44.The National Leasehold Campaign told us that they had evidence of “the blatant mis-selling of leasehold homes by developers’ salespeople, with misleading or lack of critical information to enable consumers to make an informed choice when buying a leasehold home.” Indeed, in the written evidence we received, we heard several accusations of mis-selling, primarily relating to false promises by developers’ salespeople and a failure of developer-recommended solicitors to highlight onerous terms in leases. This chapter explores these accusations of mis-selling and makes recommendations for how to provide greater clarity for prospective purchasers in the sales process.
45.In a recent report, NAEA Propertymark found that 78% leasehold house owners bought their home directly from a developer, rather than going through an estate agent, while 50% of those who purchased a leasehold house in the last 10 years were first-time buyers. Concerningly, they found:
… more than half (57%) didn’t understand what being a ‘leaseholder’ meant until they had already purchased the property, and 48% were unaware of the escalating ground rent until it was too late. When it came to completing the purchase, 65% used the solicitor their house builder recommended, who failed to tell 15% that they weren’t buying the freehold–they had to find it in the contract themselves. As a result, two thirds (62%) feel like they were mis-sold, while the majority (94%) regret buying a leasehold.
46.Many of the written submissions we received reinforced these findings. Several leaseholders, particularly house lessees, told us that, while they were aware they were buying a leasehold property, they were not told during the sales process how this was distinct from purchasing a freehold property or what the additional obligations would be. It was suggested to us that some leaseholders were even told by sales staff that their properties were ‘virtually freehold’:
She repeatedly told me that it was fine, the lease was virtually freehold because it was 999 years and that the only reason it was leasehold was because we would need to pay a service charge for the roads before the council adopted them in the future. She repeatedly told me that everyone would be in exactly the same position and at no point could freehold houses be sold on the estate. We were handed a leaflet, telling us all the benefits of leasehold, how it was virtually freehold—Mr Ashley Bishop
Repeatedly told ‘it’s basically freehold’ as it’s a 999-year lease and we can buy the freehold in two years anyway if we wish to. That this is the new way to sell houses everyone does it—Miss Alexia Dempsey
When we were offered to buy the leasehold property at a fair market price, we were advised [ … ] A 999-year lease is “equivalent to freehold” and neither you nor the next ten generation of yours would have to worry about renewing the leasehold—Mr Ellison Tomas
47.This was a trend noted by the Government in its response to its consultation into Tackling unfair practices in the leasehold market, where it said:
It is clear that many consumers did not make an active or informed choice to buy a new build leasehold house. Far too many homeowners report being surprised and distressed to learn that they did not own the freehold on their properties and that instead they had bought a depreciating asset, and/or to find that the freehold had been sold to a third-party investor. In many cases the cost to purchase the freehold had risen considerably, sometimes running into tens of thousands of pounds.
48.We also heard evidence from leaseholders that they were unaware of the terms within their leases at the point of sale, with some accusing their solicitors of negligence—which we explore later—and others telling us that developers’ salespeople failed to disclose these details to them. For example, Mrs Jody Murphy told us:
We now realise that we have an annual rent that can double every 10 years and can then be sold on and any kind of amount of money can be demanded from us from someone we don’t know who is just trying to line their pockets at the expense of myself and my family and many others in this position. Had I have known this at point of sale we would not have purchased the property.
49.Developers strongly rejected the accusation that they had mis-sold properties, arguing that leaseholders must have known what they were purchasing, given safeguards in the mortgage and legal process. Jason Honeyman, from Bellway, said, “I do not always subscribe to the idea that people were unaware of what they were buying.” David Jenkinson, representing Persimmon, told us he was not sure what more developers could have done:
You have to remember there are five clear points of contact when this would have been made out. At the reservation stage, it is clearly made out. They sign a reservation form. We are trained to tell them. When they meet their brokers, this has to be factored into their financial viability before they even apply for a mortgage. They had to know it was a lease. There is no way the solicitor would not tell them that it was a leasehold property and explain the ground rent. When they apply for their mortgage, it has to be filled in on the mortgage application form. Then, finally, the valuer takes account of it, and I have read the [UK Finance] rules. I am not sure what more we can do. I just cannot reconcile the information you are being told with how they would not know. They may not fully understand the implications of it, but they must have known it was leasehold.
