Memorandum by Michael Mortimer MRICS (DHB
25)
1.1 INTRODUCTION
The following are submitted for consideration
by the Select Committee, with the hope that they may be of assistance
to the Committee's inquiry into the draft Housing Bill. More detailed
information can be made available from research papers and calculations
which we have prepared. Abstracts from some of the papers have
been submitted as part of the formal consultation process into
the Bill.
1.2 PART 1—HOUSING
CONDITIONS
Although the old fitness tests might have been
regarded as being very subjective, are the new hazard categorisations
with their numerical scoring methods going to be an over complication?
It appears quite difficult to assess the impact of these provisions
without the inclusion of the actual hazard rating classification
into this primary legislation.
1.3 PARTS 3 &
4—SELECTIVE LICENSING
AND ADDITIONAL
CONTROLS
Surely if housing problems exist, Local Housing
Authorities should be empowered to take action regardless of housing
demand. As many tenanted housing problems can emanate from the
actions of tenants, could be an appropriate time to consider additional
provisions for "a register of bad tenants".
1.4 PART 5—HOME
INFORMATION PACKS
Although there appears to be industry wide support
for any proposals to improve the process of buying and selling
a home, I, along with others, have major reservations as to whether
the Home Information Pack proposals are the best solution to a
problem which arises out of the very complex and fragmented nature
of the housing market.
1.4.1 Home Information Packs will add at
least £650 million per annum to home selling costs or £505
per transaction. In the partial Impact Assessment which accompanies
the Draft Bill, it is stated that "the total cost of assembling
the Home Information Pack would be around £1.33 billion [per
annum] if, as now, two million homes were marketed each year".
We have calculated that the necessity to include a Home Condition
Report and some other items within the Home Information Pack will
add at least £650 million per annum, in real terms, to home
selling costs in England and Wales. Our calculations can be borne
out by figures published by the ODPM as a result of the Bristol
Trial whereby it was stated that "selling costs would rise
from 1.9% to 2.3%" of the resultant sale price or on average
£505 per transaction.
1.4.2 The Costs of Home Information Packs
appear to far outweigh the benefits. In the most recent issue
of the Cabinet Office's Guide to Regulatory Impact Assessment
(January 2003), it is stated that Government Departments should
consider alternatives to legislation if "the costs of Government
action are greater than the costs imposed by the problem it is
designed to correct." Best estimates from the ODPM suggest
that the hypothetical savings attributable to the introduction
of Home Information Packs would be £350 million per annum.
We have calculated that this hypothetical saving when taken away
from actual additional costs products a net additional cost of
at least £300 million per year to consumers. When this is
coupled with the estimated costs of implementing the legislation
on the property industry, a net total additional cost of £380
million is derived.
1.4.3 Home Information Pack legislation
appears premature when electronic conveyancing and other IT based
infrastructures might not be fully available until the end of
the decade. The ODPM has stated that "Electronic conveyancing
will complement our proposals for Home Information Packs. Home
Information Packs will ensure that important information is provided
up front at the very start, and electronic conveyancing will speed
up the conveyancing process thereafter." The Land Registry
has embarked on massive change to make electronic conveyancing
possible. The scale and extent of the change can be illustrated
by an extract from a Report to the Prime Minister, which was prepared
by Patricia Hewitt, the e-Minister and Andrew Pinder, the E-Envoy
in April 2002—"The aim is to introduce, over the next
five to 10 years, a radical overhaul of the conveyancing process
in England and Wales."
These sentiments were also reiterated in a statement
made by a minister in the Lord Chancellor's Department—"A
system offering all those advantages will not appear overnight.
Electronic conveyancing is not a short-term project. The Land
Registry, for example, is planning for a decade or so of progressive
change. Advances will be made incrementally as experience is gained
and methods tested. We must not prejudice the security and integrity
of the land register, or any other public register, through undue
haste. A big-bang approach would be a long time coming, out of
date before it was launched and impossible to manage." The
timescales involved can be seen from The Land Registry published
Timeline where it is stated that "We think we will be able
to launch a pilot version of the new system during 2006. We do
not know at this stage how a pilot will be operated, but it is
likely that volunteer conveyancers will run both the new electronic
system and the old paper-based system in parallel. It will then
be possible to compare the new system with the old, and quantify
the benefits, if any, following from the new electronic system."
