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Vulture Funds Ireland 2023 – Report

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moneysherpa believe that the Government and Central Bank are failing customers who have been sold off to ‘vulture funds’.

Vulture Fund Ireland

Although the name ‘Vulture Fund’ is commonly used, these funds, also known as non bank entity funds and closed funds, are usually backed by pension funds who are looking for low risk investments with a steady return and are common in financial markets around the world.

The important difference between mortgages with Vulture Funds and those with other lenders is that they are not open for new retail business. That’s why they are also known as closed funds.

The 85,000 Mortgage holders in Ireland with closed funds (‘vulture funds’) are more vulnerable than customers of ‘open’ funds (funds offering new mortgages) because.

  1. Closed fund customers may be tied to their lender due to not being able to meet open lender affordability tests, making them ‘mortgage prisoners’ leaving them open to predatory pricing.  
  2. Closed funds are not actively competing for new business so are not constrained in their approach to their customers as Open funds.

It’s this lack of options that we believe is the key concern, where there is in effect a monopoly. When there is market failure as in this case, bad things can often happen to consumers.

If you have been out of arrears for more than 2 years and paying full capital and interest for more than a year a moneysherpa advisor will be happy to advise you for free here. If you are over sixty then even if you aren’t out of arrears equity release may be an option, if want to find out more check out our Equity Release Ultimate Guide.

We think that the current proposals to address these issues fall short of what is needed, being either unrealistic or even counter productive. The right approach to help vulture fund customers in our view is to focus on addressing the clear market failures.

For this reason moneysherpa believes, the regulator and government have a duty to protect consumers by lowering barriers to accessing the open market.

Within the 85,000 closed fund customers our analysis shows that there are three broad customer groups to consider

  1. Customers who can access the open market now – circa 26,000
  2. Customers who can’t access the market due to affordability tests- circa 38,625
  3. Customer customer who can’t access the market due to arrears – circa 20,375

Our estimates are based on the Central Bank non bank lender data reduced by the projected non bank lender share of open bank lenders and converted to actual mortgage holders using the 1.2 ratio of mortgages per mortgage holder als in Central Bank data as below.

Number of mortgages affected by vulture funds Ireland 2023
Closed Fund Status Mortgage Holders
Total Closed Fund Mortgages 90,104
Performing Tracker 25,625
Performing & Fixed 7,500
Performing Variable 12,500
Restructured 13,638
In Arrears 20,496
moneysherpa estimates 20/10/2023 based on Central Bank Arrears Data

Within the 85,000 mortgage holders with closed funds we estimate there are around 59,000 ‘mortgage prisoners’ who are unable to move to the open market.

Current interest rates for these groups is estimated below based on Central Bank Jan 2023 data and assuming that the 1% ECB rate increase post Jan has been passed through to mortgage holders.

Closed Fund TypeMixMortgage AccountsMortgage HoldersEst Rates March ’23
Closed Fund TypeMixMortgage accountsMortgage holdersEstimated Rates March ‘23
Trackers37%37,51731,0004.14%
Variable45%45,47538,0005.57%
Fixed18%18,00015,0002.57% (5.57% after fixed ends)
Total100,99285,000
Rates based on Central Bank January 2023 Retail Interest Report + ECB 1% March ’23 – 20/03/2023

Based on these projections the majority of closed fund customers are paying or will be paying significantly above current market rates, which are typically around 3.5% APRC.

It should be recognised that a sizable group of these customers, over 30,000, are simply with closed funds due to the exit of HBOS and Danske bank from the Irish market. 

Our report covers the following areas.

  1. Customers who can access the open market now – vulture funds Ireland
  2. Customers who can’t access the market due to affordability tests – vulture funds Ireland
  3. Customers who can’t access the market due to arrears – vulture funds Ireland
  4. Releasing Mortgage Prisoners – vulture funds Ireland

Read on for further analysis of the vulture funds customers and what should be done.

Customers with non restructured mortgages – vulture funds Ireland

53% of closed fund customers (46,294) are not in arrears and are paying the full outstanding capital on their mortgage. They are therefore in theory able to switch to open market lenders subject to meeting lender criteria.

  • Affordability checks
  • CCR requirements 2-5 outside of arrears 

It’s unclear how many of these customers can switch in practice.

The most significant obstacle in practice is the lender affordability checks which include a mandatory 2% stress test on the prevailing rate required under the Central Bank Consumer Protection Code.

