Communities and Local Government CommitteeWritten evidence submitted by The Property Ombudsman

Summary

TPO welcomes the CLG’s decision to conduct an inquiry into the private rented housing sector.

To assist the CLG Committee’s inquiry, this response includes comprehensive data relating to disputes referred to TPO by consumers in 2012. Last year saw a total of 14,017 letting related issues being reported to TPO with the Ombudsman formally investigated 2,018 issues and made a judgement in each instance. A full breakdown of these issues can be found in Appendix 1.

In addition, the Ombudsman has drawn on his extensive experience of dealing with letting disputes to provide the CLG Committee with detailed commentary concerning the problems and inconsistencies currently present within the private rented housing sector and has provided potential solutions where appropriate.

In responding TPO has also taken the opportunity of reiterating the anomaly which persists between sales agents who are obliged under law to join a redress scheme and letting agents who are free to operate under their own set of standards and who are not required by law to offer their consumers any route to redress if things go wrong.

The Ombudsman would welcome the opportunity to provide oral evidence to CLG’s Committee to assist their inquiry.

1. TPO Overview

History and Purpose

1.1 The Property Ombudsman (TPO) scheme was originally established in 1990 as the Ombudsman for Corporate Estate Agents. In 1997 the scheme was renamed as the Ombudsman for Estate Agents and then changed to TPO to reflect its broader jurisdiction covering disputes relating to sales, lettings, personal search organisations, residential leasehold management, international sales (through UK based agents), chattels auctions and commercial property. In June 2008 TPO was the first redress scheme to gain the status of an OFT Approved Estate Agents Redress Scheme under the provisions of the Consumers, Estate Agents and Redress Act 2007.

1.2 The Property Ombudsman Limited is a “not for profit” company limited by guarantee which provides an alternative dispute resolution service to consumers within the property sector. There is no cost to the consumer or the taxpayer for TPO’s services.

1.3 TPO provides consumers with a free, impartial and independent alternative dispute resolution service for complaints against TPO scheme members. The Ombudsman’s resolutions are designed to achieve a full and final settlement of the dispute and all claims made by either party. The Ombudsman can, where appropriate make compensatory awards in individual cases up to a maximum of £25,000 for actual and quantifiable loss and/or for aggravation, distress and/or inconvenience caused by the actions of a registered firm.

Membership, Standards and TPO’s Codes of Practice

1.4 TPO’s Code of Practice for Residential Estate Agents has received full approval from the OFT’s Consumer Codes Approval Scheme (CCAS) and is followed by 11,570 estate agent branches who are members of TPO. We believe this equates to approximately 95% of the estate agents trading in the UK.

1.5 TPO’s Code of Practice for Residential Lettings Agents received Stage 1 approval from the OFT’s CCAS in July 2011. Compliance monitoring activities required for full approval have been carried out since this date.

1.6 Despite no legal requirement for letting agents to be registered with a redress scheme, the TPO Code of Practice for Residential Letting Agents is voluntarily followed by 9,748 letting agent branches who are members of TPO. We consider this equates to approximately 60% of letting agents trading in the UK.

1.7 TPO’s Codes of Practice are widely used throughout the property sector by other industry bodies. For example the National Association of Estate Agents (NAEA) and the Association of Residential Letting Agents (ARLA) use TPO’s Codes as the basis for their own judgements regarding their members conduct. In addition, TPO’s Codes have been replicated by other trade bodies to use as their own membership codes, for example the UK Association of Letting Agents (UKALA).

1.8 Customer satisfaction and compliance surveys carried out as part of the OFT’s CCAS requirements have shown a year upon year increase in consumer (buyer and seller) satisfaction with member firms and the firms’ compliance with the TPO Code of Practice for Residential Estate Agents. Similar positive results have been received for CCAS monitoring carried out on TPO letting agents who voluntarily follow the Code of Practice for Residential Letting Agents.

1.9 As well as sales and letting agents, the Ombudsman’s jurisdiction also covers disputes relating to commercial property agents, residential leasehold management agents, international sales agents (based in the UK) and valuers and auctioneers conducting chattels auctions.

1.10 The Ombudsman can only investigate disputes relating to registered firms. However, as at 31 December 2012, over 11,933 sales offices and 9,748 lettings offices were registered with TPO. We estimate that these figures represent approximately 95% of sales agents and 60% of lettings agents operating within the UK.