Is Home Information Pack legislation putting "the cart before
the horse", when the IT Land Registry infrastructure for
e-conveyancing will not be piloted until 2005 and unlikely to
be complete until the end of the decade?
1.4.4. A need for joined up Government.
It would appear that the Lord Chancellor's Department has adopted
a more prudent approach in respect of electronic conveyancing
in that some of its consultation documents refer to a "a
possible solution" whereas ODPM documents refer to Home Information
Packs as "the solution". This subtlety has to be seen
in the context of a consultation exercise where there is a feeling
that the views of many were ignored after the first consultation
exercise into Sellers Packs. It could be said that the Lord Chancellor's
Department has to date conducted a model project in the desire
to bring about electronic conveyancing by proposing that the introduction
of massive change will be on an incremental and voluntary basis
over a number of years. The Homes Information Pack legislation
appears to be adopting the big bang and compulsory approach. From
a political perspective, the impact of Home Information Packs
will be felt far more directly by consumers than electronic conveyancing.
Any improvements to the process of buying and
selling a home will be almost totally dependent upon a series
of integrated IT led solutions, coming in the main from Government
led projects for electronic conveyancing. The National Land Information
Service and The National Land and Property Gazetteer. Although
substantial work is under way to implement these projects, we
should always bear in mind the track record of past Government
led IT projects and the Land Registry's own statements that electronic
conveyancing would not be fully operational until 2012 as per
a statement from the Chief Registrar. "The Land Registry
has just embarked on a massive period of change that, by 2012,
will have delivered a complete Land Register for England and Wales
and a full electronic conveyancing system that will revolutionise
home buying in this country." As Home Information Packs are
an integral part of the overall project to improve home buying
and selling, the ODPM should surely be adopting a more joined
up approach by proceeding with caution and conciliation to those
who are offering genuine advice and will have to work with the
consequences of any legislation.
1.4.5 Who will really benefit from Home
Information Packs—if compulsory Home Condition Reports are
to be included in the pack, Home Inspectors stand to earn over
£500 million per annum. Is it any wonder that the Royal Institution
of Chartered Surveyors, whose members will probably make up the
majority of Home Inspectors, is so supportive of the proposed
legislation whilst the National Association of Estate Agents,
whose members will have to implement the legislation, have major
reservations. Consumers, in this case home sellers, will have
to find an additional £650 million per annum to pay for the
cost of fully implementing the proposed Home Information Pack
legislation.
1.4.6 The Bristol Trial—Despite leafleting
every household (162,000 from latest Census returns) in Bristol
with a population of 380,000 and other extensive publicity together
with the Government paying for the cost of preparing the pack,
only 159 volunteer transactions came forward over a six month
trial period. Of those only 61 exchanged or completed a sale by
the end of the six month trial, when 4,400 sales were completed
in Bristol in a six month period in the same year. Hardly a ringing
endorsement or large sample size.
1.4.7 Will the transposition of the Danish
model from Home Information Packs work in England and Wales? In
Denmark 90% of their housing stock was built in the 20th century
whereas England and Wales have the oldest and poorest housing
stock in Europe. In Denmark, their Home Information Pack process
only had to cope with 70,000 property transactions in 2000 when
in England and Wales we would have to produce 1.5-2 million packs
in an average year. To deal with the complexities of Home Information
Packs in Denmark, estate agents have to be licensed. To gain a
licence, agents must have a good theoretical and practical knowledge
of property matters. From June 2003, all new licensees must have
a degree in property transactions and have completed two years
practical training. This has to be compared with England and Wales
where no formal qualifications or training are required for estate
agency.
In Denmark, it is not actually compulsory for
a condition report to be included in a Home Information Pack although
the seller could become liable for all defects which were not
disclosed to a purchaser for up to 20 years if a condition survey
and insurance for hidden defects is not included. The process
of change in Denmark was brought about over a decade, which like
us included the computerisation of their Land Registry. Most importantly
the change in the law to make sellers' responsible for defects,
if a condition report is not included, was not introduced until
the later stages of the whole process in 1997 and only after home
inspectors, who are mainly architects and engineers, had been
trained and evaluated by the Ministry of Trade and Commerce.
1.4.8 Lessons from Australia. The New South
Wales regional government first introduced Home Information Pack
type legislation in 1987 and have been legislating ever since
to try and resolve problems which have emerged with the process.