Closed Fund Switching ExamplesMarch ‘23 APRCNew rate APRCRemaining LoanRemaining TermCurrent RepaymentNew Average RepaymentMonthly SavingTotal Saving
Variable customer5.57%3.19%€138,00015€1,133€966€167€30,068
Tracker customer4.14%3.19%€173,00015€1,292€1,211€81€14,626
Fixed customer5.57%3.19%€206,00015€1,691€1,441€249€44,884
Data from Central Bank Retail Interest Rate report Jan 23 

Therefore a typical performing closed fund variable rate customer @ 5.57%, €138,000 and 15 years outstanding, paying €1,133 a month may not be able to switch to an open market repayment of €167 less due to a combination of lender and Central Bank affordability rules.   

Customers with Restructured Mortgages – vulture funds Ireland

22.5% of closed funds,19,000 in total, are classified as restructured of which 16,000 are meeting the terms of the restructure. This includes mortgage splits, capitalisation, reduced interest and term extension.

The 16,000 restructured mortgages meeting the terms of their restructuring may also be able to switch to the open market, although only to a limited set of products and lenders. The example shown below uses Finance Ireland Progress Plus rates, which are available to restructured customers, not in arrears for 2 years when paying the full capital and interest.

Closed Fund Switching ExamplesMarch ‘23 APRCNew rate APRCRemaining LoanRemaining TermCurrent RepaymentNew Average RepaymentMonthly SavingTotal Saving
Variable customer5.57%5.69%€138,00015€1,133€1,142-€9-€1,589
Tracker customer4.14%5.69%€173,00015€1,292€1,431-€139-€25,061
Fixed customer5.57%5.60%€206,00015€1,691€1,694-€3-€592
Data from Central Bank Retail Interest Rate report Jan 23 

For both Variable and Fixed mortgage holders, if ECB rates rise above 3.5% returning to the open market could potentially reduce monthly repayments.

Customers in Arrears – vulture funds Ireland

Almost 24%, a total of 25,469 customers are in arrears of more than 90 days currently.

Number of mortgage in arrears Ireland 2023
Arrears Status Accounts Mortgage Holders
Total > 90 days arrears + 17,723 14,178 (19%)
Of which > 5 years arrears + 11,623 9,298
Data from Central Bank Arrears Report adjusted for closed funds using moneysherpa estimates 20/10/2023

These customers may have fallen into arrears due to changes in personal circumstances or other reasons. There are very limited solutions for them in the open market, however equity release may still be an option as explained below.

Options for customers by group – vulture funds Ireland

Depending on individual circumstances there are different options open to these customers. We have broken it down into three main groups.

1 – Customers who can access the open market now – vulture funds Ireland

We estimate that 26,000 of the 85,000 mortgage holders with vultures are able to switch, based on taking the average salary and outgoings 45,625 performing non restructured loans, with the average salary and outgoings applied to current lender calculators.

These customers may not have chosen to move to the open market, by switching their mortgage lender, as they think there may be little benefit or may be unaware that they can.

We believe that there are in fact substantial benefits for the majority of customers of moving to the open market, by being able to fix for example or to be able to exercise market power and that these benefits may not be fully understood by consumers.

We believe that inaccurate or misleading media coverage around Vulture funds and lack of communication by active lenders and brokers may have led to a false perception that these customers are ‘mortgage prisoners’ when they are in fact free to move.

2 – Customers who can’t access the market due to affordability tests – vulture funds Ireland

We estimate that there are 38,625 customers who can’t access the market due to affordability. These customers are either paying the whole value of the loan, but can’t pass affordability checks due to changed credit rules or circumstances, or are only currently paying off part of their loan.

These customers are not in arrears, but are currently ‘mortgage prisoners’ as they can not pass the open market lender affordability tests. 

  1. Some of these customers are being stopped moving by the Central Bank CPC stress test requirement of 2%. 
  2. Some of these customers would still fall below affordability thresholds if this test was to be removed. 

3 – Customers who can’t access the market due to arrears – vulture funds Ireland

These customers 20,375 are in arrears and are currently ‘mortgage prisoners’ as it is unlikely another lender would take them on due to their credit history.

There are some exceptions to this, in particular equity release for those over 60 is not dependent on credit history and is a way to pay off the closed fund in return for giving away a slice of your property when you leave the home.

However for most people, it is unlikely they have any open market options currently and are therefore the group most in need of protection from predatory pricing.

Releasing Mortgage Prisoners – vulture funds Ireland

moneysherpa are advocating for a number of changes from both government and the funds themselves to help those customers who are currently trapped or believe themselves to be trapped with closed funds.

1- Customers who can access the open market

The Government and/or the Closed Funds themselves should fund free independent financial advice to all closed fund customers currently able to access the open market.

This advice would include a full comms plan administered by the funds, website and advice services provided by the government and government agencies such as Citizens Information and/or MABS. 