50.Several organisations called for the implementation of a standardised key features document to be provided at the start of the sales process by developers or estate agents which would clearly outline the tenure of a property, the length of the lease, the ground rent and permission fees. For example, the National Trust called for “some form of key facts document which professional advisers have to give to leaseholders when they purchase a lease (whether an existing or new lease).” The Conveyancing Association called for anyone marketing a leasehold property to provide upfront information, with Beth Rudolf explaining:
The idea of upfront information is key [ … ] Something where all that information is available and set out in a “what that means to you” way, as you describe, would make a huge difference. People could then make an informed choice before they put their offer in, understanding what it means to them now.
51.It is clear that many of the leaseholders we heard from were not aware of the differences between freehold and leasehold at the point of purchase, in particular the additional costs and obligations that come with a leasehold property. The Government should require the use of a standardised key features document, to be provided at the start of the sales process by a developer or estate agent, and which should very clearly outline the tenure of a property, the length of any lease, the ground rent and any permission fees.
52.We received a substantial number of submissions accusing developers of reneging on promises made by their sales teams to allow leaseholders to purchase their freeholds at an agreed price after two years. Leaseholders told us that their freeholds had been subsequently sold on—without having given them the opportunity to purchase the freehold themselves—to third party investors, who were not willing to allow leaseholders to purchase their freeholds at the same price offered during the sales process. It was surprising—and revealing—how many similar stories we heard, of which these were just a small sample:
When the majority of us bought our new-build houses, we were told [ … ] “Do not worry; you can buy it after two years for a couple of thousand pounds” [ … ] Unbeknown to us, by the time we got to our two years, when we were legally entitled to buy our freehold via enfranchisement, our freeholds had been sold on in the interim [ … ] For me personally, the price rocketed from £3,000 or £4,000 up to £13,000—Katie Kendrick
Told by the sales executive that the lease could be bought at a later date and it would cost in the region of £5,000. At no point was it mentioned that the lease could be sold on to another company [ … ] The developer sold the lease on without our knowledge within 12 months of being at the property. Residents on the estate have enquired about buying their lease and have been quoted £10,000 plus. On top of this figure are the legal fees to complete the process. This is far more than originally told by the sales executive—Ian Ashmore
In the verbal conversation with the saleslady at the time [ … ] She said, “Okay, you can buy the freehold at any point for about £5,000” [ … ] The freehold was sold, 11 months later, to an offshore investor. It was not until the summer of 2016 [ … ] they wrote to the management company for a quote to buy the freehold. That costs £108, by the way, just to ask for a quote. The quote they got back was over £50,000. We held a residents meeting, because somebody else had written and said, “That cannot be right. It must be a typo”. They got a different number but that was over £40,000—Jo Darbyshire
53.Developers denied that leaseholders had been misled during the sales process. In correspondence, Bellway told us, “We do not accept the position of some customers that they were given a verbal offer whereby they could purchase the freehold of their property at a future date for an agreed price”, noting that this would constitute an option to purchase the property without an end date, which is not permitted by law. However, developers admitted that they often sold freeholds without consultation with leaseholders. Jason Honeyman, representing Bellway, told us that this was not a scandal:
Yes, we are [ … ] It is how we have always operated as a business. I am sure that is not the answer you want [ … ] I am not sure I subscribe to it as a scandal. You are offered at the point of sale a freehold and a leasehold, and the law says that you have the right to acquire the freehold after two years of living in it. You are right. You are quite right. You are 100% right that I sell that basket of freeholds to an investor without asking the customer whether they would like to buy it again.
54.The Landlord and Tenant Act 1987—described to us by Guy Fetherstonhaugh QC as “probably judges’ least favourite piece of parliamentary drafting” due to the number of loopholes it presented—placed a duty on freeholders of blocks of flats to offer a ‘right of first refusal’ to leaseholders when they are seeking to dispose of their interest. There is no duty on a freeholder of a house to inform the leaseholder of a change in ownership, nor does the leaseholder have a right of first refusal to buy the freehold interest at that point. It has been suggested that leaseholders of houses should be given a right of first refusal to ensure that freeholders offer the sale of the freehold interest to the leaseholder before selling to a third party. In its response to its consultation into Tackling unfair practices in the leasehold market, the Government suggested that transfers to third parties without the leaseholder’s knowledge were not in consumers’ best interests, and it would “consider introducing a right of first refusal for house lessees.” The Law Commission is also looking at a potential right of first refusal for house lessees as part of its Thirteenth Programme of Law Reform.
