CHAPTER 5

INVESTMENT OF AUSTRALIA'S SUPERANNUATION SAVINGS
CONTENTS

CHAPTER 5

SUPER FOR HOUSING

5.1 The Committee is required to report on the implications of the enormous growth in superannuation fund assets in Australia for housing finance. It has considered two aspects of this question: investment in rental housing and public housing stock by super funds; and the drawdown of an individual's super funds to assist with the purchase of a home.

 

Investment in housing infrastructure

5.2 Typically, super funds have not invested directly in residential housing, probably because of its low unit cost and high administrative requirements. If super funds could be encouraged to do so, then a flexibility in the supply of public housing could be introduced. This is not necessarily to suggest that more housing is required, but that the private rather than the public sector build it, thus freeing up government money for other uses. The Department of Social Security (DSS) has advised the Committee of the Commonwealth's support for private investment in public rental housing. [1]

5.3 Super funds will diversify their assets in order to reduce risk. Housing can be part of this diversification if it can be packaged in such a way as to provide the kind of returns that would attract super funds. Investment in residential property may also help reduce volatility in a portfolio.

5.4 A project in housing could appeal to a super fund if the return was higher than the typically benchmarked return on government bonds, for example. It may be that housing projects could be packaged as some recent road projects have been, where securities have been listed on the stock exchange. The Committee was told that they had been readily accepted by investors and that there was a huge untapped market for such projects. Of course, the usual difficulties with infrastructure projects, such as the long gestation period, would have to be taken into account.

5.5 The bond market provides another avenue. If a project were to be structured in such a way that there was a tradeable debt instrument rather than bank debt, a super fund would be able to invest and still maintain liquidity. [2]

5.6 Examples of private involvement in public housing in New South Wales include the PEP (Public Equity Participation) Schemes I and II. Under these schemes, AMP purchased dwellings in Sydney which were then leased to the NSW Department of Housing. [3]

5.7 In the first scheme, AMP provided initial capital to fund the acquisition of 1 000 dwellings which were let to public housing tenants. The homes were leased to the NSW Department of Housing on a guaranteed inflation-linked rental and guaranteed re-purchase after twenty-one years. The Department of Housing assumed maintenance and management responsibility. The Department and AMP share in any capital gain in the houses over and above the compounded inflation rate. The overall cost to the NSW government was a one-off payment used to subsidise the difference between the investor yield required and net rental income.

5.8 The second project took the form of an extension of the first, involving again a one-off payment by government.AMP has also invested $100 million in a single placement of state government guaranteed Victorian housing bonds, designed to provide housing for low income families. [4]

5.9 These examples indicate one way housing can be 'packaged' into something that may appeal to super funds, provided returns are within the desirable parameters. AMP, however, has submitted that its analysis of such investments indicates that residential real estate is the least attractive of all the property classes for institutional investors, with other, alternative investments in infrastructure providing substantially higher returns. AMP has said that expectations of the returns and terms acceptable to attract institutional investors in social housing are 'extremely optimistic'. [5]

5.10 The Committee notes differing views about what investment in social housing infrastructure can offer the institutional investor. It is not in a position to prefer one view over another. In so far as superannuation funds are concerned, that is the task of trustees and their investment managers.

5.11 Lack of certainty about the taxation treatment of investment in housing has caused the private sector difficulty. Section 51AD and Division 16D of the Tax Act, designed to deal with leasing arrangements with tax exempt entities, operate to deny normal business deductions to a private sector owner of property who has entered into a lease arrangement with a tax exempt entity such as a government, the Committee has been told. [6]

5.12 Mr Campbell, Director, Infrastructure Finance, Fay Richwhite Australia Ltd, said:

5.13 The Committee considered whether some kind of investment allowance or special tax arrangement would be useful as a means of encouraging super funds to invest in housing. Mr Campbell noted 'an obscure section of the tax act which allows an investment allowance for short term traveller accommodation' and suggested that a similar type of proposal might work in relation to housing. [8]

5.14 Mr Campbell made it clear that, in his view, his proposal for super fund investment in public housing infrastructure was viable without so-called tax concessions, as long as the law was clarified to establish that the funds could be entitled to the same sorts of deductions that personal investors would be entitled to if they were to invest in residential property. [9] To the extent that the law is unclear in this way, the development of worthwhile projects could be hindered.

