8.We received hundreds of written submissions from leaseholders who wanted to tell us about their personal experiences of living in a leasehold property. They told us about what are perceived to be onerous ground rent terms, high service charges and one-off bills, unfair permission charges, alleged mis-selling of leasehold properties by developers, imbalanced dispute mechanisms, inadequate advice services, and unreasonable costs to enfranchise or extend leases. But it was important for us to consider whether the submissions we received represented the views of the majority of leaseholders, or if they reflected a minority of views in an otherwise functioning market.
9.Our first chapter seeks to address this question. We reflect on whether freeholders provide, as they claim, a unique and valuable service, or if leaseholders might be better placed to manage their buildings alone. We look at evidence on the extent of dissatisfaction with the leasehold model. Finally, we consider the reasons why there has been a low take-up of the principal alternative model of flat ownership, commonhold, since its creation in 2004 and how these barriers might be overcome.
10.Estimates of the numbers of leasehold properties vary. Government statistics suggest there were 4.2 million leasehold properties in England in 2015–16, of which two-thirds (2.9 million) were flats, while Leasehold Knowledge Partnership reported that there were 6.7 million leasehold properties in England and Wales. When a leasehold flat or house is first sold, a lease is granted for a fixed period of time, typically between 99 and 125 years, but sometimes up to 999 years. The value of a leasehold home reduces over time, as the remaining term reduces—it is often, therefore, referred to as a ‘wasting asset’. A leaseholder, in effect, purchases the right to live in their property for an agreed period, although statute gives tenants the right to extend their lease term or buy the freehold. Owners of leasehold properties are in a landlord and tenant relationship with their freeholder. Leases usually impose obligations on the leaseholder, such as the payment of a ground rent, and the freeholder. Other obligations may relate to repairs, so that freeholder and leaseholders know who is responsible for what, or so that neighbours can ensure rights of support or maintenance are enforced.
11.Many leaseholders reported that they were surprised to learn that they did not own the properties they had purchased in the same way as they might have owned a freehold property. One leaseholder, Jo Darbyshire of the National Leasehold Campaign, told us there was “a fundamental lack of understanding about what leasehold tenure means to consumers out there.” Shula Rich, from the Federation of Private Residents’ Associations, described leasehold as “the fag end of a timeshare… it is not owning anything” and called for greater clarity from the Government and industry that purchasing a leasehold should not be sold as the ‘ownership’ of a property in the same way as freehold. This was echoed by the National Leasehold Campaign, who told us:
[ … ] to avoid confusion, it would assist consumers to change the language we use when we refer to leasehold properties. We are not home owners, nor did we get Help to Buy anything other than the right to live in a building for the term of the lease. The Advertising Standards Authority should enforce this on advertising and marketing of properties.
12.There are clearly very significant differences between the freehold and leasehold tenures, but these are not always apparent to prospective leaseholders at the point of sale. As we will come on to recommend, this should be made much clearer to prospective purchasers from the start of the sales process. Our view is that it would be more appropriate to refer to this tenure as ‘lease-rental’. The Government and others may wish to use this terminology in future publications and policy statements.
13.Do freeholders provide a unique and valuable service, such that the financial cost to leaseholders—through ground rent, permission fees and enfranchisement costs—is justified? This question is key, not just in the context of proposals to move to alternative models of flat ownership, but also when considering policies that are likely to influence the incentives for freeholders to participate in the market, such as for a mandatory peppercorn ground rent or lower enfranchisement costs.