Governance, Independence and Principles

1.11 The Ombudsman provides redress, where appropriate, to consumers whose complaints are supported after consideration on a case by case basis. Redress is intended to put the consumer back into the position they were before the complaint arose. The Ombudsman is not a regulator and does not have the authority to take regulatory or legal action against a registered firm. The Ombudsman does not have the power to impose fines or dictate the way in which firms conduct their business.

1.12 Whilst the scheme charges its members an annual subscription and the fees collected by the Board of TPO, the Ombudsman reports to the independent Council, the majority of which is made up of non-industry members. The Council is chaired by Lord Richard Best. It is the Council who appoints the Ombudsman and sets his Terms of Reference, (ie how the complaint process operates). The Ombudsman is accountable to the Council.

1.13 TPO is an ombudsman member of the Ombudsman Association (previously named the British and Irish Ombudsman Association—BIOA) and operates in accordance with the organisation’s principles of good governance:

Independence.

Openness and transparency.

Accountability.

Integrity.

Clarity of purpose.

Effectiveness.

2. TPO’s Work in 2012

2.1 During 2012, TPO received 8,019 individual complaint enquiries from members of the public who were either tenants or landlords. Many enquiries concerned multiple issues and a full breakdown of the different types of issues can be found in Appendix 1. Overall, 2012 saw tenants and landlords report over 14,017 issues to TPO.

2.2 The vast majority of complaint enquiries referred to TPO were resolved by providing consumers with further information, signposting to appropriate bodies and/or directing the letting agent to deal with the complaint in accordance with the in-house complaint procedure set out in the TPO Code of Practice.

2.3 Just over 1,800 individual enquiries related to letting agents who were not registered with TPO. As a point of interest, over the last five years, 29% of enquiries received by TPO concerned the actions of non-registered letting agents.

2.4 TPO resolved 210 disputes were via our early resolution process whilst the Ombudsman carried out a full formal investigation of 871 disputes which covered 2,028 different letting issues. A full breakdown of these issues can be found in Appendix 1.

2.5 In order to assist and advise the industry on matters of best practice and to encourage higher standards, the Ombudsman produced over 30 articles for the trade press, published nearly 150 case studies, made a number of television and radio appearances and spoke at numerous events and conferences.

2.6 TPO asked the eminent academic, Professor Michael Ball, to conduct an investigation into the issues surrounding the regulation of residential letting agents in England and his thought-provoking and cogent report “Regulating Residential Letting Agents: The Issues and the Options” was the outcome. The report was officially released at a forum arranged by TPO which took place at the House of Lords on 23 November 2012 and was attended by a representative of CLG and 33 other individuals from key organisations including ARLA, ARMA, CAB, NAEA, NALS, NLA, OFT, RICS, Shelter, TDS, UKALA, Crisis, Which?, and several lettings agencies in addition to senior personnel from TPO.

2.7 TPO responded to consultations and requests from Which?, Shelter, the Welsh Government and the OFT by providing detailed commentary and extensive letting data to assist their inquiries into the private rented sector. Using the OFT complaint grouping system employed in their Letting Agent Intelligence Report consultation, TPO data from 2012 relating to letting complaint enquiries and formal investigations have been included in Appendix 1. Data relating to specific regions within the UK can be made available upon request.

3. The Select Committee’s Inquiry

3.1 The Committee has asked for submissions from interested parties covering the quality and regulation of private rented housing, and levels of rent within the sector. Specifically the Committee has asked for submissions to include comment on the following issues:

(a)The quality of private rented housing, and steps that can be taken to ensure that all housing in the sector is of an acceptable standard.

(b)Levels of rent within the private rented sector—including the possibility of rent control and the interaction between housing benefit and rents.

(c)Regulation of landlords, and steps that can be taken to deal with rogue landlords.

(d)Regulation of letting agents, including agents’ fees and charges.

(e)The regulation of houses in multiple occupation (HMOs), including the operation of discretionary licensing schemes imposed by a local authority for a category of HMO in its area.

(f)Tenancy agreements and length and security of tenure.

(g)How local authorities are discharging their homeless duty by being able to place homeless households in private sector housing.