5.15 The Committee recommended in chapter 3 that the government review the intent and operation of the infrastructure borrowings concessions and clarify the position. It believes this recommendation meets the concerns that have been raised by Mr Campbell. It does not believe that investment in housing infrastructure calls for any further special consideration.

 

Home purchase assistance

5.16 From time to time, calls are made for the use of individuals' superannuation monies to assist with a home purchase. In the 1993 election campaign, both of the major parties put forward proposals to allow the use of superannuation funds to finance the purchase of housing by members. [10]

5.17 In October 1995, the Australian Democrats expressed support for a limited drawdown of super funds for low to middle income earners to assist with home purchase. [11]

5.18 More recently, the government in its pre 1996 election Housing Policy Statement, said it was attracted to allowing first home buyers to withdraw a portion of their superannuation contributions towards the cost of a deposit on their first home. The Committee understands that steps are currently underway to examine the implementation of this proposal. [12]

5.19 In its report Super for Housing [13] the Committee proceeded cautiously, noting many of the pitfalls inherent in such a proposal and advocating further investigation if such a scheme were to be set up. It concluded that any such scheme would have to be tightly targeted.In this inquiry, the Committee received a number of submissions claiming there was little justification for the introduction of a scheme whereby super funds could be drawn down and used for the purchase of a home. These included submissions from the Life Investment and Superannuation Association of Australia Inc (LISA) and the Association of Superannuation Funds of Australia Limited (ASFA). [14]

5.20 A number of reasons are put forward in support of this position. Arguably, Australia does not need greater investment in housing. It already has one of the highest percentages of home ownership in the world, with around 70% of Australians living in owner occupied dwellings. Lower interest rates mean that home affordability [15] has increased and home accessibility [16] has also improved in recent years. In addition, home ownership receives favourable tax treatment, for example in relation to capital gains tax.Allowing access to superannuation for housing is more likely to increase the average size or quality of dwellings (or allow people to increase current consumption, with lower mortgage payments) than the rate of home ownership. Thus additional investment in housing would be equivalent to consumption rather than adding to the productive capacity of the economy. [17]

5.21 Superannuants are already able to access their super contributions in situations of hardship. Hardship may include a case where a person may lose his or her home if mortgage repayments cannot be met. In 1994-95, the ISC received 39 680 hardship applications, 82% of which were accepted in full and 9% of which were accepted in part. [18] Many of these related to housing. [19]

5.22 Average balances per fund member tend to be small - the Committee has been told in the past that it would be some time in the next century before the average account member balance was as high as $10 000 [20] - and proposals for the draw down of super monies for housing have always only related to a portion of those monies. Yet it is usually a minimum of 10% of the purchase price that is required as a deposit on a home purchase. Based on home loan figures for 1994-95, the average deposit required would be at least $7-9000. [21] It is likely that those who would be most in need of assistance for the purchase of a home would be those most unlikely to have sufficient super monies to draw down to assist.

5.23 It is undeniable that home ownership contributes to security in retirement and that pensioners owning their own homes require less taxpayer support than renters. Home ownership may be seen as an alternative form of saving, as a source of security in later life, and as an opportunity to avoid the payment of rent. Home ownership is an important component of retirement needs, then, but it is not a substitute for income support, and comes at a cost to public saving:

5.24 There would also be an adverse impact on a member's end benefit, perhaps out of proportion to the relatively small withdrawal that might have been made, because of the compound effect on the account of the interest forgone. It is difficult to estimate the effect on the overall level of superannuation funds if a 'super for housing' proposal were to be put in place. While it might be small initially, when few people could be expected to have sufficient super monies to draw down, the long term effects could be considerable, with a consequent increase in uptake of publicly funded pensions in addition to a reduced pool of national savings.

 

The ACTU/National Mutual scheme

5.25 The Committee notes the continuing success of the ACTU/National Mutual Super Members' Home Loans (SMHL) scheme, set up in 1994, and of other schemes that have adopted the practice of mortgage securitisation. Securitised funding and lending operate on smaller overheads and therefore assist more competitive housing finance. They do not require a base of equity capital as do the traditional lending institutions like banks and building societies, for example, and are not subject to prudential requirements for capital backing for funds raised from mortgage-backed securities. [23]

5.26 Through the SMHL scheme, home loans are available to members of funds which invest in a trust managed by National Mutual Funds Management. Eighty funds have invested in the scheme, allowing some 4 million people access to loans. The first loan was settled in August 1994 and over 7 000 people have applied for more than $700 million in home loans since the commencement of the scheme.