14.Reflecting much of the evidence from freeholders, City and Country Group told us that “the role of the professional freeholder cannot be underestimated”. Freeholders emphasised the long-term interest they have in their investments. Many contrasted the average tenure of flat lessees, who retain their properties for an average of between three and five years, with professional freeholders, who typically hold their investments for more than 50 years. The Home Builders Federation said the freeholder was the “custodian of the building or estate” and provided “a very long-term view on the decisions affecting the building and grounds”. Long Harbour outlined how this long-term presence was to the benefit of leaseholders:
A responsible freeholder plays a valuable role in protecting consumers by ensuring properties are maintained in the long-term interest of residents, managed in a professional and efficient manner and resolving not only critical issues such as fire safety but also ensuring peace and harmony within a residential dwelling block. This advantage [ … ] comes from the involvement of a freeholder responsible for the long-term interests of the development [ … ] In particular we have seen in the past decade, large and well-regulated institutions come into the sector, which has driven up standards: they have held managing agents to account and rooted out bad practices.
15.Mick Platt, representing the Wallace Partnership Group, told us that freeholders were the “ultimate safety net for leaseholders when things go wrong”. The removal and replacement of unsafe cladding from high-rise residential buildings was cited by Long Harbour “as an example of the role that freeholders play”, noting one example in Liverpool where the freeholder provided “emergency interest free loans to fund critical emergency measures, such as the presence of fire marshals on site 24/7, as well as works to remove and replace the unsafe cladding”.
16.However, fire safety was often noted as an area in which the leasehold system was not working as anticipated. Despite pressure from the Government, many freeholders have been reluctant to pay for the removal and replacement of the combustible cladding that many were ultimately responsible for commissioning. For example, Consensus Business Group told us they believed it was “reasonable that leaseholders rather than the freeholder should pay for the remediation works” and that the price paid for freeholds was on the understanding that the costs of remedial work were borne by leaseholders. This is in contrast to the Government’s position, which Heather Wheeler MP, Minister for Housing and Homelessness, articulated as, “No, freeholder. That is up to you, and it is up to your insurers behind you”.
17.The freeholders and developers we spoke to all supported the Government’s proposal to introduce a ban on “the unjustified use of leasehold on new houses” but argued that freeholders played a valuable role in the functioning of apartment blocks and mixed-use developments. In many buildings, freeholders are solely responsible for the selection of, and ongoing relationship with, the managing agent. By contrast, the commonhold model of ownership requires the residents to take over the stewardship of the block. The Minister for Housing and Homelessness told us that this was one of the key benefits of having a freeholder—someone who could manage this relationship on behalf of residents:
[ … ] there will be some people in blocks of flats who really just want to go home at 6 o’clock or 6.30, shut the door and have nothing to do with the running of it. They just want to pay a managing agent, have a freeholder and not have those concerns at all.
18.Others noted that ground rent and other charges are paid to freeholders regardless of the level of maintenance to the building or oversight they provide and argued that there was very little financial incentive for freeholders to promote the long-term interest of a building at all. Martin Boyd, from Leasehold Knowledge Partnership, told us that freeholders had “no genuine interest in maintaining the quality of the building”:
If it is a 999-year lease, they are not going to get it back for a very long time. It matters not to them whether it is in good condition or bad condition. It does to the people who live in and own the properties … When we had a third-party freeholder, he got no benefit from the building being in good or bad condition. His only benefit was from making a profit [ … ]
19.We are unconvinced that professional freeholders provide a significantly higher level of service than that which could be provided by leaseholders themselves, although we recognise that there are complexities in larger, especially mixed-use developments. The high premiums leaseholders are required to pay—ground rents, permission fees and enfranchisement costs—are paid regardless of the level of oversight the freeholder provides, and do not provide an obvious financial incentive for freeholders to work in the interests of leaseholders or promote the long-term condition of a building.