4. TPO’s Responses

(a) The quality of private rented housing, and steps that can be taken to ensure that all housing in the sector is of an acceptable standard

4.1 The quality of private rented housing is an issue which is currently underpinned by existing “safety” legislation. The property is the landlord’s responsibility as well as his investment and, whilst TPO receives many complaints concerning property conditions, these are matters which, on the whole, fall outside the Ombudsman’s Terms of Reference as they are landlord/tenant issues falling under the terms of the tenancy agreement. However, the Ombudsman can, and frequently has, investigated the conduct of a letting agent in respect of their responsibilities under the Code of Practice to ensure that issues of repair and maintenance reported to them have been referred to their landlord clients and any instructions received thereafter carried out.

4.2 Letting agents who follow the TPO Code of Practice are also obliged to inform their landlord clients, at the market appraisal stage, of any obvious items of repair or maintenance required in order to prepare the property for the intended letting. Furthermore, they are also obliged to inform their clients of the need to comply with safety legislation and regulations and verify the validity of any necessary certificates. This is an important requirement as current market conditions have seen many inexperienced and “reluctant” landlords enter the private rented sector.

4.3 Given the obligations placed on TPO letting agents by the Code of Practice, it could be argued that landlords are more likely to improve their overall knowledge and performance (resulting in a better outcome for tenants) when dealing with letting agents who operate to a set of defined common standards. Logically, it would therefore follow that problems concerning the condition of the property are less likely to occur if a letting agent registered with TPO is involved in the transaction.

4.4 TPO is unable to comment in relation to landlords who choose not to use letting agents or instruct letting agents who are not registered with a redress scheme and who operate to their own set of standards.

(b) Levels of rent within the private rented sector—including the possibility of rent control and the interaction between housing benefit and rents

4.5 TPO receives many letting disputes which concern the issue of rent arrears. In a number of cases it was apparent that the tenant was in receipt of housing benefit but has failed to pass these monies on to the landlord/letting agent. The subsequent response from the landlord was to usually start proceedings to remove the tenant from the property. These proceedings can often be a long and complicated process where the tenant’s chances of being re-housed by the local authority may increase if they are evicted rather than if they leave the property of their own accord. The impact on landlords is that they are less inclined to let their property to tenants in receipt of benefits or, if they do, may consider increasing the rent or seek other guarantees to offset potential future losses.

Such a scenario could be easily avoided in the first instance if local authorities made housing benefits payments direct to the landlord or to the landlord’s letting agent.

4.6 Regarding the issue of “rent control”, attempting to restrict profit margins for landlords is likely to dissuade potential landlords from entering the market. It may also have the undesired impact of encouraging landlords to “cut corners” in order to save money which could impact on many areas of the tenancy such as repairs and maintenance matters or the level of fees and potential penalty charges levied at tenants.

(c) Regulation of landlords, and steps that can be taken to deal with rogue landlords

4.7 Due to current market conditions, some people have found themselves taking on the role of landlord in addition to their normal everyday profession. It is often the case that in an effort to save costs, many landlords elect to manage the tenancy themselves. Whilst experienced landlords understand the complexity and responsibilities of that undertaking, new landlords are often less aware of the full extent of their responsibilities and have less experience in conducting a mutually beneficial landlord/tenant relationship in-line with their responsibilities as set out in the tenancy agreement.

4.8 The service offered by letting agents who have agreed to follow TPO’s Code of Practice has improved over the years, as shown by our compliance monitoring. It should also be recognised that the TPO Code of Practice is not only a means by which the Ombudsman measures standards but is also a document which provides letting agents with a blueprint for best practice. It could, therefore, be argued that if landlords were required to act in accordance with a similar code of practice, standards employed by private rental sector landlords would improve. Furthermore, if landlords were also required to undertake some sort of initial basic training it would assist in helping them to understand their responsibilities.

4.9 Existing legislation may also present a method of dealing with rogue landlords providing sufficient resources available to enforce its requirements.

4.10 As a point of interest the Welsh Government is currently considering the further step of a compulsory licensing system for landlords and letting agents, whilst the Mayor of London is also consulting on a similar, yet voluntary scheme.

(d) Regulation of letting agents, including agents’ fees and charges

Regulation of letting agents

4.11 TPO recognises that the UK Coalition Government is, in general, opposed to the introduction of regulation and, therefore, that regulation in the property sector is not currently a priority.

4.12 TPO believes that consumers should be entitled to expect a route to redress when things go wrong. However, the anomaly that currently exists within legislation means that, whilst the sales activities of an estate agent’s office are required to be covered by a redress scheme, there is no such requirement for their lettings activities.

