lend into the sector would expand (remember its regulatory capital that is truly constrained inside a bank, not deposits). Its a no brainer solution if the exposure was managed appropriately but of course politically it be classed as another bailout of the banks. In reality its the quickest mechanism by which the State's superior cost of capital could be transmitted to the private sector which is best placed to allocate lending appropriately. Under the SRT 'skin in the game' is retained at the bank level but it is required to to make development financing a business that the Irish banks and their shareholders would have any interest in entering again given the current regulatory environment, high risk relative to the low RoE's.
 
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The business case does not exist for a developer to produce an apartment building and as such no developer would walk into a bank to seek a loan to do so as the upside down math would become apparent in the first 15 minutes - remember above €52m sales price needed to build and where the market will only pay €37m for it.

Developers say that they can't build apts in cities for the price that people are willing to pay.

Some developers (who must be bonkers) have publically stated that the solution is for apt prices to rise.

Bear in mind that what is needed in Ireland is for residential rents to halve, and house prices to fall maybe 25%-30%.


We all agree that rents and house prices are too high.

Therefore, we all agree that the aim of public policy should be an outcome where both rents and house prices fall.

The solution is obviously a large cut in costs.

(1) site costs

(2) finance costs

(3) profit margins




New apts in Liverpool start from GBP 100k, to 250k here:


Meanwhile, they are 400k+ here. Bonkers.
 
Here is an example of excessive costs of constructing apts.

Developer Joe O'Reilly snaps up Hickey site on Parkgate Street for €30m


18.2m per acre.

Seems to have got PP for 481 apts?

Site cost is 62,000 per apt., although this excludes any comm aspect.

Way too high, needs to halve.
 
The solution is obviously a large cut in costs.

(1) site costs

(2) finance costs

(3) profit margins

Yes input costs coming down is an obvious lever. The building standards reduction is another. A predictable planning system with reduced delays would be a third.

I described above how finance costs and availability could be improved by strategic SRTs - as covered and as per your original question one can talk about all the deposits in the banks all day long....bank regulation set beyond our shores has made development lending a business that our domestic banks (even with all their deposits) quite rightly have no interest in participating in at scale....capital requirements have made that business a crappy high risk low margin regulatory capital intensive one for them.

Re: profit margins.....well lets talk about excess profit margin issues if/when they occur.....cause right now the reason stuff isnt getting built at scale is because there are NO profit margins in building it. So reducing profits margins clearly isnt the answer.

See three things cant be true at once.....(1) developers are greedy so and sos......(2) they are making a killing in excess profits....and yet (3) construction numbers are falling YoY....the left lunatics cant quite figure that one out. You can see go look at various publicly listed homebuilders in the UK, Ireland, US etc.....these are the scaled most efficient players.....I can tell you on a comp basis there is nothing special going on with the profit metrics (margins, RoE of the homebuilders in Ireland)....if there we're of course you'd have more people looking to 'get into it'....but again production numbers are falling YoY precisely because its not a good business.
 
Some developers (who must be bonkers) have publically stated that the solution is for apt prices to rise.

They arent bonkers, they are telling you the truth.....I explained it above in detail.....they are assuming no significant change in the cost structure in Ireland....if there is no change in the cost structure in Ireland then PRS development prices need to go up because right now PRS developments are transacting in the private and public markets at a price (gross rental yields) that means that new apartment development makes no sense....as shown above why build something that costs you €45m to deliver and that can only be sold after completion for €37m? I assume your not in the business of losing money in your day to day life so why would a developer be?
 
If building apts in Dublin is unviable, why did Joe O'Reilly pay 50% over the €20m asking price for the former Hickey's site on Parkgate street?
 
They arent bonkers, they are telling you the truth.....I explained it above in detail.....they are assuming no significant change in the cost structure in Ireland....if there is no change in the cost structure in Ireland then PRS development prices need to go up because right now PRS developments are transacting in the private and public markets at a price (gross rental yields) that means that new apartment development makes no sense....as shown above why build something that costs you €45m to deliver and that can only be sold after completion for €37m? I assume your not in the business of losing money in your day to day life so why would a developer be?

Assuming all of this is true, and I don't doubt you, and as selling prices are too high already, then the only solution is lower costs.

e.g.

(1) Abolish VAT on new housing

(2) Developers should pay a max site cost of €10,000 per apt to the landowner

(3) I am told by a former financial controller of a property developer that they paid up to 8% - 9% for development finance. This is crazy. It is such a crisis that the State should either lend directly to developers, or else guarantee loans to developers.