20.Developers and freeholders argued that dissatisfied leaseholders are not representative of the wider leasehold sector. The British Property Federation warned us that too great a focus on a minority of disaffected leaseholders risked “allowing leases to become demonised, without due regard being given to those who don’t have onerous leases”, leaving people feeling trapped in their homes, “which is simply not the case”. The Home Builders Federation insisted that leasehold “works very well for the vast majority” of the country’s leaseholders, and that most leases included fair and reasonable terms. Long Harbour told us that they had received complaints from just 0.07% of their leaseholders in the past year, with the vast majority of their leaseholders having a “tacit understanding that the relationship between leaseholder and freeholder is a positive one”. This was a view supported by the Minister for Housing and Homelessness, who told us, in the context of onerous ground rent terms, that it was important to put the problem in perspective:
We have not got on record how many of the 4 million freeholders have onerous leases. The ones that we have to crack down on are the onerous leases, so that varies, does it not, between 12,000 and 100,000? That is a much smaller figure than 4 million. Let us put it in perspective, Chairman.
21.Developers, freeholders and lenders told us that leasehold was a proven tenure that worked well. Jason Honeyman, Chief Executive of Bellway, said he “did not think there is anything wrong with leasehold tenure, particularly for apartment blocks”. Mick Platt, from the Wallace Partnership Group, told us that “the leasehold system works very well for the vast majority of leaseholders”. Matthew Jupp, representing UK Finance, explained that the view of lenders was that, while there were additional risks associated with leasehold properties when compared to freehold, “the leasehold market, as a whole, works fairly well”.
22.But others painted a less optimistic picture. A 2016 online survey of over 1,200 leaseholders conducted by the Leasehold Advisory Service (LEASE) found that 57% of leaseholders who responded said they regretted buying a leasehold property. Barry Gardiner MP and Jim Fitzpatrick MP, who provided evidence to our inquiry about the challenges in their constituencies, told us that their experience suggested that the figure could be even higher. Indeed, NAEA Propertymark published a report in September 2018 which claimed that 94% of leasehold homeowners who took part in their survey regretted buying a leasehold.
23.We heard that the relationship between leaseholders and freeholders was, at its core, fundamentally one of conflict. Professor Nick Hopkins, the Law Commissioner for property law, explained that part of the difficulty with the leasehold system was that it “immediately sets up that relationship of opposition” between freeholders and leaseholders, who will often have competing interests. This was a view shared by Guy Fetherstonhaugh QC, who told us that leasehold provided for an “antagonistic relationship”, where “the interests of landlords and tenants will not coincide.” This inherent conflict was clearly represented in some of the evidence we received from individual leaseholders, with one anonymous submission angry at what they perceived to be:
[ … ] the current, disgraceful system that is rigged against leaseholders and allows rip-off charges and exploitation of ordinary people by bullying, irresponsible developers and off-shore, tax-avoiding companies.
24.It was noted by a number of witnesses that the leasehold model was not used in most other countries. For example, Professor Hopkins highlighted that “the rest of the world manages those sorts of developments without needing that external third party there”, while Leasehold Knowledge Partnership told us that, “Almost nowhere else in the world continues with the archaic and deeply flawed leasehold system.” However, freeholders and managing agents noted that this did not necessarily mean that those other countries had preferable systems. For example, Richard Silva (Long Harbour) told us, “all those jurisdictions, without exception, have problems with those tenures”.
25.As we will go on to outline in this report, too often leaseholders, particularly in new-build properties, have been treated by developers, freeholders and managing agents, not as homeowners or customers, but as a source of steady profit. The balance of power in existing leases, legislation and public policy is too heavily weighted against leaseholders, and this must change. Our report sets out various recommendations for how this might happen.
26.We believe that there is a clear distinction between flats sold on leasehold terms and houses. We recommend that the sale of houses under leasehold should cease, as the Government has proposed, and urgent action be taken to enable those leaseholders in houses to be given the right to enfranchisement under appropriate low cost arrangements.
27.The Commonhold and Leasehold Reform Act 2002 introduced a new form of tenure, known as commonhold, as an alternative to leasehold. The main provisions of the Act came into force in September 2004. Commonhold allows for the ownership of a freehold flat within a larger residential development, participate in the management of communal areas and shared services, without the existence of leases or third-party freeholders. This form of ownership also operates in the Australian Strata Title system and the condominium system in the United States, as well as Belgium, France and Germany.