55.An extension of the right of first refusal was a change supported by several organisations, including Taylor Wimpey, but others told us that the right of first refusal required more fundamental reform. Indeed, the Law Commission noted in its enfranchisement consultation “suggestions that the right should be abolished or, if retained, improved.” Housing lawyer, Giles Peaker, expressed his view that the right of first refusal needed to be revisited, in particular the ability of companies to avoid the right of first refusal by transferring shares in a freehold to another company. Developers are able to avoid the right of first refusal by contracting with the third party before granting the lease to the home buyer; or they can register the freehold interests to an “associated company.” The developer can sell the shares—and therefore the freehold interests—in that associated company to an investor. Under this arrangement, owner-tenants have no right of first refusal, leaving them to exercise any right to enfranchise. In August 2017, Business Insider reported that Persimmon and Bellway, had engaged in this practice.
56.The right of first refusal currently only applies to leasehold flat owners. The Government is right to seek to extend this right to leasehold house owners. The Government must also close the legal loophole allowing developers to sell freeholds to subsidiary companies, which means leaseholders lose out on the opportunity to purchase the freehold at whatever price it is offered to the new freeholder. This would benefit both new and existing properties.
57.The standardised key features document we recommend should also include, prominently, a price at which the developer is willing to sell the freehold within six months or, otherwise, a prescribed statement that the developer is not so willing, and that the purchaser would have to rely on their statutory rights.
58.Several witnesses drew parallels with the mis-selling of Payment Protection Insurance (PPI) by banks to 12 million customers. Jim Fitzpatrick MP, Deputy Chair of the APPG on Leasehold and Commonhold Reform, agreed, telling us that “It goes that deep.” Jo Darbyshire, representing the National Leasehold Campaign, said:
I know Jim said earlier that this was the PPI of the housing industry. For me, it absolutely is. I do not think it is a coincidence that all these developers suddenly adopted a very similar business model in terms of leasehold houses at the same time [ … ] Any kind of financial mis-selling, whether it be mortgages, PPI or pensions, has been subject to an independent inquiry and a redress scheme that sets out to put consumers back in to same financial position they would have been in, had they not been missold in the first place.
59.Others argued that this was a difficult comparison to make, with PPI having being mis-sold on a far larger scale and in a variety of ways which did not compare easily with unfair terms in leases. For example, PPI was sold “without the customer’s knowledge, or sold as ‘essential’, or sold to people such as the self-employed who would never be able to claim”, which did not apply in the case of leasehold. Asked whether it was fair to make a comparison with PPI, Jennie Daly, representing Taylor Wimpey, said she “would not agree with that comparison”, while Jason Honeyman emphasised that “I do not believe we have mis-sold”. The Minister for Housing and Homelessness told us the Government did not agree that leasehold sales practices were akin to the mis-selling of PPI:
I find that a very difficult comparison because, in effect, with PPI, you were sold something you really did not need, whereas this is completely different, isn’t it? It is a contract and there was legal advice, but perhaps people are caught up in the moment because it is their first purchase and it is incredibly exciting: “That is the estate we want to live in, in that village, and this is the only place that you can get a property.” It is very difficult [ … ]
60.In November 2018, the Secretary of State wrote to the Competition and Markets Authority (CMA)—a non-ministerial department with responsibility for enforcing consumer protection legislation to tackle practices and market conditions that make it difficult for consumers to exercise choice—urging them to undertake a market study into the effects of onerous ground rents and to bring a test case, “to empower thousands of leaseholders to challenge the terms of their leases and would have a significant effect on the industry, bringing pressure on it to voluntarily address the issues.” However, the Minister explained that the CMA had been “quite strong in saying that it does not think that there needs to be an inquiry because we know the facts”, noting the recent Government consultation into the issue and this inquiry. Indeed, a CMA spokesman recently said that “the issues around ground rent clauses are well known and a market study would shed little further light”. However, others have called on the CMA to use its powers to enforce competition law, including the enforcement of prohibitions on the use of unfair terms or unfair business practices. LKP argued that the CMA’s inactivity meant individual leaseholders had been left to fight their own cause.
61.Developers denied that their sales teams deliberately misled leaseholders with partial sales information and false promises of purchasing their freeholds at an agreed price. But the number of near-identical stories from leaseholders reflects a serious cross-market failure of oversight of sales practices. Some affected leaseholders may have a strong claim that their properties were mis-sold. The Competition and Markets Authority should investigate mis-selling in the leasehold sector within the next six months and, where appropriate, make recommendations for appropriate compensation, with the option of enfranchisement.