2- Customers who can’t access the market due to affordability 

The Central Bank to work with lenders to develop more flexible affordability test for customers who are reducing their repayments by returning to the open market and to remove the CPC stress test for any customer moving to a lower average repayment over the mortgage term

The Government should also fund an equity grant scheme modeled on First Home scheme to bridge the affordability gap by reducing the required open market mortgage to a level that can be afforded by the customers and return closed customer to open market.

In the UK the London School of Economics has recently published a set of proposals including free advice and an equity release scheme to address the issue of Mortgage Prisoners there.

Next Steps- vulture funds Ireland

We are keen to understand the circumstances around mortgage prisoners as well as we can, so that we can lobby and develop ways to help.

If you have been out of arrears for more than 2 years a moneysherpa advisor will be happy to advise you for free here. If you are over sixty and want to find out more about equity release as an option, check out our Equity Release Ultimate Guide.

We are keen to understand the circumstances around mortgage prisoners as well as we can, so that we can lobby and develop ways to help. We have also opened a thread on this topic on askaboutmoney.com here.

If you have any views or experience that you would like to share with us, please get in touch with us mortgageprisoner@moneysherpa.ie

6 thoughts on “Vulture Funds Ireland 2023 – Report”

  1. Hi,

    Would there ever be any downsizing options? We had a discounted tracker that went through the roof after 12 mths. We were with PTSB, restructured and then sold to Start. I had an accident 10 years ago so can’t work and husband can only work part time.
    We live in a bungalow which suits my injuries as stairs would be a big struggle. We managed the payments but now we are borrowing from family to make payments. We are now up to 6.5%.
    Another weird finding, PTSB discharged our mortgage years ago (discovered this by mistake on our folio). So the instrument of burden is crossed out on my folio and I have since obtained the receipt to show it paid. Long story.
    We will have a balloon payment in 18 years that there’s no hope of paying. Any advice?
    Thanks

    Reply
    • Hi Lydia,
      It sounds like you have had your mortgage restructured potentially, so that a portion of it has been ‘warehoused’. This reduces your repayments, but also can make the repayments more sensitive to interest rate hikes as well as leaving the capital part to be paid off at the end. People with restructures have limited options to switch or fix or switch their mortgages, so it’s important to contact your lender if you are struggling to make your repayments and also talk to MABS about options such as a personal insolvency arrangement. Downsizing your home is also an option for some or if you are over sixty equity release through a lifetime loan can be an option. I’d definitely encourage you to explore all these options with a qualified financial advisor so you know which would suit your individual needs best. Hope that helps!

      Reply
  2. Hi Mark,
    I built my home in 2006 and remortgaged with KBC. After that agreed short restructure I asked if it would be possible to increase the term of the mortgage in order to reduce the monthly payment and make it more afordable. They agreed and also offered to put us on a reduced interest payment for 5 years of 0.5%. They said it would give us a chance to get back on our feet financially. We were delighted. Really nice to deal with. So at the end of the 5 year reduced interest rate (2021) KBC announced they were leaving the Irish market they allowed us to fix at 2.6% before selling us off to pepper. We have never missed a payment in 17 years on mortgage car, or any loan. We have 3 years remaining on our fixed rate, after that I’m afraid that it will be inevitable we will start going into arrears for the first time in our lives. I’ve tryed every lender but we are still too far off the lending criteria with a low wage and now 2 dependant children. Is insolvency likely to be our only option we can afford €1,000 a month, if it rises above that it’s a choice of food and heating/electric or defaulting on the mortgage.

    Reply
    • Hi, Unfortunately many people were caught in a similar trap to yourselves with bank staff who may of thought they were being helpful inadvertently leading you on the path to being trapped with the ‘vulture funds’. You may have options including a personal insolvency arrangement, but it’s worth having an appointment with an advisor first just to absolutely double check you can’t get a switch, you can book one here. Sometimes we are able to switch mortgage holders who have been refused previously as we know the policies and work with all the lenders, if we can’t switch you we will also give you advice on alternatives. I’ve dropped you a separate note so you can set up an appointment.
      Thanks,
      Mark

      Reply
  3. Hi Mark
    My situation is a difficult one. My husband and I took out a mortgage with Danske. We were later offered an interest only tracker to term. This was great while we were married and paying down investment property. Fast forward NIB took over and then Pepper. In the meantime my husband and I separated and he has left the country to reside in Australia. I am remaining in the family home with three dependent children. The judge awarded the home and interest in the home to me, with interest only payments at the time being 450 pm. Fast forward 6 months I’m paying 2K per month interest only with balloon payment due in 12 years. I am due back in court for divorce decree and judge will deal with house at that time but I would like to pay down capital as much as possible and now there appears no option. If I attempt to pay the mortgage down I am breaking contract. This mortgage has never been in arrears.

    Reply

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