4.13 Sales agents are required by the Consumers, Estate Agents and Redress Act (CEARA) 2007 to be registered with an OFT Approved Redress Scheme and are now used to working in such a regime. Since CEARA, the customer satisfaction and compliance surveys carried out by TPO have shown a year upon year increase in consumer (buyer and seller) satisfaction with registered firms and the firms’ compliance with the TPO Code of Practice for Residential Estate Agents.

4.14 TPO estimates that around 60% of letting agents trading in the UK have voluntarily registered with the scheme and follow the TPO Code of Practice for Residential Letting Agents. However, this leaves approximately 40% of letting agents who are operating under their own set of standards and which present a greater risk to consumers. Consumers who use non-registered letting agents are not afforded a route to free and independent redress should things go wrong.

4.15 Market conditions have seen many sales agents broaden their business into lettings. It can, therefore, be argued that making compulsory registration with an Ombudsman scheme applicable to every letting agent would not present (for the majority of firms) anything different and it would remove this clear inconsistency for consumers.

4.16 We believe this inconsistency could be resolved by an amendment to the Estate Agents Act 1979 to bring letting agents within the scope of CEARA to oblige them to join a redress scheme and follow a Code of Practice. This would ensure that all letting agents would have to operate to industry recognised standards and consumers would be provided with access to a redress scheme should things go wrong.

4.17 In the absence of a formally structured regulatory regime, the Ombudsman (in his 2011 Annual Report) discussed the concept of an Industry “Council” with the key objective of ensuring that consumers understand why they should avoid letting agents who refuse to sign up to independent redress through TPO, or who do not seek out membership of a recognised industry body such as ARLA.

The industry bodies who may make up such a Council (with a consumer stakeholder contribution) could ensure that firms within their membership or influence could attract the consumer because they display certain confidence measures, specifically:

Membership of an independent redress (Ombudsman) scheme.

Licensing of firms’ representatives by an appropriate body.

Proper facilities for the protection of client money.

Common standards, applied through adherence to Codes of Practice.

Adherence to Tenancy Deposit protection regulations.

In addition, the Council’s role could extend to consumer education, by putting in place a structured and consistent approach to the information provided by firms to consumers who fall within its influence. However, in order for such an initiative to work, the Council would require support from the Government and specifically CLG, along with obtaining the appropriate financial commitments for the Council to function.

Fees and Charges

4.18 The issue of fees and charges, especially those levied on tenants by letting agents is a topic which has recently received widespread publicity. Shelter’s campaign in Scotland was successful in motivating the Scottish Government to enforce existing legislation that prevented tenants being charged anything other than rent and deposit monies. However, there is no such existing legislation in England and Wales which could be enforced.

4.19 From the cases referred to TPO it is clear that letting agents utilise a range of fees charged to both the tenant and the landlord and that these vary from agent to agent depending on their particular business offering.

4.20 TPO recognises that the lettings market is an extremely competitive environment and that agents should not be restricted in the development and innovation of their offerings in order to gain business. However, the TPO Code of Practice places the obligation on the agent to ensure that all fees and charges are actively flagged to both the landlord and the tenant before they have committed themselves by signing an agreement. In all cases fees must be presented clearly and unambiguously to enable the consumer to make an informed decision. TPO believes that these obligations should apply to all letting agents.

4.21 Concerning the topic of potentially capping or removing tenant fees altogether, TPO is concerned that such an initiative may result in adverse consequences. For example, letting agents may seek to recoup their potential income losses by increasing the level of fees charged to landlords. Landlords may then react by increasing the level of rent to mitigate the increased cost which would result in little benefit to tenants who, whilst have not paid fees, would be required to pay a higher rent. Alternatively, faced with higher fees, more landlords may decide to manage the tenancy themselves which raises issues about experience, knowledge and standards previously discussed in part c) of this Section.

4.22 Overall, TPO would be willing to assist in any initiative which aims to make fees clearer, easier to understand and comparable for consumers.

(e) The regulation of houses in multiple occupation (HMOs), including the operation of discretionary licensing schemes imposed by a local authority for a category of HMO in its area

4.23 Currently there are many inconsistencies across the licensing schemes being operated by various local authorities in respect of HMOs.