62.While developers have been accused of providing misleading sales information or imposing onerous terms in leases, ultimately it was the responsibility of conveyancing solicitors to ensure prospective purchasers of leasehold properties were aware of the ownership structure and lease terms and their effect. It is the conveyancing solicitors, as opposed to the developers, who could be legally liable for failing to highlight these terms to prospective leaseholders. It was concerning, therefore, to hear several reports from leaseholders that they had been advised, incentivised or required by the developer to use a specific conveyancing solicitor, who subsequently did not advise them of onerous terms in their leases.
63.It is not uncommon in other industries for companies to recommend a panel of solicitors to their clients, and there is nothing inherently wrong or unlawful in developers doing so. Developers and solicitors representatives told us that such relationships were for the benefit of customers. David Jenkinson told us, “The real reason Persimmon uses a panel of solicitors is to save the customer money because they only need to review the title once. If you go each individual time, the biggest part of actual cost from a sale is to review the title.” Jonathan Smithers, representing the Law Society of England and Wales, highlighted the volume of work for new developments:
If you are acting for a client on a new development, you may get a massive amount of information to digest. If it is a large development, the site may have been made up of five, 10, 15 or 20 different titles, all of which you have to look through. There are road agreements, planning agreements and so on to familiarise yourself with. If you are doing that and everyone is doing that, again and again, you are reinventing the wheel. It is very helpful for a buyer to have an independent firm—and it may be one of a panel that developers recommend, which has had the time to go through all that, so they do not have to keep on doing it every time. It can be to the buyer’s real advantage.
64.As a matter of professional conduct, the Solicitors Regulation Authority (SRA) makes it clear that any arrangement with a third party who introduces business “should not jeopardise that trust by, for example, compromising your independence or professional judgement.” Jonathan Smithers explained that “the important thing is that the buyer has the ability to have independence of choice, so the developer does not say, ‘I will only accept your offer if you go with this conveyancer’.”
65.However, we received considerable evidence of developers incentivising and insisting on the use of a specific conveyancing solicitor. Katie Kendrick, representing the National Leasehold Campaign, told us that members of her group had been offered “free carpets, free lawn in the back gardens [ … ] a discount off other parts of the house, if they were to use their panel of solicitors”. Other leaseholders told us developers were more insistent:
We originally wanted to use the solicitor we used on our previous house purchase. Taylor Wimpey held back information from them to the point that my solicitor told us if we didn’t use [their] recommended [solicitor] there was no way we would complete within the eight-week deadline—Mr Lee Bennett
[ … ] people had been told that they could not use their own solicitors and were made to use the ones that Persimmon recommended—Mrs Rebecca Delaney-Cowley and Mr Dean Cowley
Taylor Wimpey pushed me to use their recommended solicitor by offering £500 towards legal fees and threatened that the sale would fall through if I didn’t complete within 28 days, and Bannister Preston were the only solicitors they could be sure would hit this deadline—Mr Robert Bater
66.Reflecting on some of this evidence, Beth Rudolf, representing the Conveyancing Association, told us that conveyancing solicitors should have refused the instruction in where clients have been unethically acquired:
I am not here to defend developers. That all sounds very wrong if people are being coerced into doing something that is not in their best interests. As we have said, as conveyancers we are heavily regulated and we should not be accepting instructions from clients where they have been acquired through something that is in breach of our regulations. If any conveyancer was aware of that, they should have refused the instruction.
67.Consumers must be able to access independent and reliable legal advice when purchasing a property. Their interests cannot be served where they are coerced into using developer-recommended conveyancing solicitors, who rely on repeat business from developers and may not be inclined to put their client’s interests first. The Government should prohibit the offering of financial incentives to persuade a customer to use a particular solicitor. Further, as outlined above, key sales information should be provided at the start of the sales process in a standardised key features document, so purchasers are in no doubt about the costs involved in purchasing a leasehold property.
