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> I f the bank has a loan on the books that’s being paid-as-agreed and is in compliance with the agreed ratios, it's not at all clear to me that there's been an
by User23 5y ago
> I f the bank has a loan on the books that’s being paid-as-agreed and is in compliance with the agreed ratios, it's not at all clear to me that there's been an underwriting mistake and consequently I don't think that giving them the power to foreclose is in the public or borrower’s interests.
This view is implicitly premised on the notion that banks exist purely to make a profit. I take the view that banking licenses are issued by the government representing the public and that licensees should act in a way that benefits the community in which they are licensed to operate. Using a dishonest valuation scheme that blights urban commercial districts violates that public purpose. I have no strong opinion on how the lender and borrower ought to work out the costs of accepting reality, and I acknowledge that it probably needs to be handled with finer granularity than some blanket policy.
- sokoloff 5y agoThe question remains "how [and when] do we determine that this specific property is being valued dishonestly?" If commercial property commonly has 2 year vacancies (as a matter of the inherent friction in finding a user who needs exactly that amount/mix/configuration of space), how does one determine that 123 Commercial St that's been vacant for 9, 12, 15, or even 30 months is being incorrectly valued or valued at less than the bank's note? It sounds to me like you're perhaps pulling on the wrong rope. If your concern is encouraging occupancy, go directly to policies that encourage occupancy rather than concluding that this is banking problem at its root. Maybe it is; maybe it isn't, but rather than trying to puppeteer an outcome by tweaking something in banking, there might be more direct policy frameworks that would help more.
- User23 5y agoThis is circular reasoning. These multi-year vacancies exist precisely because the present regime encourages it. One determines the appropriate vacancy rate and then tunes the regulatory framework to remove barriers to achieving that public purpose. The most direct policy framework would be wielding the sledgehammer that is eminent domain. However, I think government should use the lightest touch possible to achieve the public purpose, so I’d prefer setting the rules in a way that maximizes freedom while still achieving the public purpose of having non-blighted commercial districts.
- sokoloff 5y agoIt’s not just banking ratios that cause this behavior, though, but rather in part the owners of commercial property, often let out for 5 year terms with 2 5-year renewal options, who don’t want to be too quick to lower their rental base for possibly 15 years for a 1-2 year recession. Property with no bank note on it would behave the same way. (It’s just exceedingly rare, especially in an easy-borrowing, money-printing presses running environment.