debt, but for our home-lending institutions, as well.

The

Subcommittee is familiar I'm sure,

with the extreme financial

difficulties faced by thrift institutions in recent years.

One-fourth of the net worth of savings and loan associations

accumulated over half a century

-

disappeared in just two

years; industry-wide, our associations lost $4.6 billion in

1981, and despite improving conditions in the fourth

quarter, another negative $4.3 billion in 1982.

Over 800

institutions either closed their doors or were merged out of

existence in the course of the thrift crisis.

If interest rates remain relatively stable at today's

levels for the remainder of 1983, our researchers forecast a

"break-even" first-half with a slightly positive, perhaps $700

million, result for the year.

We remain apprehensive about the

interest-rate outlook

particularly since nearly one-fourth

of our deposits have been converted since the first of this

year to the immensely popular Money Market Deposit and Super

NOW accounts.

While the deposit inflows are welcome, we

recognize that this is high-cost, current market-rate,

potentially-volatile, money.

It is, in effect, day-in day-out

money, which could leave in pursuit of other investment

opportunities if Wall Street rates should start to climb again

dramatically.

Though we now have the deposit products to compete with the

money markets, we remain handicapped by the legacy of

portfolios filled with low-yielding mortgage loans.

Eventually, with the broader asset powers provided by the last

Congress in the Garn-St Germain Depository Institutions Act of

1982 and increasing acceptance of adjustable-rate mortgage

loans, we should be able to restructure these portfolios.

But,

at the present time, we must continue to live with some very

sobering statistics:

55 percent of our mortgages on the books

earn less than 10%, and 30 percent are under 9%.

Many of these

loans have 20 or 25 years left until maturity.

Only 19% of our

portfolio mortgage loans are above the current market, which is

about 12.5% nationwide.

Overall, our portfolio yield today is 10.6%.

At the

present time our cost of money is a little over 9.6%, giving us

an operating "spread" of less than 1%.

While this is a vast

improvement over the negative spread of 1.1% at this time a

year ago, this is not enough to compete effectively and rebuild

net worth.

It is far below the historical 1.75% spread between

yield on investments and cost of funds under which our institutions operated successfully for decades.

One approach to our low-yielding loan problem, of course,

is to package and sell loans to investors.

This is not easy to

do, especially in periods of rapidly- rising interest rates.

And, just as our customers are attracted today by the

highly-liquid short-term Money Market Deposit Accounts,

investors generally prefer liquid short-term investments

not

long-term mortgages

in times of economic uncertainty.

Another approach is a "self-help" program where thrift

institutions make it attractive for existing long-term

borrowers to pay off their loans before maturity, so that they

might own their home "free and clear" of debt.

Since

homeowners recognize that they can invest their disposable

income in many other ways, our institutions must offer

substantial "discounts" to appeal to those interested in

fulfilling their loan obligations early.

The loss of the

mortgage interest deduction for the taxpayer is also a

consideration in the calculation.

In periods of high market

interest rates the discount must, of course, be proportionately

larger to induce the borrower to relinquish the mortgage.

From the point of view of the lender and the housing

market, early pay-off has another important benefit. It provides

fresh funds for lending to other home buyers.

This is

particularly important in the periods of rapidly rising rates generally, when deposit flows to traditional hometown

institutions are in jeopardy.

Funds generated by early

retirement of mortgage debt of existing borrowers can be an

important factor in keeping a local mortgage market functioning.

The position taken by the IRS in Revenue Ruling 82-202 is a

new barrier to encouraging early pay-off of mortgage debt by

existing borrowers, particularly those with older, low-yielding

rates, early pay-off activity may be relatively modest.

But,

when rates skyrocket in the future, this legislation could

provide important benefits for home borrowers, mortgage lending

institutions, and the entire housing sector of our nation's

economy

Before concluding, I would like to make one observation

about the revenue impact of this legislation.

While we are not

aware at this writing of the Treasury's views, we would remind

the Subcommittee that encouraging pay-off of mortgage debt

involves some compensating revenue gain for the tax collector. The Treasury will gain some revenue through mortgage interest

deductions no longer claimed by these home borrowers.

That

will moderate the revenue sacrificed uner s. 1147 if ordinary

income is not immediately recognized on discounts as it would

be under a strict application of Revenue Ruling 82-202.

Mr. Chairman, the U.S. League wholeheartedly supports s.

1147, the Mortgage Debt Forgiveness Tax Act of 1983.

We

encourage this distinguished Subcommittee and the Congress to process this worthwhile improvement in our tax code as soon as

possible.

I have appreciated this opportunity to present the views of

the U.S. League and look forward to your questions.

###

STATEMENT OF KEITH G. WILLOUGHBY, PRESIDENT, MUTUAL

BANK FOR SAVINGS, ON BEHALF OF THE NATIONAL ASSOCI. ATION OF MUTUAL SAVINGS BANKS, NEW YORK, N.Y.

Mr. WILLOUGHBY. Mr. Chairman, my name is Keith Willoughby. I am president of the Mutual Bank in Boston, Mass. I am here this morning representing the National Association of Mutual Savings Banks. We, too, greatly appreciate the initiative by you and Senator Tsongas in introducing S. 1147. We hope it will be successful. We would, however, propose that a more effective approach than the adjusted tax basis of the property would be one of complete forgiveness. I speak from some experience inasmuch as the institution

represent-that is, the Mutual Bank-did take advantage of Dave Cramer's program and we did have some of the reactions that he expressed.

We feel that no matter how conjectural or how far in the future that taxability of the discount may be, it still is going to be an impediment to those who are seeking to prepay their mortgages. Many of these people are middle aged, and for them the possible sale of their home is close at hand rather than far in the future. For anyone, as Mr. Pitt pointed out, there is a sacrifice of flexibility in terms of the future monthly payments that they would have to make, as well as giving up control of their funds. Consequently, the discount has to be greater in terms of its current value than what they believe they might earn at some point in the future. In the case of my institution, in order to get a response that was better than average I think it turned out to be the second best, Nation-wide, of the clients of Dave Cramer's organization—we had to offer a 13 percent effective rate to those who were prepaying their mortgages. This was at a time when our customers could not have put their money to work at a rate of 13 percent. In spite of that, the conversion rate that we had was only 11 percent of our mortgagors. That simply is not enough to have a meaningful impact on our assets structure.

Beyond that, to the extent that the cost of a program of this sort can be minimized in light of the already depleted capital positions in the industry as a whole, the impact on our capital position is reduced. This means that the day in which we might recover fully is hastened.

The Treasury's position on this, as I understand it, is one of just deferring the tax. We submit that this is an instance where subjecting the discount to the tax in effect shrinks the revenue base almost to the point of disappearing. In other words, it is the ultimate Laffer curve. If the discounts are tax free, it is not going to have any material impact on the Treasury's revenues in any case. In fact, I think the Treasury concedes that for most people the $125,000 exclusion for those over 55 means that even at some point in the future they won't be taxable.

Beyond that, as Mr. Cramer pointed out, this will reduce a major tax expenditure—the mortgage interest deduction-and in future years will thereby increase the Treasury's revenues. Finally, it will help to put our industry back into a fully taxable position at some point in the relatively near future, and will provide funds for housing that would not otherwise be available.