TREBs Letter to the Mayor.

Dear Mayor Tory:
Given recent government and media attention to the issue of foreign investment in Toronto real estate, I am writing to provide you with the views of the Toronto Real Estate Board (TREB) on this issue. TREB represents over 45,000 REALTORS® working within Toronto and the Greater Toronto Area. As such, our Members are uniquely positioned to provide knowledgeable commentary on this issue. As you may know, this issue has predominantly been a priority for public policy makers in British Columbia and Ontario because of conditions in the Vancouver and Toronto markets. In this regard, the British Columbia provincial government recently implemented a 15 per cent tax on foreign buyers of real estate. In addition, the Ontario provincial government is working closely with the Federal Minister of Finance’s working group on housing affordability, which has been tasked with reviewing and making recommendations on this issue. TREB is working with the Ontario Real Estate Association to provide input to the provincial government and the federal working group. Given the importance of this issue to Toronto, we believe that it is also important to provide our views to you and all of City Council. In this regard, TREB believes that implementing tax increases on foreign home buyers is a knee-jerk reaction to a problem that is not yet fully understood. Furthermore, we believe that such action would do little to address the growing affordability challenges in Toronto, and could have negative consequences for our broader economy.

 For the following reasons, TREB believes that Toronto City Council should not implement public policy to intervene with foreign investment of Toronto real estate:  Toronto market is intertwined with the GTA market: any City of Toronto Council intervention could have the result of simply persuading foreign investment to invest more heavily in regions surrounding Toronto, which in turn could have a corresponding impact on housing prices in those regions, which would in turn have an impact on Toronto prices. As such, with the provincial and federal levels of government currently reviewing this issue, it would be wise for Toronto City Council to allow those levels of government to make decisions on the need and scope for any public policy changes.  There is a lack of reliable data on foreign buyers: Both at the provincial and federal levels, there is currently a dearth of reliable data on how much of the market foreign buyers actually make up. Before making any public policy decisions, it would be prudent to gather reliable data. In this regard, TREB will be surveying its members in the Fall on the issue of foreign buyers, and releasing the results of this publicly. These survey results could be extremely valuable to the all levels of government before they make any policy decisions on this issue.  Housing supply factors are a real concern: while foreign buyers may be contributing to the overall pool of buyers in the GTA, the demand side of the price growth equation should not be considered in a vacuum. Instead, both demand and supply issues should be considered as contributors to the growing affordability challenge. Of particular importance is what could be done at the local and provincial levels to bring more supply into the marketplace. For example:  Reassess Growth Plan and Greenbelt policies with a goal of responsibly easing restrictions on developable land in the GTA and surrounding areas;  Look at whether or not the Provincial Policy Statement, as it relates to a ready and diverse supply of housing alternatives, is being enforced;  Look at opportunities to re-designate lands within urban areas for low-rise housing development; and,  Reduce, reform or eliminate barriers to the purchase and sale of residential real estate like the Toronto Land Transfer Tax, which, as a significant transaction-related cost, has acted as a barrier to mobility and has thereby played a part in suppressing the number of existing homes being offered for sale. Looking at the GTA in particular, we remain on track for approximately 110,000 residential sales (including condominium apartments) through TREB’s MLS® System in 2016. This second consecutive record sales year will be up against 150,000 to 160,000 new listings – a decline compared to 2015. This illustrates the amount of competition between buyers that currently exists in the marketplace today, which has prompted double-digit annual increases in low-rise home prices (MLS® Home Price Index and average prices) and high single-digit increases in condominium apartment prices. With this in mind, even if a demand-focused policy were to reduce sales by between five and ten per cent, we would still experience seller’s market conditions in the GTA, quite possibly with the continuation of double digit price increases for low-rise home types. As discussed above, the only sustainable way to bring about more balance, and thereby more moderate annual rates of price growth, in the marketplace would be to develop new or modify existing policies to allow for a greater supply of listings. At current sales levels, we would need to see approximately 200,000 to 210,000 new listings per year to achieve a balanced market, based on historic norms. This would require an additional 50,000 to 60,000 new listings per year. On the demand side we also encourage the City Council and the province to consider actions targeted at the segment of the market that is being hurt the most by rising prices – first time buyers. For example, the City should consider modernizing the land transfer tax rebate for first time buyers to reflect modern housing prices. In 2008, when the Toronto land transfer tax was introduced, Toronto first time home buyers paid little or no tax on the average priced home. Eight years later, Toronto first time home buyers purchasing an average priced home are paying a balance of close to $6,000 in Municipal Land Transfer Tax, after receiving the maximum City rebate of $3,725, which has not been adjusted since this tax was implemented. In addition, the City continues to levy the highest land transfer tax of 2 percent on properties beginning at $400,000, which is well below the current average price of a Toronto home, which currently sits at almost $700,000. In summary, we encourage Toronto City Council to take careful and thoughtful consideration of all aspects of this issue before any potential action to intervene. Thank-you for your consideration of our views. We would be happy to meet with you to discuss this issue in greater detail. Mauro Ritacca, TREB’s Senior Manager of Government Relations, will contact your office in the near future to inquire about meeting with you on this issue.