68.The reports of such coercive practices are particularly concerning in the context of evidence that some developer-recommended conveyancing solicitors failed to draw clients’ attention to the ownership structure or onerous lease terms. We received several submissions making such allegations, of which these are just a small selection:
I was told we needed to complete quickly and that we MUST use their recommended solicitor. This solicitor never warned us about permission fee to re-mortgage, build a conservatory and even change the colour [of] our front door. Also, we were never told that the ground rent was increasing with RPI every 10 years—Mr Joel Da Costa
[ … ] the sale was rushed through with the solicitor that I was told to use [ … ] I was not told exactly what the implications were for the onerous terms of the lease, and everything was made out to be part of the normal process of buying a house—Dr Ellen Fry
We were urged by Taylor Wimpey to use a recommended solicitor as it would speed things up during the sales process. At no point was it brought to our attention by the recommended solicitors that there was a doubling ground rent or that there were such restrictive covenants in place meaning we would have to ask permission to make any alterations to the property and face exorbitant fees just to ask permission—Mr Dan Hamer
69.While developers may have included onerous terms in leases, it was the responsibility of solicitors to highlight these to their clients. As noted in case law, a solicitor should advise about an unusual clause in terms “appropriate to the comprehension and experience of the particular recipient”, and if a solicitor should be “alerted to risks which might elude even an intelligent layman”, it is their duty to advise the client about the risks. Jennie Daly, representing Taylor Wimpey, also emphasised that it was the solicitor’s responsibility to act independently on behalf of their client, whether or not they were identified as part of a panel of solicitors: “Even if they are on the panel that we recommend, the first duty of that solicitor is to their client. It is the solicitor’s responsibility to ensure the customer is fully aware of both the ownership structure of the property and the terms of any lease.”
70.Solicitors’ representatives highlighted that buyers had very little scope to negotiate with the large developers, however onerous the proposed terms were. Jonathan Smithers, representing the Law Society, said:
[ … ] I think that the number of developers getting much smaller and the power that they now have to effectively impose their conditions—because the buyer cannot go anywhere else to buy a house; they have to buy it from them—means they have much greater market power to say, “These are the papers. Take it or leave it.” The solicitor acting for the buyer is not really in a position to negotiate. All they can do is say to the buyer, “These are the terms. If you want to buy the house, you have to sign here, because I cannot negotiate individual terms in the way that, 20 years ago, I could with a local developer.”
71.Further, the solicitors’ representatives argued that, late in the sales process, many buyers are unable to consider such details. Jonathan Smithers told us it was difficult for solicitors to know how much of the legal information—which, “for a brand-new development, it could be an A4 lever-arch file”—the buyer had absorbed. Beth Rudolf, from the Conveyancing Association, highlighted the difficulties in communicating complex information to prospective leaseholders who had “already fallen in love with the property”, and called for more information to be provided at the very start of the sales process:
The problem is that, by the time the buyer gets [the legal documentation], with 14 days to exchange contracts or lose their deposits or lose their incentives, they are not in a position to absorb any of it. The time they should have been told was the point when they viewed the property [ … ] By the time the poor buyer gets hold of all of this, they have already fallen in love with the property. They have already worked out where their sofa is going to go and where the kids will go to school. They are in no position to absorb all of this and then make an unemotional decision about whether to continue to proceed, at a point when they are properly committed financially, after paying for searches, surveys, mortgage product fees—probably as much as £1,200.
72.It was extremely concerning to hear from so many leaseholders that their developer-recommended solicitors had failed to advise them of onerous terms in their leases. Such evidence suggests that some conveyancing solicitors have become too close to developers and did not put their client’s interests first. This does not, however, absolve developers of the blame for taking advantage of their dominant position and creating such leases in the first place. Buyers should be encouraged to ensure that they seek independent legal advice.
73.In its response to its consultation into Tackling unfair practices in the leasehold market, the Government said it would support consumers in seeking redress from solicitors who failed to fulfil their legal duty to inform prospective purchasers of leasehold properties of escalating ground rents and other onerous terms:
To help consumers access justice we will work with the redress schemes and Trading Standards to provide leaseholders with comprehensive information on the various routes to redress available to them, including where their conveyancer has acted negligently.
74.This appears welcome—although the specific actions and timings remain imprecise—as the National Leasehold Campaign informed us that leaseholders were not clear about routes to redress, and those that had tried to seek redress for mis-selling and negligent conveyancing solicitors had found it “extremely difficult to get any kind of meaningful resolution.” Martin Boyd, representing Leasehold Knowledge Partnership, told us that some claims against solicitors had been made, but many had become subject to Non-Disclosure Agreements, which had made it difficult for other leaseholders to gauge the benefits of taking such action. He also noted the cost of pursuing legal action, which for many people—particularly the first-time buyers who bought leasehold houses—was prohibitive. Jo Darbyshire, from the National Leasehold Campaign, also raised this issue, noting that she would need to either pay for the legal action herself, or find a solicitor willing to take it on a no win, no fee basis—of which, there were very few.