I suggest as follows:

First €1bn at 0% interest rate.
Next €4bn at ECB rate


It is such a crisis, I ignore EU Single Market rules, it's an emergency, we need radical measures.
 
Abolish VAT on new housing

I'm with you 100% on this.

Developers should pay a max site cost of €10,000 per apt to the landowner

You cant and shouldn't mandate land costs - its a free market and it should remain so. The tinkering in rental market has shown how disastrous price controls are.

8% - 9% for development finance. This is crazy. It is such a crisis that the State should either lend directly to developers, or else guarantee loans to developers.

Nature of the beast - development finance was defacto moved off banks balance sheets via regulation (some might say over-regulation). The Irish government SRTs idea I floated above would allow banks to provide much cheaper funding than 8-9% while returning the business case (RoE) to expanding their development loan books all while ensuring they have 'skin in the game'.

Again I wouldn't put interest rate controls on anything - banks should charge rates commensurate with the risk....what SRT's would do is somewhat equalize the regulatory capital penalty put on banks tangible equity by lending into the sector. IMO defaults and therefore recourse to the States balance sheet would be a rounding error inside our fiscal budget while driving down the cost of finance propelling activity.....taken in the round and in a world where new build VAT remains it would actually be a profitable enterprise for the State as I assure you the incremental VAT revenues & property taxes relative to baseline would easily exceed any SRT costs that may come in from loan defaults.
 
My friend's employer were building apts in Dublin that were, eventually, sold to AHBs.

There is no selling risk.

All of the product made, is in demand, and will sell.

The risk and margin should reflect that, not the risk of exploring for oil off the coast.
 
building apts in Dublin is unviable, why did Joe O'Reilly pay 50% over the €20m asking price for the former Hickey's site on Parkgate street?

Only two types of apartment schemes are viable in CBD Dublin - high end luxury schemes with selling prices exceeding 500k this is a very small market but one that does exist if you create the product - but clearly this doesn't solve the housing crisis cause the incremental units supplied are tiny...there are only so many people with the income to buy houses like this.

The other type of apartment scheme that is viable is yes AHBs, County Councils and the LDA as end points for the purchase of the completed apt scheme - the reason these work is that the AHBs, County Councils and LDA are paying prices far above what private sector PRS providers would be willing to pay and as such then the developer can a make profit. The issue AHBs, County Councils and the LDA which are funded by the government have only so much scope and State has only so much scope per annum to buy directly this stuff. Remember they are over-paying what a Zurich or Blackstone would pay in the current gross yield PRS Dublin market.

There is no selling risk.

Your partially right - the vast majority of developers will not put shovels in the ground on an apartment scheme unless it is forward funded...the only forward fund counterparties right now are, as we said above, AHBs/CCs & LDA.....the State does not have the balance sheet to fund these quasi-governmental agencies enough to drive the huge increase in delivery numbers we need to address the housing crisis.....so again as much as folks don't like to hear you need the private sector/international capital to come in and fund & own a big chunk of this stuff...driving down build cost will help, finance costs will help but the big piece is you need to restore confidence that rental market is not so state directed & price controlled.....if you do Dublin's gross PRS yields might converge with other European capitals (yes this means the price paid by funds per apartment would go up) the point however would be a situation where those funds have confidence that a bunch of socialists in Ireland arent going to make them take a bath on their investments over time and its a stable inflation protected asset that works for the PRS guys over the long pull.....I mean everybody wants to vilify these guys but on the other end of a Dublin PRS apartment building is an 85yr old German granny who's also worried about paying her rent/electricity from her pension......the so called 'cuckoo funds' just sit in the middle of all this which I think gets lost on folks almost entirely.
 
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My wife and I own jointly own 5 rental properties. Under the proposed legislation this makes us a "Large Landlord" which does not seem a good place to be, thus we are considering our options. If we change ownership to our separate names with one of us owning 3 properties and the other 2 properties - are we then defined as two small landlords instead of a large Landlord?
 
My wife and I own jointly own 5 rental properties. Under the proposed legislation this makes us a "Large Landlord" which does not seem a good place to be, thus we are considering our options. If we change ownership to our separate names with one of us owning 3 properties and the other 2 properties - are we then defined as two small landlords instead of a large Landlord?

Under the current Act, a “landlord” is the person entitled to receive the rent.........most certainly you would need to change the ownership structure and then the rent flow payments.

Even then they are going to have to put in anti-avoidance measures which will undoubtedly result in some aggregation mechanism to 'catch', maybe not what your doing, but what people will attempt to do with SPV's and LTD's to avoid the large landlord designation.

The other thing you'll likely need to think about is your tax assessment situation - jointly or individually....one obvious point of aggregation is properties under a joint assessed tax return.