The legislation was not adopted by the five other states and territories
in Australia. In New South Wales, a seller has to have a "contract
for sale" prepared and available before a home is put on
the market. The contract document must contain a zoning certificate
(planning permission), a sewerage diagram and a copy of the title
deeds and plan. There is no compulsion to include a survey or
home inspection report in that it is still the responsibility
of a prospective purchaser to obtain information on the condition
of the property. This arrangement of "buyer beware"
contradicts the statement made in an ODPM Housing Research paper
(No 101 1999) where it states under the section of New South Wales
that "The new system is based on caveat vender . . . the
transfer to caveat vendor has been a success." My enquiries
of legal and real estate practitioners in New South Wales confirm
that "caveat buyer" has not been reversed in that the
contract for sale still has to be checked by a purchaser's solicitor
and the purchaser is always advised to obtain their own survey
and termite test.
In New South Wales, it is considered by many
who I have contacted that buyer commissioned and paid for surveys
show a commitment by a prospective purchaser. If Home Information
Pack legislation were introduced in England and Wales with a compulsory
Home Inspection Report, it could introduce what I have euphemistically
called the "butterfly purchaser". In a post Home Information
Pack market, purchasers will only have to make a minimal financial
investment up to an exchange of contracts which means that they
could flit from property to property making offers at will. Could
the butterfly purchaser be worse than the gazumper or gazunderer?
1.4.9 Proposals for Home Information Packs
amused the Americans. When we were researching the US market for
some other property related product developments, we explained
what was being proposed in the UK. In some areas of the US, pre-marketing
appraisals and home inspections have been tried without great
success in that it led to fraud and coercion of surveyors in some
instances. The expressions of astonishment at what was being proposed
and rueful sentiments which we received to the Sellers Pack proposals
are understood to be similar to those received by a delegation
from the DETR when it visited Massachusetts in 2000. However,
we have been unable to find any reference to that visit or research
from the US in any background documents to this proposals legislation.
1.4.10 The Impact of Home Information Packs
on the Housing Market. The partial Impact assessment which accompanies
the Draft Bill considers the effect of the legislation on the
market (Paragraphs 34-36 Page 257). Having considered the two
extreme consequences of "some" and "no real long
term" effects, the section concludes by stating that "There
is no way of knowing in advance which of these views is correct".
The spectrum of effect has to be seen in the context of the research
used where the least effect research data comes from Countrywise
Assured Group who are the owners of the largest estate agency
chain. This company also has extensive surveying interests as
well as having a significant shareholding (47% in 2001) in TM
Property Services Ltd, which is one of the three companies licensed
to provide electronic property data form the National Land Information
Service. At the time Countrywide Assured secured their stake in
TM Property Services, they stated that "The Company plans
to extend its electronic infrastructure to enable it to become
the primary source of land and property information throughout
the UK and become the UK's leading facilitator of Sellers' Packs."
Is research from Countrywide unbiased as it appears to have a
considerable vested interest? At the other end of the spectrum,
anecdotal evidence suggests that "as many as 40% of sales
could be as the result of an unplanned house move." Therefore
quite a large proportion of this group could be deterred from
putting their house on the market if they had to prepare a Home
Information Pack. These anecdotal findings were put to representatives
of the DTLR when they visited some estate agency offices in the
West Country in November 2001.
On a personal note, I consider that there will
be an effect on the housing market given our obsessions with house
prices etc. While I fully appreciate that it is difficult to quantify
the full effect of the legislation, a clue to its effect can be
gleaned from the reaction of sellers to Home Information Packs
in a report to the ODPM in March 2003 where it is stated that
"The seller's immediate concern was the initial cost outlay
of putting the pack together. Having to pay something to put your
house on the market was a dramatic change from current practice
and was viewed with a certain amount of concern." This reaction
was from actual workshop reactions from real property sellers.
Although hypothetical cost and transaction time savings can be
put forward to show the merits of Home Information Packs, all
too often British consumers use only one measure—actual
cost, with cheapness being a prime selection criterion. Surely
further consideration of any Home Information Pack legislation
should be halted until a detailed Regulatory Assessment has been
completed to include detailed research on its actual effect on
the housing market, which is a vital component of the British
economy.
