Chapter 4

Chapter 4

The loans component

4.1        The second component of the Green Loans Program, the green loans after which the program was named, was cancelled by Minister Garrett on 19 February 2010 as a result, according to the Minister, of it being unpopular.[1]

4.2        Organisations representing the financial institutions which participated in the program noted various issues with the design of the loan product, a lack of consultation in the government's development of the program, as well as serious communication issues with DEWHA, which they argued contributed to problems with the operation of the loans aspect of the program. For example, Mr Mark Degotardi, Head of Public Affairs, Abacus Australian Mutuals (Abacus), commented:

Abacus believes that this program had both design and implementation issues and we remain disappointed with the performance of the Department of the Environment, Water, Heritage and the Arts in designing and administering the program.[2]

4.3        Furthermore, the evidence received by the committee with respect to various stakeholders' experience with the loans component of the program, does not correspond with the evidence that the committee received from householders, assessors and participating financial institutions, all of whom largely blamed the low uptake of loans on the slow return of assessments.

4.4        This chapter sets out the concerns of financial institutions and other submitters with the development of the green loans product; the issues experienced by participating financial institutions throughout the program; and evidence received by the committee regarding the experience of householders and financial institutions with the uptake of green loans.

The green loan product

4.5        Under the program, once a householder had received their home sustainability assessment report from DEWHA, they could apply to a participating financial institution for an interest free green loan of up to $10 000. According to DCCEE's submission, 'agreements existed with 24 financial institutions to cover payment of the interest and administrative costs of the loans, and for the financial institutions to report the loans approved'.[3]

4.6        The Australian Banking Association (ABA) and Abacus, which represent 23 of the 24 financial institutions involved in the program—two banks and 21 credit unions, mutual building societies and friendly societies respectively—each made submissions to the inquiry, and appeared before the committee at its public hearing.

4.7        Both organisations informed the committee that before the program commenced they had identified a range of design and implementation issues with the loans. These issues included:

4.8        Furthermore, the way the loans were set up, and specifically the fixed administration fee of $150 and fixed interest rate, required banks to absorb significant costs in managing the loans as well as carry the risk of the loan:

Financial Partners [were asked] to provide an unsecured loan at a large discount to usual unsecured rates, with no flexibility to alter the rates or charges. This meant that Financial Partners carried the additional risk and capital cost for the loans, which in hindsight considering later events, have borne out in terms of sovereign risk.[5]

4.9        With respect to the $150 administration fee, the ABA submitted:

At the time, banks indicated that the fee restrictions would result in a bank being required to absorb the additional administration and servicing costs. It was noted that loan origination and set up costs for all unsecured personal loans are fixed, which means these costs are more difficult to recover on small loans, even at current interest rates.[6]

4.10      The ABA thus explained:

The proposed loan subsidy model was based on a calculation being the cash rate plus 5% as specified by the Government. The subsidy amount provided to financial partners was 50% of the funds dispersed on each application. At the time, banks indicated that current interest rates for unsecured lending were in excess of this subsidy, implying that a bank would be required to carry the capital cost of the difference between the commercial rate available at the time and the loan subsidy.[7]

4.11      According to both Abacus and the ABA, these issues created a disincentive for financial institutions to become involved with the program.[8]

4.12      Both organisations told the committee that the issues with the structure of the loans could have been addressed had the government consulted with the lending industry prior to rolling out the program. Mr Steven Münchenberg, Chief Executive Officer, ABA stated:

...we believe the program would have been stronger if the government had consulted earlier with the banking industry on the structure of the program and the design of the product. It is possible to deliver government programs through the banking system, but this can only be done effectively if the industry is involved early in the product design.[9]

4.13      According to Mr Münchenberg, the ABA was consulted about the program 'belatedly', however by that point:

...more important design features of the program already appeared to have been settled upon and it would have been preferable to have had those discussions earlier, before decisions or assumptions were made by the government as to how the program and the product were to operate.[10]

4.14      Similarly, Mr Degotardi, Head of Public Affairs, Abacus, stated with respect to the consultation that they were involved in with DEWHA from September 2008 that 'we do not think that it was an effective consultation'.[11] Mr Degotardi further commented:

The view from our side of the consultation was that, while we had quite considerable experience as financial institutions—and that is only one perspective—that experience was not being considered.[12]