4.24 It is TPO’s view that, in order to avoid confusion and to promote universally acceptable standards, there needs to be consistency across all of the schemes in force and those which are currently being considered by local authorities. For landlords operating a portfolio of properties across multiple local authority boundaries, the differences between the different scheme requirements could lead to unnecessary and avoidable confusion which could also have an indirect impact on their tenants.

(f) Tenancy agreements and length and security of tenure

4.25 TPO recognises that there is a need for both short and long term tenancy agreements to be offered to tenants. For groups such as students, the current six to 12 month Assured Shorthold Tenancy is suited to their circumstances. However, for families who are settled in the area, with children attending local schools and parents employed nearby, such a tenancy period is unlikely to be suitable. Indeed, the potential for families to have to move on a regular basis is unsettling and can also lead to disputes arising. Tenants, therefore, need to be better educated to understand that they can request a tenancy for a period of time which suits their circumstances and not feel that they have to accept the period of the tenancy offered to them without question.

4.26 From a landlord’s point of view, their circumstances can also dictate the length of the tenancy agreement which they are willing to agree. The property could be their own home which they let during an extended period away. They may wish to let in the short term with a view to selling when the market improves. Alternatively, the property might be one of many in a portfolio where the desire for longer term tenants may be greater.

4.27 Regardless of the tenant or the landlord’s circumstances, if a letting agent is involved in the transaction they should assist by using their experience to provide advice suitable to the circumstances of the parties entering into that transaction.

4.28 TPO would therefore be willing to support and assist any initiative which seeks to educate and inform consumers about the options open to them when negotiating a tenancy.

(g) How local authorities are discharging their homeless duty by being able to place homeless households in private sector housing

4.29 This is a matter which TPO is unable to comment upon.

5. TPO Recommendations

5.1 For the reasons already stated, TPO would strongly recommend amending the Estate Agents Act 1979 to bring letting agents within the scope of CEARA to oblige all agents to join a redress scheme and follow a Code of Practice. This would ensure that all letting agents would have to operate to industry recognised standards and consumers would be provided with access to a redress scheme.

5.2 In the absence of such an amendment or a formally structured regulatory regime, TPO would request CLG and Government to support the proposal to form an Industry Council.

5.3 The OFT’s approach under CEARA has been to approve two schemes for redress provision. The current arrangements under which TPO and Ombudsman Services: Property effectively compete in that provision, work without detriment to the consumer (because both schemes set out to ensure consistency of treatment etc). However, there is always a danger of agents seeking to use the threat of transferring to another scheme as a lever to influence decisions. No Ombudsman would be swayed by such an approach but the ensuing exchanges between scheme and agent simply delay redress for the consumer. A single scheme could also avoid any potential confusion in the mind of the consumer about who to contact when they have a dispute against an agent.

5.4 TPO has considerable experience in the field of dispute resolution within the lettings sector and would be happy to provide additional information, clarification or any further assistance to the CLG Committee throughout its inquiry process. Furthermore, the Ombudsman would welcome the opportunity to attend Committee hearings and provide oral evidence to assist with their inquiry.

January 2013

APPENDIX 1

THE PROPERTY OMBUDSMAN

Lettings Workload

1 January 2012
to
31 December 2012

2012 SUMMARY

Lettings WorkloadAn Overview

2011

2012

Individual Complaint Enquiries

7,641

8,019

Issues Reported

11,253

14,017

 

Early Resolutions

101

210

 

Investigations (Formal Reviews)

756

871

Issues Reviewed

1,817

2,028

Complaint Supported*

67.4%

70%

Average Award

£307

£325

* Complaint supported either in whole or in part.

Lettings Offices Registered with TPO

2011

2012

As at 1 January

7,851

8,701

As at 31 December

8,701

9,748

OFT LETTING AGENT GROUPINGS

Groupings are based on the OFT’s Letting Agent Intelligence Report consultation of 2012–13.