28.At its inception, the Government had assumed that commonhold would become the standard form of tenure for new-build blocks of flats. It was argued that commonhold had several advantages over the leasehold model, including that the freehold ownership did not expire, owners had an interest in the long-term well-being of the wider building and shared areas, and had much greater control over one-off costs and service charges. However, since September 2004, fewer than 20 commonhold properties have been registered, most of which have been of a very small scale—with a median size of 6.5 units, the largest being a caravan park of 30 units. We heard there were several reasons for the lack of commonhold developments.
29.Professor Nick Hopkins noted that there were “significant difficulties” with the commonhold legislation passed in 2002. In 2017, the Government asked the Law Commission to propose reforms “to re-invigorate commonhold as a workable alternative to leasehold, for both existing and new homes” as part of their Thirteenth Programme of Law Reform. The Law Commission published a consultation paper in December 2018, which sought to address the “various legal issues within the current commonhold legislation which affect market confidence and workability”, including legal issues around the creation of commonhold properties (including conversion), shared ownership, dispute resolution and enforcement powers.
30.We heard concerns from house builders that commonhold was not appropriate for mixed-use developments. Indeed, Professor Hopkins told us that that the Commonhold and Leasehold Reform Act 2002 was drawn up with modest developments in mind, and that the Law Commission did “not think the commonhold legislation we have is capable of dealing with the sort of mixed-use developments we see today”. He explained that the legislation assumed a community of interest between all owners within a commonhold development, but in situations where residential owners share a block with commercial owners, these interests do not always align. This was a view echoed by the Home Builders Federation, who told us that the practicality of commonhold for mixed-use developments was uncertain:
[ … ] in a layered commonhold structure the ability to alter service levels and relative contributions would ultimately rest with the uppermost tier, meaning that commercial operators may be subject to changes to the nature of the services it receives as a product of the commonhold decision-making process. This could affect business-critical services such as security or cleansing and the lack of certainty would either make commercial space less valuable or saleable, or involve fundamentally redesigning future schemes to clearly delineate commercial/leisure amenities and residential spaces even where this is inconsistent with good design and place-making principles.
As part of its project on commonhold reform, the Law Commission said it would “consider reforms to make the commonhold model more sophisticated and flexible”, to make it more appropriate for mixed-use developments and to allow different costs to be shared between unit-holders.
31.We were told that the reasons for the lack of commonhold developments since 2004 extended beyond inadequacies of the legislation. In particular, we heard there were a lack of incentives for developers to build commonhold, difficulties for residents in obtaining mortgage finance, and an unwillingness to take on the responsibility of managing a complex residential building.
32.We heard that there were insufficient incentives for developers to build commonhold properties. Leasehold properties provide developers with either long-term revenue through ground rents, permission fees, lease extensions and enfranchisement fees, or an asset to sell on to a freeholder. Commonhold provides none of these incentives. This was an issue highlighted by several witnesses, including Giles Peaker, a housing lawyer, who told us he did not think developers would be interested in commonhold unless there was a level playing field, “That is, effectively, removing ground rents and enfranchisement costs, or lease extension costs, as an income stream.” Professor Hopkins expressed his view that the Law Commission’s work would not address all of the reasons that commonhold has not taken off, and the issue of incentives for developers would also need to be addressed:
There are no incentives for developers. If it is a choice between selling commonhold with no income streams and selling leasehold, which has them, there is an incentive for developers to build as leasehold [ … ] Whether you tackle that by taking away those incentives, by providing incentives to developers to build commonholds in other ways, or a combination of both, is not really a question for us at the Law Commission to answer.