4.15      Mr Münchenberg explained that because of the government's lack of early consultation:

[W]hat was put on the table to us by the government really did not make a lot of commercial sense to the banks and we had to do a lot of work to make changes and modifications to enable the banks to deliver those loans.[13]

4.16      However, Mr Münchenberg continued:

In contrast, had the government come to us early on and said, 'This is overall what we would like to achieve. What products do you have that might already be suitable that can be quickly rolled out or that just need a few modifications?' then we would have been in a situation where we would have had both a commercial and a social incentive to provide those loans rather than a whole pile of difficulties to overcome before those loans could be provided.[14]

Lack of regulation of householders' use of loans

4.17      Submitters also raised concerns about the lack of regulation surrounding the loans portion of the program. Specifically, it was argued that as that there was no regulation or verification mechanism to ensure that loan funds were spent on improving the energy efficiency of households, there was no way of ensuring householders used the loans as intended.

4.18      For example, a householder who received an assessment but whose report was delayed by DEWHA, preventing him from obtaining a loan, submitted:

It is open to abuse as the householder decides how much is allocated to each eligible item. If ten items at your house were eligible, a person could decide to spend 100% of the loan on one item, such as “Install external shading for north facing windows”. There is nothing to stop a person building an elaborate $10,000 pergola over two windows. The item selected by the household could have been the least effective method of reducing the household energy costs on their list.[15]

4.19      Mr Jeff Wormald, an assessor from NSW, emphasised the need for verification of the green loan expenditure:

I would strongly suggest that as a minimum for checking and validation of the Green Loan spend, the Green Loan funds are only made available by way of bank cheque or electronic transfer direct to supplier or installer of energy efficiency technology and that in this way there is at least some accountability of the use of the Green Loan funds and some means of verification put in place as the funds are spent.[16]

4.20      According to DCCEE:

Applicants were required to sign a Green Loan Declaration that the loan funds received from the financial institution would only be used for eligible actions as identified in a valid assessment report.[17]

4.21      However, there was no mechanism in place to verify that householders had spent the loans amount in the manner in which they declared they would. Mr Münchenberg, Chief Executive Officer, ABA confirmed:

We are not aware that the banks took any role in confirming that customers had actually expended the money as they had indicated.[18]

4.22      Yet he noted, that it 'is not unusual' for there to be no checks on the way customers spend bank loans:

Even if we lend money to you to buy a car, we do not necessarily go around to make sure you actually bought a car.[19]

Financial partners' experience of the program

4.23      The majority (87.5 per cent) of the financial institutions involved in the program were credit unions, mutual building societies and friendly societies rather than banks. Abacus submits that these financial partners put significant resources into developing, complying with and marketing their products.[20] However, according to Abacus, its members had significant problems with their interactions with DEWHA during the course of the program, including:

4.24      Furthermore, Abacus submitted that a number of financial partners:

...were not paid for the loans they had provided for months, despite providing the necessary information to the Department. Abacus is advised that in most cases, institutions did not receive any of their funding between October 2009 and February 2010 when the loan component of the program was withdrawn.[22]

4.25      Mr Degotardi, Head of Public Affairs, Abacus, attributes some of this non‑payment to DEWHA's inadequate invoice payments system, and noted an instance where one financial partner 'was due an outstanding subsidy payment of over $1 million for its involvement'.[23]

4.26      The experience of the two banks involved in the program seems to have been identical:

There were ongoing issues at the time that the program ran. There were some technological problems with it [the program], which resulted in delays in the processing of applications.[24]

4.27      The lack of communication and consultation from DEWHA to its financial partners under the program is demonstrated by the fact that financial partners were not informed of the closure of the program until the day it was publicly announced. Both Abacus and the ABA informed the committee that they and their members first became aware of the cancellation of the loans portion of the program 'via media release that the involved banks and I [Ms Dianne Tate, Director, Financial Services, Corporations, Community, ABA] were provided with'.[25]

4.28      Mr Mark Degotardi, Head of Public Affairs, Abacus, commented that the 'unilateral way in which the program was withdrawn' along with the numerous other problems with the program experienced by financial partners meant that the program 'turned out to be a very disappointing engagement with the government'.[26] Mr Degotardi further stated:

It is also unlikely that participating institutions will be so keen to participate in partnerships in the future without more binding agreements on both parties.[27]

