RBI frowns on 80:20 housing loan schemes

RBI has advised banks that disbursal of housing loans sanctioned to individuals should be closely linked to the stages of construction of the housing project/houses and upfront disbursal should not be made in cases of
incomplete/under-construction/green field housing projects. While yesterday's notification talks only about banks, we believe that it will be applicable to nbfcs and housing finance companies as well.

• ICICI Bank said that such schemes are only ~2-3% of their total home loans.
• LICHF has said that they do not finance any such schemes as in their view these are akin to developer financing and they are not doing any developer financing at the moment.
• HDFC says that they sanction loans based only on the borrower's ability to may and all their disbursements are construction linked and they do not make upfront disbursements. HDFC had highlighted this as risk for the industry in their 2013 annual report.

RBI has issued a notification with reference to certain innovative housing loan schemes introduced by banks in association with developers/builders where in upfront disbursals are made of sanctioned individual housing loans to the builders without linking the disbursals to various stages of construction of housing project and / or interest/EMI on the housing loan availed of by the individual borrower is serviced by the builders during the construction period/specified period. These loan products are popularly known by various names like 80:20, 75:25 Schemes

Residential Sales Fall Across India

Tough macro finally appears to be taking a toll on demand for residential property, which has held up relatively well over the past 1-2 years. Residential property absorption in 11 key cities (Source: Propequity)
fell 10% YoY/ 20% QoQ in 1QFY14. The absorption had grown 7% in FY13. Commercial absorption in April-May 2013 fell 5% YoY (FY13 : -20% YoY)

Residential price rises continue due to high cost inflation and developers’ inability to cut prices. Residential prices are up 13% YoY / 1% QoQ in key cities. However, the All India House Price Index (Source: RBI), which is a more reliable but less comprehensive indicator, shows a 2.1% QoQ increase in residential prices in 4QFY13. This is the slowest pace of QoQ increase since 4QFY09 (except 3QFY11) and seems to be pointing to some cooling off in the pace of price rises at the margin. Commercial rentals remain flat YoY despite high inflation due to oversupply in most parts.

LoopHoles for Corruption in Real Estate Regulatory Bill of India

Atleast Half of the Members of Indian Parliamentary Democracy have Solid Criminal Background and Cases who are framing the Laws / Policies for the Civilized and Law Abiding Citizens. The Thugs in Indian Parliament stand united to overturn a Supreme Court Verdict banning Citizens with Criminal background from contesting in Elections. These Thugs are so united that they have left lot of holes in the Proposed Real estate Regulatory Bill and we highlight the same.

States have substantial leeway in deciding several key issues like the rate of interest payable by the developer, form and particulars of agreement, the details to be published and maintained on the regulator’s website, while the centre will only have an advisory role. This will lead to lack of consistency across states and dilute the power of the centre. [Give State Govt Money and they will make it favorable to Developers]

The bill has a provision of extension of delivery timelines of projects in case of delays. The developer is required to simply apply to the regulatory authority for the same. This provides the developers a leeway in delaying project deliveries. [Give Money and Seek Extension while leaving the Consumer at the Receiving End]

The bill has not stated the procedures and flexibility of changes in project plan post launches. Change in number of units or sizes are not dealt with in this act. The treatment of such changes is a key monitorable [Extortion from Builders by Political Thugs]

Though the mission of this Publication is to report on the Real Estate Developments in India, it is evident on How your Political Masters are functioning without any concern for the Citizen. So you decide who you should elect & who should frame laws for you, henceforth.

Provisions and Impact - Real Estate Regulatory Bill

The Real Estate (Regulation and Development) Bill of India, 2013 that was tabled in Rajya Sabha on 14th August, 2013 has been referred to a standing committee for discussion and review. Our analysis on the draft bill indicates that it is an important step forward to promote consumer awareness and bring in transparency.

 We do an Analysis on the Provisions and the Impact as below.

No developer shall offer area for sale in any real estate project, without registering the project with the Real Estate Regulatory Authority. Impact Ban on pre-launch sales will reduce the ability of the developer to accelerate cashflows and also undertake newer projects. Hence, it will lead to reduction in supply. It would also affect investor demand negatively.

Mandatory for a developer to maintain a separate bank account for every project to ensure that the money raised for a particular project is not diverted elsewhere. Developers would have to keep aside 70 percent, or below, as prescribed by the authority. Impact As the percent to be kept aside is to be prescribed by the concerned state authorities, it will vary on a state to state basis.

Developers will be barred from collecting money from buyers before obtaining all necessary permits to start construction on the project. Builders cannot take more than 10 percent of the advance from buyers without a written agreement. Impact As the 'written agreement ' is to be defined by the relevant states, the need of a registered agreement may be circumvented.

Bangalore - Mumbai Residential Trends

Bangalore 2QCY13 saw new launches momentum continue at ~10,000 units for the third consecutive qtr. Historically, annual launches in B’lore averaged at ~26,000 units in last 3 yrs. However, if the current launches momentum continues, CY13 might witness ~40,000 unit launches. With rising unsold inventory, we believe this can become a concern going forward. Developers are launching new projects purely aiming at cash inflows when liquidity is poor. Timely execution is questionable outside organized developers and we advise caution.