Whats clear I think from this conversation and many others on here - is that landlord Ireland is taking a deep breath and a pause to think about whether they want to be providing this service anymore....as many rightly see the possibility that the choice may not be theirs to make in years to come. Its a deeply silly thing to do by the Government - the age of the typical small landlord is quite advanced and time in peoples lives when they are less interested in accumulating wealth (with the inherent hassle and risk) and more interested in enjoying a less complicated existence spending some of that wealth. Its such an easy choice now, for many, to throw in the towel here.
 
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So why not keep it simple and sell. Your profits wont increase much from here on in.
That's the problem.I have a good bit invested in property, it throws off a decent wedge every month. I would be hard pressed to get this from equities or any other passive investment.

I'm a long time at this. When I started there was little or no kafkaesque legislation, no RTB etc no regs that you have to read multiple times and still leave you scratching your head.

I'm the frog in the gradually heated cauldron.

I may ditch 2 of the 5 properties I own but will keep the other 3.

It really annoys me that I have to sell, I genuinely do not want to but the Govt are actually forcing me out. I'll make the decision later when I see this long awaited legislation but I suspect I need to rebalance to manage the Govts insidious meddling.
 
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Thanks both for the responses. Yes, selling some or all of the properties is certainly on our radar. We built up the portfolio over the past 20 or 25 years, it hasn't been plain sailing but we need to continue our original purpose of building (retirement)income stream. Diverting the proceeds of sale into a different investment certainly has attractions given the anti landlord legislation, hassle, not to mention RTB dealings. Our rent is largely below market due to RPZ and our having not been too greedy on rent levels in the early years. I think I'm starting to convince myself to exit while I still can!!
 
I have a good bit invested in property, it throws off a decent wedge every month. I would be hard pressed to get this from equities or any other passive investment.

Think alot of folks, advanced into the game and sitting with properties fundamentally unlevered or lowly levered and heading into their advancing years would do well to speak to a financial advisor here about possibly switching horses.....the magic to a certain extent in property is in the leverage it gives you on early cash investments, the big cash-on-cash return years are actually those early years.....the torque you used to be able to get on say €25k cash to own a €250k BTL asset.....if your 20 or 25yrs into the game your leverage ratio/LTV and therefore your return on the underlying equity in the property is coming down mechanically year by year as you pay down the mortgage....it might surprise many how you could re-create a very similar return stream on that equity in other things that are more liquid, dont call you up at 3am or Mary Lou cant wreck on you one morning in 2029.

The policy volatility moving forward on rental investments, the enhanced tenants rights, an RTB that is a landlord hostile and tenant agreeable and future ruling Governments to come that have only one way to go in terms of their landlord hostility......I mean given all this how risky is an investment in the Irish rental market....I'd say pretty risky and getting riskier by the day....the rent regulation reforms, building standards and then the recent budget tiny VAT cut...combined they look like a busted flush to me in terms of attracting international capital back in and so as market rents at the margins scream ever higher and supply goes lower this Government or successive ones will get even more draconian with the existing stock.
 
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Another thought/question on the new legislation. If an individual has more than 3 tenancies now, are they automatically considered to be a "large" Landlord on 1st March, or this this only happen when they have signed 3 new leases after 1st March? If it's the latter, one could continue on the current basis until a tenant leaves, and at that point decide whether to sell the property or re-rent under the new rules.
 
@Karmann
I attended a webinar with the Department of Housing last month (hosted by the IPOA). I put the notes I took here (which answer your question)
 
and supply goes lower this Government or successive ones will get even more draconian with the existing stock.
I think the odds are shortening on rules saying that if a tenant leaves of their own accord, the landlord must re-let or sell to another landlord. I agree with @letitroll I don't think the Funds will be stupid enough to come back. Stock will decline and they'll take increasingly desperate measures to keep the remaining properties in the PRS.

I also expect the right to buy to reappear.
 
I don't think the Funds will be stupid enough to come back. Stock will decline and they'll take increasingly desperate measures to keep the remaining properties in the PRS.

Yeah interested in counterfactuals to the idea that the funds will take pass again on Dublin/Ireland.....some positive noises from Ireland based stakeholders on the reforms but they all have a dog in the fight and saying not nice things about the incumbent government is just not good business or stakeholder mgmt....so watching for actual forward funds deals or feedback from international PRS asset managers on whether they believe the landscape as (a) meaningfully changed & (b) how they assess the risk of policy volatility moving forward.

I dunno - to a certain extent this thread and others on AAM and the general level of anxiety around the new rules and general trajectory of travel of the rules kinda tell you everything you need to know.
 
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