1.4.11 Home Information Packs—A sledgehammer
to crack a nut? Under the proportionality section to the Principles
of Good Regulation published by the Better Regulation Task Force
it is stated that "Policy solutions must be proportionate
to the perceived problem or risk . . . .don't use a sledgehammer
to crack a nut." In the report on the British Seller's Pack
Trial it was reported in paragraph 7.11 that "38% of sellers
considered their experience with the seller's pack worse than
expected" and in paragraph 9.4 that "The buyer's exist
survey showed that only 23% felt that the pack helped them to
decide whether to put in an offer." He same report stated
that "one of the aims of the seller's pack was to help the
buyer make an informed decision on whether to purchase."
Yet only 42% consulted the Pack before making an offer. Again
hardly a ringing endorsement of the Pack. The cost implications
and possible impact of the proposed legislation have already been
examined. The overall objective of the proposed legislation "is
to reduce the high rate of transaction failure . . . ." In
research which was conducted by the ODPM in 1999, 28% of offers
made and accepted failed to proceed to completion." In the
Bristol trial report, it was stated in paragraph 5.7 that "the
failure rate [in the trial] was 25%"—a 3% improvement.
In my opinion, one problem with any pack is
the amount of detail it will have to contain, more especially
if the property is a leasehold flat. In many instances, the detail
and documentation will be too detailed for many purchasers in
that they will find the contents of a large folder quite daunting.
This is not to mention the cost of reproducing it for those who
do not have access to the internet or other forms of electronic
delivery. Surely it would be better for legislation to require
property sellers to produce a summary or abstract of relevant
information. For my own part, I consider that one of the fundamental
shortcomings of The Home Information Pack proposals of is that
none of the information contained in the pack will have been verified
as being correct. This means that prospective purchasers would
still have to have it verified as being correct, which will take
time and then only perhaps discovered defects or anomalies in
title/leases etc. I have been unable to think of any consumer
purchase which will require such prescriptive action from a seller.
Whilst it may be beneficial for some information to be provided,
market prices usually reflect the amount of information which
is made available to a purchaser. I would use the purchase of
a car as an example. If two similarly aged and condition cars
were being offered for sale, it is not compulsory for a car to
be sold with an MOT. However if one car is being sold with full
documentation and a current MOT and the other doesn't have a MOT,
it is likely that the car with a current MOT and full documentation
will sell more quickly and at a higher price. My contention is
that emerging technological advances will make it much easier
to provide detailed information on a property in the future. Will
the sledge hammer of legislation be necessary in the future when
e-conveyancing is in place? Surely it would be better to wait
and review the situation once all the electronic components of
the National Land Information Service. The Land Registry and the
National Land and Property Gazetteer are up and running.
1.4.12 Should Home Information Packs contain
a Home Inspection Report? The inclusion of a compulsory Home Condition
Reports (HCR) into a Home Information Pack will add an estimated
£650 million per annum to home selling costs. Under the existing
home buying process only about 25-30% of the purchasers commission
a more detailed private survey. Most purchasers choose to rely
on the mortgage valuation. The existing survey and valuation workload
is carried out by about 2,500 qualified residential surveyors,
whose average age is said to be 53. Mortgage lenders will not
usually accept a valuation unless it has been prepared by a qualified
valuer or surveyor. To qualify as a surveyor, it is necessary
to complete a three or four year academic course followed by two
years of practical training and assessment. Under the proposed
new arrangements it is estimated that 7,500-8,500 home inspectors
will be required. It is proposed that home condition work will
be opened up to other professional groups and new entrants via
a two year academic course.
This means that Home Condition reports will
be coming from a whole spectrum of persons. This could present
major problems to the insurance industry which is meant to be
providing insurance cover for home inspectors to cover their mistakes
and also to purchasers in the form of hidden defects insurance.
Mortgage lenders have also expressed concern. Whilst it is accepted
that standards will be monitored by an accreditation body, which
has already been established—SAVA (Surveyors and Valuers
Accreditation). Could this body's credibility already been partially
undermined in that it is both a training and examination organisation,
as well as being charged with providing the additional 5,000 home
inspectors. In most other fields, examination bodies and training
organisations are separate entities. In the US, the Appraisal
Foundation is charged with setting and maintaining standards.
A director of that organisation, who was on secondment from an
academic organisation, was forced to resign when it was found
that he was usurping his position to steer practitioners towards
his academic institution. The introduction of compulsory Home
Condition Reports to say 2006 will require a least an additional
5,000 home inspectors to be trained by that time. To date, I have
only been able to find about 800 surveyors who had become accredited
to SAVA so far. If it were not compulsory to include a Home Condition
Reports under the proposed new arrangements the possible logistical
nightmare of having to train and assess so many additional home
inspectors could be avoided.