ISSUES REPORTED TO TPO IN 2012

OFT Groups

Issues

Percentage

Group 1—Fees and charges

1,713

12.22%

Group 2—Agents providing poor service

7,553

53.88%

Group 3—Security deposits

878

6.26%

Group 4—Delayed and substandard repairs

791

5.64%

Group 5—Unfair business practices

2,676

19.09%

Other

406

2.90%

Total

14,017

100%

ISSUES FORMALLY INVESTIGATED BY TPO IN 2012

OFT Groups

Issues

Percentage

Group 1—Fees and charges

401

19.77%

Group 2—Agents providing poor service

1,022

50.39%

Group 3—Security deposits

183

9.02%

Group 4—Delayed and substandard repairs

180

8.88%

Group 5—Unfair business practices

70

3.45%

Other

172

8.48%

Total

2,028

100%

LETTING COMPLAINT ENQUIRIES

1 January–31 December 2012

TOTAL INDIVIDUAL COMPLAINT ENQUIRIES

8,019

ISSUES

Number

Percentage

OFT Group

Communication Failure

3997

28.5%

2

Duty of Care

2197

15.7%

5

Deposit

878

6.3%

3

Repairs and Maintenance

740

5.3%

4

Management Failure

738

5.3%

2

Administration

729

5.2%

2

Complaints Handling

619

4.4%

2

Rent

528

3.8%

1

Check In/Check Out

412

2.9%

2

Tenancy Agreement

297

2.1%

1

Holding Deposit

291

2.1%

1

Other Fees

256

1.8%

1

Instruction Failure

243

1.7%

2

References

238

1.7%

2

Other

220

1.6%

Inventory

190

1.4%

2

Not known

186

1.3%

Inspections

181

1.3%

2

Rudeness

178

1.3%

5

Let Details/Advertising/Marketing

173

1.2%

5

Management Fees

125

0.9%

1

Management Agreement

100

0.7%

1

Keys

84

0.6%

2

Renewal Fees

74

0.5%

1

Viewing

67

0.5%

2

Gas Safety Certificate

42

0.3%

4

Harassment

42

0.3%

5

Lease Agreement

42

0.3%

1

Eviction

32

0.2%

2

Conflict of Interest

29

0.2%

5

Discrimination

19

0.1%

5

Energy Performance Certificate

15

0.1%

2

Racial

13

0.1%

5

Unfair bias toward other Party

13

0.1%

5

Disability

9

0.1%

5

Electrical Test

9

0.1%

4

Let Board

6

0.0%

2

Gender

3

0.0%

5

ID

2

0.0%

2

TOTAL ISSUES REPORTED

14,017

LETTING INVESTIGATIONS (FORMAL REVIEWS)

1 January–31 December 2012

TOTAL INVESTIGATIONS (FORMAL REVIEWS)

871

ISSUES

Number

Percentage

OFT Group

Communication Failure

261

12.9%

2

Complaints Handling

236

11.6%

2

Deposit

183

9.0%

3

Other

172

8.5%

Repairs & Maintenance

164

8.1%

4

Rent

125

6.2%

1

References

114

5.6%

2

Tenancy Agreement

96

4.7%

1

Inspections

87

4.3%

2

Check-in/Check-out

76

3.7%

2

Inventory

56

2.8%

2

Administration

54

2.7%

2

Other Fees

49

2.4%

1

Holding Deposit

45

2.2%

1

Management Failure

39

1.9%

2

Management Agreement

39

1.9%

1

Management Fees

39

1.9%

1

Duty of Care

32

1.6%

5

Lettings Particulars/Advertising

31

1.5%

2

Keys

26

1.3%

2

Rudeness

20

1.0%

5

Gas Safety Certificate

16

0.8%

4

Viewings

13

0.6%

2

Instruction Failure

13

0.6%

2

Harassment

8

0.4%

5

Energy Performance Certificate

8

0.4%

2

Renewal Fees

7

0.3%

1

Conflict of Interest

7

0.3%

5

Eviction

6

0.3%

2

Unfair Bias

2

0.1%

5

Let Board

2

0.1%

2

Withdrawal Fee

1

0.0%

1

Racial

1

0.0%

5

Electrical Test

0

0.0%

4

OTOR

0

0.0%

Offer of Financial Services

0

0.0%

5

Gender

0

0.0%

5

Disability

0

0.0%

5

TOTAL ISSUES INVESTIGATED

2,028

Contact

Christopher J Hamer
The Property Ombudsman
Milford House
43–55 Milford Street
Salisbury
Wiltshire
SP1 2BP

Direct Tel: 01722 430027

Fax: 01722 332296

Email: christopher.hamer@tpos.co.uk

Twitter: @TPOmb

The Ombudsman’s Terms of Reference, the Codes of Practice, Consumer Guides and other documents about the operation of the scheme are available on our website (www.tpos.co.uk), together with previous annual and interim reports, further explanation of governance arrangements and a full list of registered firms.

Prepared 16th July 2013