33.We were told by developers and freeholders that there was a reluctance by lenders to provide mortgages for commonhold properties. Long Harbour and the Home Builders Federation both highlighted that fewer than half of the top 20 mortgage lenders in the UK were willing to lend on commonhold properties. Several possible reasons were given for this. Taylor Wimpey argued that commonhold associations were at greater risk of insolvency, due to the fact that they cannot ultimately forfeit a unit for non-payment of the commonhold assessments (contributions), and this had put lenders off participating in the market. City and Country Group also told us that lenders were averse to commonhold due to the risk of insolvency, which, they said, could lead to buildings falling into disrepair, with no funding or freeholder to step in and remedy the situation.
34.However, UK Finance, which represents lenders accounting for 98% of the mortgage market in the UK, told us that 40 providers loaned against commonhold, and that this represented “a fairly reasonable, functioning market”. Matthew Jupp, representing UK Finance, indicated that the key issue for lenders was a lack of commonhold developments, which made it very difficult to assess commonhold risk. He told us, “If we started to see more being created by developers, more lenders would come through in terms of being willing to lend on them.” Indeed, Mr Jupp explained that, for mortgage lenders, “As long as the property is well maintained and looked after and has all the necessary insurance [ … ] it is just another way to hold property.” He told us that lenders supported the proposals put forward by the Law Commission “to help relieve concerns” around the issue of insolvency in commonhold properties.
35.Freeholders, such as the Ground Rents Income Fund, warned that residents in commonhold would lose the “consumer protections” found in the leasehold model, which come from “the involvement of a large-scale, well-resourced, professional freeholder with a long-term interest in the development”. Richard Silva, representing Long Harbour, argued that “it is just too complicated to expect people in their spare time to run their own affairs”, particularly in buildings of several hundred units, or with complex engineering infrastructure, combined heat and power plants and mixed tenures of residents. The City and Country Group asked whether we could “reasonably assume the average resident director has the skills, knowledge and willingness to manage and tackle issues with blocks and not pursue their own agendas which are not for the benefit of the wider-residents and building”, in the same way as a professional freeholder. These concerns were also expressed by Dr Nigel Glen, representing the Association of Residential Managing Agents (ARMA), who outlined the potential complexity for residents seeking to manage their own buildings:
Do not underestimate how much effort there is in actually managing a building [ … ] My concern is that you will have people who have potentially not the right set of skills or knowledge of property law in particular. When I had a company, there were many examples of people who had [resident management companies] instructing me to do things that, frankly, were against the law, but they did not know any better, because they were not familiar with the law.
36.The Home Builders Federation told us that it was not clear that a large proportion of apartment owners or prospective purchasers would necessarily wish to take an active role in the management and financial oversight of the communal facilities on their estate, or even be entirely responsible for the appointment, re-appointment and replacement of management companies. Indeed, ARMA highlighted that in Australia, which operates a model similar to commonhold, 37% of executive committees found it difficult to recruit members due to a variety of factors including time and perceived problems with the operation of the scheme. John Dyer, from the British Property Federation, told us that there were several examples of resident management companies having folded because not enough residents were willing to take on the administrative and legal obligations, telling us this was “an issue that I do not think there is a solution to.” Recruitment may be particularly challenging where the owners of properties are buy-to-let landlords, who may have less of a personal interest in the day-to-day management of a building.
37.However, Sir Peter Bottomley MP, co-Chair of the APPG on Leasehold and Commonhold Reform, told us it was wrong to suggest “that the leaseholders in my constituency are any less responsible or less capable than the freeholders” in managing their buildings, and noted that managing agents would remain responsible for the day-to-day management of buildings:
You do not need an outside person owning the building for it to be looked after properly. That is the managing agent at someone’s instructions, and the instructions could be from the leaseholders if they have the right to manage or if they have taken over the ownership of the property. It is not needed.