1.4.13 If a Home Condition Report is to
be included in a Home Information Pack, could purchasers rely
on it? In the Bristol Trial and in the more recent reports which
examined the impact of Home Information Packs comment was made
about the Home Condition Reports. Some sellers regarded HCR's
as a "double edged sword" if their property was in poor
condition and whether they could be relied on if the HCR had been
commissioned and paid for by the seller. As the Home Condition
Report will not contain a valuation, it will be difficult for
prospective purchasers to assess whether the asking price has
been set to take account of the condition of a property. When
I raised this point with Dr Steve Nuttall from the DETR, he suggested
that one possible course of action would be for prospective sellers
to borrow more money from their bank or building society to carry
out repairs before the property was put on the market. Is this
really a realistic option?
In the Bristol Trial report, it was stated that
under paragraph 8.16 that "surveyors also believed that the
system for allocating HCR's should be seen to be fair and open
if the scheme is rolled out nationally. One idea that received
strong support was that the surveyor be drawn at random from a
pool in the local area. It was felt that this would stop the practice
of estate agents steering the consumer in the direction of their
"favourite" surveying firm". Under the proposed
new arrangement, the buyer and or their estate agent could select
a home inspector. That same home inspector could also work for
the estate agent. In a recent letter from the Property Services
Training Organisation it was stated that "conflicts of interest
will not apply as Home Inspectors will be regulated through the
certification scheme and will be required to undertake inspections
with full impartiality." This is a situation which many surveyors
feel uncomfortable with ie having to answer to both buyer and
seller. Under the current system the surveyor acts on instructions
received from the purchaser. I have on file a copy letter, which
was submitted as evidence to a Congressional hearing in the US,
where a seller client refused to pay an appraiser's bill for a
pre-sale inspection because the appraiser commented on the poor
condition of a ceiling. The same situation could occur here. If
Home Condition reports are to be included in a Home Information
Pack, more stringent safeguards will have to be put in place in
respect of Home Inspector selection etc. Failure to put in place
such safeguards could lead to a similar situation and one which
was heavily criticised by both the Public Accounts Committee and
the European Commission in respect of the Foot and Mouth outbreak
"where farmers could themselves select a valuer of their
choice with a clear potential risk of conflict of interest."
The Public Accounts Committee was very critical of the old Ministry
of Agriculture for allowing "potential recipients of compensation
to select and appoint the valuers." Whilst the home seller
is not going to receive compensation, the ability to select a
Home Inspector of their choice might lead to a more favourable
report and therefore a higher price easier sale etc. The situation
of in-house estate agency Home Inspectors providing Home Condition
Reports has to be viewed with concern, in my opinion, more especially
as the commission which an agent earns from the sale of the property
is derived from the sale price achieved. A higher price and a
property reported to be in a good condition equals a higher fee
earnt.
In the partial Impact Assessment, which accompanies
the Draft Bill, the average anticipated cost of a Home Condition
report is shown as £285. The Home Condition Report is supposed
to be based on the existing intermediate Home Buyers type survey.
There is a suggestion that the average cost of a Home Condition
report could reduce by increased competition from increasing the
number of Home Inspectors. At the current time many existing surveyors
are finding that their operating costs are increasing substantially
ie Professional Indemnity and employer's Liability Insurance.
Therefore the opportunity for reducing Home Inspection costs appears
small, more especially when a comparison is made between the proposed
cost of a Home Inspection Report and the current costs which the
RAC and AA charge to undertake a pre purchase car inspection and
report, namely from between £190-309.
1.4.14 An alternative solution which embodies
the aims of the proposed Home Information Pack legislation which
would not require legislation or increase the costs of selling
a home. All too often resistance to change can take the form of
negative statements. In this submission, I have sought to illustrate
what I perceive to be the major shortcomings of the proposed legislation
more especially from a consumers point of view. I would conclude
on a positive note by setting out how we believe that it is possible
to achieve the same aims without the necessity to have to legislate
or increase sale costs.