Cancellation of the loans

4.29      As noted above, the cancellation of the loans portion of the program was announced on 19 February 2010. Participating financial institutions were told to stop offering loans as of 22 March 2010.[28]

4.30      In announcing the cancellation of the loans, the then responsible Minister, the Hon Peter Garrett MP, stated that the loans had been a 'less popular component' of the program, and ceasing them would 'provide for the significant boost to assessment availability'.[29]

4.31      The submission from DCCEE echoed Minister Garrett's statements regarding the end of the green loans portion of the program, stating that:

This followed the low take-up of loans experienced to that date under the Program. As at 4 April 2010, participating financial institutions reported that 2,527 loans had been issued to householders.[30]

4.32      DCCEE outlined 'factors contributing to householders’ decisions in relation to the take-up of loans', which included:

4.33      However these statements by Minister Garrett and DCCEE do not accord with the experiences of householders and financial institutions who participated in the program. Stakeholders who discussed the issue unanimously commented that the loans were more popular than expected and blamed DEWHA's slow return of assessments for participating householder's inability to access loans.

The return of assessments to householders

4.34      Under the program, once an assessor had conducted a household assessment, they sent the electronic assessment report to DEWHA, which then sent an official copy of the assessment report to the householder. This official copy was required for the purposes of obtaining a green loan.

4.35      A significant number of assessors and participating householders commented on the time that it took for the DEWHA to return assessments to householders.[32] Assessors and householders suggested that this was a key reason for householders not being able to take up the loans. For example, Ms Dot Green, an assessor from Victoria submitted:

The majority of my clients were keen to obtain a Green Loan to implement the recommendations of the report generated from the assessment. However the official report was required to apply for the green loan, not one of my clients received the report from the Green Loans Scheme and they were therefore not able to apply...

The main reason stated for the termination of the green loans component of the scheme was lack of uptake of the green loans component of the scheme. Based on the experience of my clients I believe the Department was either not aware that the reports were not being sent, or conveniently ignored that fact in its public communications.[33]

4.36      This view was echoed by Mr Mark Walker, an assessor from NSW who submitted:

It appears from my own experience, contrary to Minister Garrett’s statement that the “loans were unpopular”, that this was, in fact, a popular component of the program.

The basis on which his statement appears to have been made is that, at the time of making the statement, only 1100-odd Green Loans had been approved and paid by the Department.

Yet the moment he announced the axing of the loan component, the financial institutions, individual assessors and assessor organisations were flooded with requests from householders who did not wish to miss out on the opportunity. Add to this the approx. 110,000 householders who had received an assessment but were yet to receive the Assessment Report, from the Department, enabling them to apply for a Green Loan, and the Minister’s statement is clearly fatuous at the least, if not actually disingenuous.[34]

4.37      These comments were corroborated by submissions from householders. One submitter who received an assessment in November 2009 informed the committee that they had repeatedly asked DEWHA for the assessment in order that they could obtain a loan, and did not receive it until March 2010.[35]

4.38      Another householder, Mr Bradley von Xanten, informed the committee that he received an assessment on 30 August 2009. He repeatedly followed up the report with the assessor and DEWHA until:

I contacted the relevant department in late October 2009. They stated that there had been a backlog however I should receive mine shortly. In mid November I contacted them again and they stated that they would place my name on a list of reports not yet received and that it would be escalated...

In late January 2010 I did manage to speak to a person and they again stated that she would place me on a list of reports not yet received and that it would be escalated...

Early February [2010] after listening and reading some media reports on the green loans scheme I contacted my assessor and voiced my concerns to him and that I was still waiting for the assessment report without which I was unable to access the green loans scheme. The assessor was kind enough to provide a copy of his report. I took his report to the bank and was successfull [sic] with the green loans application...