5.27 The SMHL rate is currently 8.3%, having decreased from 8.7% mid September 1996. These rates are among the most competitive available. Schemes such as SMHL have increased competition in the home loan market generally, so that borrowers generally have benefited from lower rates, at the same time preserving their superannuation benefits for retirement.

5.28 The Committee notes predictions that within 2-5 years, 25% of new lending for housing will be funded from securitised mortgages. In the United States, for example, mortgage companies represented 56.4% of the market in the last quarter of 1995 compared with 23.5% for the commercial banks and 15.7% for savings and loans institutions. Already mortgage managers, as opposed to the traditional lenders, have shown strong penetration of the home lending market in Australia. [24]

5.29 It appears there are generally no substantial regulatory impediments to the operation and development of mortgage securitisation, although there are suggestions that the introduction of the Uniform Consumer Credit Code (UCCC) in November 1996 might influence lenders to act more conservatively. DSS has advised that discussions between state authorities and industry bodies have been progressing towards ironing out technical details. [25] The Committee considers that the implementation of the UCCC should be monitored so that any difficulties can be resolved at an early stage.

 

Conclusion

5.30 The Committee does not consider that the arguments in favour of a 'super for housing' initiative outweigh the arguments against such a proposal. Indeed, arguments in favour tend now to have been somewhat diminished by the relatively recent introduction and proliferation of securitisation schemes, compared with the appeal they have had in the past.It is the Committee's firm view that super funds must continue to be principally for the purpose of funding retirement income. They are not a source of funds to cover the range of contingencies that might arise from time to time in the course of a fund member's life. To the extent that genuine hardship arises, the ISC is already empowered to deal with it, and does so.Home loan schemes such as the ACTU/National Mutual scheme, however, are an innovative and practical way of using super funds to help with home purchase. They are able to facilitate home ownership without jeopardising the fundamental role of super funds to provide retirement income. Given the Australian situation of generally high levels of home ownership, affordability and accessibility, it is the Committee's view that such schemes are the preferred approach to assisting with home purchase, should a fund wish to invest in that way.

 

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Footnotes

[1] Submission SI-20, p27.

[2] Evidence (Mr Campbell), ppS61-2.

[3] Details of the projects are taken from submission SI-20 (Department of Social Security), pp28-9.

[4] Submission SI-15, p17.

[5] Submission SI-15, p17.

[6] Evidence (Mr Campbell), ppS58-9. (These provisions were examined in more detail in chapter 3.)

[7] Evidence, pS59.

[8] Evidence, pS59. The Committee has assumed reference was being made to Division 10C of the Tax Act.

[9] Evidence, ppS60-1.

[10] See Twelfth Report of the Senate Select Committee on Superannuation, Super for Housing, May 1994 (henceforth Super for Housing), pp1-3.

[11] See submission SI-14, attachment 4.

[12] Submission SI-20, para 5.3.

[13] Twelfth Report, May 1994.

[14] Submissions SI-14 (see especially attachment 4) and SI-11.

[15] The relationship between median weekly family income and average monthly home loan repayments on new loans, or the ability to meet ongoing mortgage repayments.

[16] The ratio of deposit gap to annual income, or the cost of becoming a home owner.

[17] Fitzgerald, VW, National Saving - A Report to the Treasurer, June 1993, p61.

[18] Insurance and Superannuation Commission, Annual Report 1994-95, p75.

[19] The Committee has previously been told that the 'most common ground' on which the ISC releases super monies relates to housing. See the Committee's Twelfth Report, Super for Housing, para 4.30.

[20] Evidence to the Committee in Canberra on 25 February 1994 by Mr P Roberts, then Chief Executive Officer of the Real Estate Institute of Australia.

[21] Submission SI-14, attachment 4.

[22] Fitzgerald, VW, National Saving - A Report to the Treasurer, June 1993, p61.

[23] Submission SI-20 (DSS), para 4.1.

[24] Submission SI-20 (DSS), para 4.2.

[25] Submission SI-20 (DSS), para 4.6.