In August 2000, I wrote to then Minister of
State—Nick Raynsford to set out the initial concept for
a process which we thought could achieve substantial improvements
to the system of buying and selling a home. Despite sending a
second letter to the Minister on 26 September 2000, no reply or
even the courtesy of an acknowledgement was received from the
department. In desperation, we wrote to the Chancellor and the
No 10 Policy Unit asking whether the full implications of the
then Sellers Pack proposals had been considered. This action had
the desired effect in that two representatives of the department
visited me in Southampton January 2001. Although the time spent
appeared to be constructive, I had this feeling that there was
a closed mind set and that "Sellers Packs" were the
only solution.
Undeterred by this apparent attitude, we started
to evolve our concept and sought the views of others in the industry
in this country and in the US. We have now completed the design
process for a system and worked up operating models, attracted
interest from within the industry as well as potential investors.
In the US, positive responses were almost immediate from both
government and the property industry. In the UK, the main problem
has been the uncertainty as to Government's intentions over a
period of four years and the failure of the original Homes Bill.
1.4.15 Summary I fully support the principle
of improving the process of buying and selling a home which include
the providing of relevant information on a given property before
it is sold. However is the proposed legislation the best solution,
more especially when it appears to adopt the big bank approach
with it being rolled out on a nationwide basis and made compulsory,
I would therefore urge you to reconsider the following.
1. The total cost of assembling the Home
Information Packs will be around £1.33 billion per annum
with a net hypothetical saving of £350 million. What are
consumers going to think of this massive increase in home selling
costs, which effectively amounts to increasing the cost of each
transaction by £505.
2. In the trial, transaction failures were
only reduced by 3%.
3. The Land Registry's e-conveyancing project
will take 10 years to complete and until it is complete the full
benefits of Home Information Packs are unlikely to be felt.
4. Is the current and previous consultation
exercise really meaningful when a comparison is made between the
actions of the ODPM and the Lord Chancellor's Department, more
especially as the only significant changes between the previous
Homes Bill is the renaming of Home Information Packs from Sellers
Packs and criminal sanctions have been replaced with civil penalties,
together with reference to Home Information Packs appearing to
be "the only solution" on the table.
5. Should legislation really be introduced
when the partial Impact Assessment states that "there is
no way of knowing" what the effect of the legislation will
be on the housing market.
6. In the Bristol Trial, only 42% of buyers
consulted the pack before making an offer.
7. The Australian approach seems measured
and reasonable by requiring that a "contract for sale"
is prepared before a property is marketed. If we have got to have
legislation, why couldn't a similar requirement be introduced
here without the necessity to have a prepare a large and detailed
information pack to include a Home Condition Report.
8. Given the old and deteriorating condition
of the housing stock in England, I would consider that the effect
of having a condition survey on every property to be sold could
have a major impact upon the housing market as some properties
or whole areas could be blighted by their poor condition.
9. Is it really necessary to have every
property surveyed prior to open marketing? In my experience the
prime concerns of most buyers is whether they can get a mortgage
on the property and that the price being paid is about right.
A Home Condition Report will not address these two fundamental
issues. Whilst it is fully accepted that the prudent approach
is for a purchaser to commission a survey, do we have to impose
that prudence on all. Consumers may grumble about the existing
process of buying and selling a home but are they really prepared
to pay upto £1.3 billion a year more for benefits which are
very difficult to quantify. In Denmark where Home Information
Packs are in existence the cost of selling a home averages about
6%. This has to be compared with our fee levels which are currently
between one and 2%. Part of the higher cost differential in Denmark
is attributable to providing Home Information Packs as part of
the sales package and the higher calibre of estate agents who
are necessary to work with their system.
10. How much more, if anything, are consumers
in England and Wales prepared to pay to sell their home. From
the partial impact assessment, it appears that the costs far outweigh
the benefits, whereby I would consider that home sellers are unlikely
to want to pay any additional costs, let alone up front costs
to put their home on the market. Could compulsory Home Information
Packs be a step too far and one which could be seen as a threat
to our obsession with residential property which is all too often
regarded as an investment rather than a home?
11. Most home sellers and some sections
of the media will probably only look a the increased sale costs
associated with Home Information Packs in that the cost benefits
are very difficult to quantify, more especially when we are currently
used to putting a home on the market with no up front costs, delay
or pre planning. With the advances that are taking place with
technology and the advent of electronic conveyancing wouldn't
it be better to re-evaluate the necessity to introduce Home Information
Pack legislation and see whether a market led solution, such as
the one which we have formulated, could be utilised.
| 