On 24 March 2010 I received the assessment report from the Department of the Environment, Water, Heritage and the Arts. The enveloppe [sic] was postdated 23 March 2010 [sic]. The report was an exact copy of the report that the assessor provided me with which was the report he forwarded on to the department on 31 August 2009. There was no covering letter or information letter with the assessment report.[36]

4.39      In summary, it took almost six months from the date of assessment for Mr von Xanten to receive his report from the Department, which was an exact copy of what the assessor had done. By the time he received his report, the green loans portion of the program had been discontinued.[37]

4.40      Mrs Patricia Smith[38] and Mr Brian Peters[39] recounted similar stories in their submissions.

4.41      The experience of participating financial institutions corroborates the views expressed by assessors and householders. In its submission, the ABA stated:

...adequate resources should also have been provided within the Department to deal with other program logistics, including addressing outstanding issues, implementing agreements with financial partners, and processing of loans (i.e. verification of assessment data).[40]

4.42      In fact, according to ABA's two members involved in the program, customer demand for the loans exceeded initial expectations:

...those banks that did ultimately make the investment in the product found that the uptake of the product was actually more than they had anticipated and there was clearly demand for the product as well...[41]

4.43      Similarly, Mr Mark Degotardi, Head of Public Affairs, Abacus, stated that the experience of Abacus members was that:

...there was strong consumer interest in the Green Loans Program. I think the fact that many people got assessments on their houses done is an indicator of that. We certainly had strong consumer interest at our financial institutions. It would appear to us, again, anecdotally, that the process of getting the assessments out was a major contributor to the lack of take-up.[42]

4.44      When asked why the government had taken such a long time to send audits back to householders, DCCEE officials explained that the delays were due to the contract between the government and the distributor, which was limited to dispatching 10 000–15 000 reports per week.[43] DCCEE did not check or value-add to the reports in any way.[44]

4.45      On 10 March 2010, Minister Wong 'aired the dirty laundry' on the Green Loans program when she made a comprehensive and damning ministerial statement about program in the Senate.[45] Included in the minister's speech was a revelation about the 'unacceptable' delays in sending out home assessment reports. The minister stated:

As at 28 February 2010, 305,327 home sustainability assessments had been booked and, of these, 210,864 had been completed. This is clearly a very popular element of the program. However, only around 84,000 reports produced as a result of those home sustainability assessments had been sent out to households as at 28 February 2010. There are currently around 100,000 reports that have been submitted to the Department of the Environment, Water, Heritage and the Arts but which had not yet been sent out to households at the time responsibility moved to the Department of Climate Change and Energy Efficiency. The remaining reports have not yet been submitted to the department by assessors following completion of the home sustainability assessment. The delay in sending reports is unacceptable...[46]

4.46      Mr Malcolm Thompson, Deputy Secretary, DCCEE informed the committee that the government had made significant progress in this area since the change of minister:

We are working to clear the backlog of home sustainability assessment reports, with over 170,000 reports dispatched to householders in May 2010. This brings the total number of assessment reports sent to households to around 280,000. New arrangements now aim to see assessment reports sent to households within 10 business days of being sent to the department by assessors.[47]

Committee comment

4.47      In the committee's view, the development and operation of the loans aspect of the Green Loans Program suffered from a severe lack of consultation by the government from beginning to end.

4.48      From the outset of the program, it is evident that the government did not pay sufficient regard to the views and experiences of its financial partners in designing the loans. This resulted in the loans component of the program having serious design flaws from the perspective of participating financial institutions, and discouraged many national lending institutions from participating in the program. In the committee's view, if the government intends to use private financial institutions to deliver a government program, it is essential to involve the private sector in a genuine consultation and take on board their views.

4.49      The government's lack of engagement with its financial partners was also evident throughout the operation of the program—in financial institutions' experience of not receiving payment; problems with departmental invoicing systems; and their difficulties in contacting DEWHA. The committee is greatly concerned that the financial sector's experience of the Green Loans Program will discourage financial institutions from becoming involved in future government programs.

4.50      Finally, the committee is appalled by the fact that the government did not consult with its financial partners and the industry bodies representing them, prior to announcing its decision to cancel the Green Loans Program. While the government has said the loans were cancelled due to being unpopular, this in no way accords with the experience of stakeholders under the program. By all accounts the loans were far more popular than anticipated.

4.51      Furthermore, any disparity between the popularity of household assessments and loan applications was, according to the unanimous view of stakeholders involved in the program, purely due to the government's own tardiness in providing household assessment reports to householders. Yet, instead of addressing this problem with its own systems and processes, the government unilaterally decided to cancel the loans.

4.52      This decision has left a great many individuals as well as a number of financial institutions in a significantly worse-off situation, simply because they chose to become involved in a government program.

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