A Deep Dive into the NCCP’s Required Comparison Rates
Commonwealth legislation requires that for every home, car or personal loan advertised, a comparison rate has to be quoted. But lenders also have to include a warning about the accuracy of the comparison rate.
Comparison rates were originally introduced as part of the Uniform Consumer Credit Code in 1994. The UCCC has since been replaced by the National Credit Protection Act (NCCP) which includes the National Credit Code (NCC) as Schedule 1 to the NCCP. Comparison rates are set out in Part 10 of the NCC. Compliance with the provisions of the NCCP are governed by ASIC (Australian Securities and Investment Commission).
As ASIC says on its own website, ‘The comparison rate includes: the interest rate and most fees and charges’. It goes on to say, ‘A comparison rate does not include all fees and charges. For example, the comparison rate does not include: government fees and charges (such as stamp duty and mortgage registration fees) and charges that are only charged in certain circumstances (such as early repayment fees and redraw fees), for example if you pay off the loan early.’ And in wrapping this explanation up, ASIC says, ‘The comparison rate only allows comparison based on cost, and will not include other factors that may make a loan more attractive, such as access to fee free accounts or flexible repayments arrangements.’
CBA also goes on to say a comparison rate does not include ‘cost savings such as fee waivers or the availability of interest offset arrangements which can influence the cost of a loan.’ And Finder.com.au adds in late payment fees, deferred establishment fees and conveyancing fees.
After reading this, it’s fair to ask:, ‘Is a comparison rate useful?’ That depends on what you want to achieve and how relevant the data is on which the comparison rate is based.
Features of the Required Comparison Rate
– The Government’s comparison rate is based upon a loan amount of $150,000 and a loan term of 25 years.
– The comparison rate takes into account:
> The interest rate includes any ‘revert to’ rate which applies to the loan after a set period.
> Fees and charges including upfront costs like establishment fees and valuation fees, and ongoing costs such as monthly or annual fees.
> Repayment frequency.
– You can calculate your own comparison rate but to do so, you will need the following information and preferably, a comparison rate calculator:
> Loan amount
> Loan term
> Repayment frequency
> Interest rate
> Monthly account fee (if any)
> Annual fee (if any)
> Establishment fee (if any)
> Valuation fee (if any)
> Mortgage documentation fee (if any)
> Settlement fee
Pros of the comparison rate
– It ensures lenders cannot completely hide all ‘hidden fees and charges’. In this sense, it is a good guide for borrowers.
– Because comparison rates take into account fees and charges as set out above, the rate of interest tends to be higher than the quoted interest rate which excludes fees and charges.
Cons of the comparison rate
– It does not reflect the actual comparison rate for your loan – unless of course your loan is for $150K over 25 years.
– It does not reflect the impact on the quoted interest rate provided by most lenders for most home loans as most home loans are well above $150K (the average Australia-wide was approximately $450K in December 2019.)
– As most fees and charges are fixed in nature, at the loan value of $150K, the impact on the interest rate would be significantly higher compared to, say, a $750K loan. On a straight comparative basis, the impact on the interest rate for the $750K loan would be one fifth of that calculated on the $150K comparative rate loan.
– If your home loan is not for 25 years, the comparison may become less relevant.
– Comparison rates are useful indicators but should not be used in isolation for all the reasons identified above.
– Do your own research before you proceed to ensure you understand all the costs a lender will charge you.
– Use a broker to do the hard work for you! Brokers have software which can show you the total cost of a loan over the life of the loan and also over shorter periods (eg the first five years of a loan). This can be very useful as you might be contemplating refinancing or moving well before your loan term expires.
 CBA – ibid
 CBA – ibid