Bangalore residential sales growth is flattening and current spurt is purely fueled by new launches by unorganized developers at reasonable prices and rising investor interest. Although affordability and expected softening of mortgage rates in CY13/14 are positives; execution delays and rise in number of investors are potential dampeners.

Residential prices in Mumbai are finally correcting! Prices in new launch projects across the city are lower than market averages by 10%. Discounts are deeper in areas where prices quote above Rs30mn per unit. Our calculations show that discounts via 20:80 schemes equate to ~10-12% cut in total acquisition cost. The
10 Yr CAGR growth in Mumbai resi prices was 14.7% in 2011 which has come down to 13.5% now as prices have either remained flattish or fallen across micromarkets. We foresee prices to remain under pressure for next 5-6 quarters till the 0 Yr CAGR comes to more acceptable levels of 11-12%.

Gurgaon’s loss = Noida’s gain - NCR Realty Trends this Quarter

Although demand was ahead of new supply once again in Gurgaon, absorption rate softened further for 4th consecutive quarter in 2QCY13. We attribute this trend to rising prices through CY12; weakening consumer sentiments; 1H has been historically weaker than 2H and slowdown in new launches by developers. Despite considerable fall in absorption rate from peak of 25.5% in Q1CY12 to 20% in 2QCY13, developers have held prices in primary market. If this fall in demand continues over next 2-3 quarters (likely), we foresee price cuts in primary markets to resurrect sales and cash flows.

Our conversation with brokers reveals considerable price softening in secondary markets (up to 15%) in Gurgaon as projects launched in 2008-09 get delivered in 2013 and investors look at exits. This has exactly been our worry for Gurgaon ‘cause the city houses large investor base who will continue to seek exits through 2013 as projects launched in 2010-11 (50,000 units) advance towards completion. We believe only change in sentiments supported by mortgage rate cuts and price cuts can reverse this trend.

Noida sustained its rise in absorption rate from a low of 7% in Q3CY11 (farmer land agitation) to 14% in Q2CY13. uptick in execution by organized developers such as 3C, Mahagun, Jaypee, ATS etc. and rise in investor interest as Gurgaon slowed down. Noida across its sub-markets offers housing at 30-50% lower prices than corresponding sub-markets in Gurgaon. For example – Prime Gurgaon trades at Rs15k-18k per
sq ft whereas Noida trades at Rs10-13k per sq ft. New Gurgaon trades at Rs5k- 6k per sq ft whereas upcoming Noida trades at Rs3.5k-4k per sqft.

Noida will continue to witness far lower migration than Gurgaon leading to suppressed housing demand from end-users. Investor interest has risen purely due to its affordability as compared to Gurgaon and vicinity to Delhi. However, slow execution and slower than expected capital appreciation in prices will keep further rise in investor interest at bay. Market dynamics in Greater Noida is even worse compared to Noida.

Stubborn Mumbai Residential Price - Demand Affected

Residential prices in Mumbai continue to remain sticky.  Average prices are up by 49% since March 2010, which is higher than the national average increase of 41%, and are now 1.7X national average. We believe the price increase was on account of: (1) investor buying; (2) curtailed supply due to slower approval process

Sustained higher prices have led to lower affordability and consequently tepid demand. Volume absorption in March was lower by 25% yoy, while rolling 3-month average absorption has dropped by 15%. Recent absorption has fallen by 65% compared to peak level in Nov-2010. We estimate 15+% price correction is required in Mumbai to drive demand. 15% price correction along with lower interest rates/ marginal salary hike will improve affordability.

We have seen several developers offering structured schemes or reducing size of apartments (thus reducing ticket size) to boost sales. 20:80 subvention schemes are one of the most popular mechanisms to propel demand, in which the buyer has to make 20% upfront payment and balance after defined period/possession. Most developers are charging 2%- 3% higher prices on these schemes, but they offer customers an interest
savings of around 15% over a construction period of 3-4 years

Real Estate Regulation Bill - A Landmark Legislatio​n

Indian Cabinet today cleared the Real estate (Regulation & Development) bill.  This bill in our view is a land mark development and will necessitate wide business practice changes across the industry.

Key features of Real Estate Regulation and Development Bill

Project launch only after all approvals in place – It is mandatory for developers to launch projects only after acquiring all the statutory clearances from relevant authorities. Under its provisions all relevant clearances for real estate projects would have to be submitted to the regulator and also displayed on a website before starting the construction.

Sales only after sourcing of clearances- Under the proposed new law, developers will be able to sell property only after getting all necessary clearances.  Registrations of projects with the regulatory authority is a must. This means developers cannot offer any pre-launch sales without the regulatory approvals. Moreover the authority must approve or reject projects within 15 days

Project Escrow to be ensured- The bill seeks to make it mandatory for a developer to maintain a separate bank account for every project to ensure that the money raised for a particular project is not diverted elsewhere. Developers will have to keep aside 70% of the buyers’ funds in a separate bank account to ensure timely completion of projects.

Curb on Misleading advertisements-The proposed legislation has certain tough provisions to deter builders from putting out misleading advertisements related to the projects carrying photographs of actual site.

Written agreement a must- Developers cannot take more than 10% of the advance from buyers without a written agreement.

Tribunal setup in the interest of Consumers - The bill also seeks setting up of a real estate appellate tribunal for adjudicating disputes. The tribunal will be headed either by a sitting or a retired judge