38.Despite problems with the legislation and wider concerns outlined here, we heard that commonhold could be made to work. Richard Silva, from Long Harbour, told us commonhold would be most suited to smaller, residential developments with willing participants who are happy to work together. Other witnesses had greater ambition. Professor Hopkins expressed his view that a reformed commonhold would leave no need for the leasehold tenure:
I would certainly say that, once we have commonhold in a way that works for the needs we have for development today, we do not need long residential leases. Commonhold solves the two underlying concerns that we hear about leases. Those are, first, that they are wasting assets and, secondly, that you have that relationship of opposition between the freeholder and leaseholder. Once commonhold is there and it is working, if you want a system of ownership that removes those underlying concerns with leasehold, you can use commonhold.
39.We heard calls for leasehold to be banned for newbuild properties generally (rather than just for houses), including from the Conveyancing Association, the Federation of Private Residents’ Associations and individual leaseholders. Sir Peter Bottomley MP noted that it would not be possible to convert existing leasehold properties to commonhold immediately, because there were so many properties affected. Instead, Martin Boyd of Leasehold Knowledge Partnership called for “a gradual transition of the existing stock”, a process of building new commonhold properties and providing realistic means for leaseholders to convert.
40.Several witnesses argued that there should continue to be a choice for residents between leasehold and commonhold. Guy Fetherstonhaugh QC expressed his view that there should not be a compulsory conversion to a commonhold, arguing that making people convert was a really bad idea: “There will be some people who think leasehold is fab and who will not want to change”. This was a view shared by the Minister for Housing and Homelessness, who told us “It is all about choice”.
41.We also heard that a ban on leasehold properties could have significant unintended consequences for retirement community residents and operators. ARCO (Associated Retirement Community Operators), which is the main body representing both the private and not-for-profit Retirement Community sector in the UK, told us that leases provided the legal basis for the obligations that exist between operators to residents, from residents to operators and residents obligations to one another. Leases also established the requirement for residents to meet the eligibility criteria to reside within a Retirement Community. ARCO warned that an outright ban on leasehold, including leasehold houses, would mean that its members would not be able to build and offer houses, only flats, at future developments. Similarly, the Retirement Home Builders Group told us that leasehold should remain available for the retirement sector, as “retirement housing needs a long-term steward to provide the care, support and maintenance services that are fundamental to the retirement living lifestyle.”
42.We urge the Government to ensure that commonhold becomes the primary model of ownership of flats in England and Wales, as it is in many other countries. The Government was right to have asked the Law Commission to review the legislation concerning commonhold, in particular to make it easier to convert leasehold properties to commonhold, and we urge the Government to act quickly once this review is completed to implement the Law Commission’s recommendations. However, if the Government is serious about promoting commonhold as a viable alternative to leasehold, it must also ensure that the incentives to build leasehold properties—particularly, monetary ground rents and permission fees—are more limited. At the same time, the Government will need to ensure that concerns regarding commonhold properties are meaningfully addressed, including ensuring appropriate resident participation in the management of buildings. This might include the provision of training to residents in management roles and ensuring external expert support is made available in extreme circumstances.
43.Our expectation is that once commonhold legislation is reformed, leaseholds begin to convert, and more commonhold developments are brought forward, leasehold as a tenure will become increasingly redundant. While it may be the case that some retirement properties and the most complex, mixed-use developments would continue to require some form of leasehold ownership, there is no reason why the majority of residential buildings could not be held in commonhold; free from ground rents, lease extensions, and with much greater control for residents over service charges and major works.
8 , press notice, Ministry of Housing, Communities and Local Government, 14 October 2018, and (Martin Boyd, Leasehold Knowledge Partnership) - LKP told us that the discrepancy arises from the inclusion of Welsh properties and flats in the social housing sector in their figures.
9 Leaseholders of certain properties, such as those on National Trust land, do not have such automatic rights. This issue will be explored further in Chapter Five.
10 Further background information can be found in: , House of Commons Library, 14 December 2018
11 (Jo Darbyshire, National Leasehold Campaign)
12 (Shula Rich Federation of Private Residents’ Associations)
13 National Leasehold Campaign (), para 44
14 City and Country Group (), para 10
15 Ground Rents Income Fund ()
16 Home Builders Federation ()
17 Long Harbour ()
18 (Mick Platt, Wallace Partnership Group)
19 Long Harbour ()
20 For example, (Sir Peter Bottomley MP, APPG on Leasehold and Commonhold Reform)
21 For example, Written Ministerial Statement (), 28 June 2018
22 Consensus Business Group (), para 3(h)
23 (Heather Wheeler MP, Minister for Housing and Homelessness)
24 , Ministry of Housing, Communities and Local Government, 15 October 2018 and, for example, (Mick Platt, Wallace Group Partnership, and Richard Silva, Long Harbour) and (Richard Silva, Long Harbour)
25 (Heather Wheeler MP, Minister for Housing and Homelessness)
26 (Martin Boyd, Leasehold Knowledge Partnership)
27 British Property Federation (), para 18
28 For example, Home Builders Federation ()
29 Long Harbour ()
30 (Heather Wheeler MP, Minister for Housing and Homelessness)
31 (Jason Honeyman, Bellway)
32 (Mick Platt, Wallace Partnership Group)
33 (Matthew Jupp, UK Finance)
34 , Leasehold Advisory Service
35 Barry Gardiner MP () and (Jim Fitzpatrick MP)
36 , NAEA Propertymark, September 2018
37 And family and trust law.
38 (Professor Nick Hopkins, Law Commission)
39 (Guy Fetherstonhaugh QC)
40 Anonymous ()
41 (Professor Nick Hopkins, Law Commission)
42 Leasehold Knowledge Partnership ()
43 (Richard Silva, Long Harbour)
44 , House of Commons Library, 14 December 2018, and , European University Institute (EUI) Florence/European Private Law Forum, 31 May 2005: “The fourth and most widespread model, to be found inter alia in Belgium, France, Germany and in England after the 2002 Commonhold and Leasehold Reform Act, combines separate ownership of an apartment with joint ownership “in forced indivision” of the land and the main structure of the building (such as walls and roof)”.
45 , House of Commons Library, 14 December 2018, section 4.1
46 Home Builders Federation ()
47 (Professor Nick Hopkins, Law Commission)
48 Ministry of Housing, Communities and Local Government (), para 9
49 , Law Commission, December 2018
50 (Professor Nick Hopkins, Law Commission)
51 Home Builders Federation ()
52 , Law Commission, December 2018
53 (Giles Peaker)
54 (Professor Nick Hopkins, Law Commission)
55 Long Harbour () and Home Builders Federation ()
56 Taylor Wimpey ()
57 City and Country Group (), para 14
58 (Matthew Jupp, UK Finance)
59 (Matthew Jupp, UK Finance)
60 (Matthew Jupp, UK Finance)
61 (Matthew Jupp, UK Finance)
62 Ground Rents Income Fund ()
63 (Richard Silva, Long Harbour)
64 City and Country Group (), para 13
65 Home Builders Federation ()
66 Association of Residential Managing Agents (), section 2(b)
67 (John Dyer, British Property Federation)
68 (Sir Peter Bottomley, APPG on Leasehold and Commonhold Reform)
69 (Richard Silva, Long Harbour)
70 (Professor Nick Hopkins, Law Commission)
71 Conveyancing Association (), Federation of Private Residents’ Associations () and, for example, Mr Chas Stewart ()
72 (Sir Peter Bottomley MP, APPG on Leasehold and Commonhold Reform)
73 (Martin Boyd, Leasehold Knowledge Partnership)
74 (Guy Fetherstonhaugh QC)
75 (Heather Wheeler MP, Minister for Housing and Homelessness)
76 ARCO - Associated Retirement Community Operators ()
77 ARCO - Associated Retirement Community Operators ()
78 Retirement Home Builders Group (), para 28
Published: 19 March 2019