75.The usual limitation period for negligence claims is six years after the damage has been suffered. For negligent conveyancing advice, this would usually run from the date the lease was acquired. If the purchaser did not know the ‘material facts’—roughly, enough that a reasonable person would think it serious enough to litigate (assuming the defendant admitted fault and could afford to pay up)—then the period would run for three years from the discovery of those facts, but not more than 15 years after the lease was acquired. The complexity of proving professional negligence, as well as the time limits, were noted by leasehold campaigners as key barriers to redress:
The situation is complicated by the six-year rule as many leaseholders did not realise their conveyancing solicitor was negligent until six years or more had passed from the point of sale. Although the six-year rule can be challenged, a favourable outcome is not guaranteed, and leaseholders need to find funds for a challenge.
76.Which? noted that individual professional negligence claims are one route of redress, but this would result in claims against hundreds of individual solicitors rather than developers. They also noted that the costs of litigation were a deterrent to leaseholders, so suggested that a dedicated Alternative Dispute Resolution (ADR) scheme—an independent arbiter between the service provider and the customer when an initial complaint cannot be resolved, avoiding the need to go to court—may be required. Jonathan Smithers, representing the Law Society, told us that he had not seen any evidence “that a separate redress scheme would be better than the existing redress scheme”, and told us that the Legal Ombudsman was a sophisticated regulator which was well-placed to provide a route to redress.
77.In November 2018, the Secretary of State wrote to the Solicitors Regulation Authority (SRA) urging them to investigate complaints against conveyancing solicitors, saying he was “troubled by some of the evidence I have received.” The Minister for Housing and Homelessness reported that the SRA advised referring complaints to the Legal Ombudsman:
The SRA have been very [ … ] clear that, where there is any evidence of lack of clarity as between the guidance for a solicitor or a conveyancer who they are acting on behalf of, because of course they are acting on behalf of the person buying the property, get the evidence to the SRA and let us get the Legal Ombudsman involved.
78.The Government needs to act on its promise to help leaseholders seek to redress where they have been let down by their conveyancing solicitors. The Government should undertake a review within the next six months to determine whether existing routes, including to redress the Legal Ombudsman’s scheme, are satisfactory or whether a new Alternative Dispute Resolution (ADR) scheme should be established for leaseholders with legitimate claims against their solicitors.
79 National Leasehold Campaign (), para 3
80 , NAEA Propertymark, September 2018
81 Mr Ashley Bishop ()
82 Miss Alexia Dempsey ()
83 Mr Ellison Tomas ()
84 , Department for Communities and Local Government, December 2017, para 35
85 Mrs Jody Murphy ()
86 (Jason Honeyman, Bellway)
87 (David Jenkinson, Persimmon)
88 National Trust (), para 14
89 (Beth Rudolf, Conveyancing Association)
90 (Katie Kendrick, National Leasehold Campaign)
91 Mr Ian Ashmore ()
92 (Jo Darbyshire, National Leasehold Campaign)
93 , 11 December 2018
94 (Jason Honeyman, Bellway)
95 (Guy Fetherstonhaugh QC)
96 , House of Commons Library, 14 December 2018
97 , Department for Communities and Local Government, December 2017, para 72
98 Taylor Wimpey ()
99 , Law Commission, September 2018, Para 1.71(3)
100 (Giles Peaker)
101 , Business Insider, 15 August 2017
102 (Jim Fitzpatrick MP)
103 (Jo Darbyshire, National Leasehold Campaign)
104 , The Guardian, 5 May 2011
105 (Jennie Daly, Taylor Wimpey, and Jason Honeyman, Bellway)
106 (Heather Wheeler MP, Minister for Housing and Homelessness)
107 Letter from Rt Hon. James Brokenshire MP, Secretary of State for Housing, Communities and Local Government, to Dr Andrea Coscelli, Competition and Markets Authority, 2 November 2018
108 (Heather Wheeler MP, Minister for Housing and Homelessness)
109 , Mail Online, 9 March 2019
110 (Martin Boyd, Leasehold Knowledge Partnership)
111 (David Jenkinson, Persimmon)
112 (Jonathan Smithers, Law Society of England and Wales)
113 , chapter 9
114 (Jonathan Smithers, Law Society of England and Wales)
115 (Katie Kendrick, National Leasehold Campaign)
116 Mr Lee Bennett ()
117 Rebecca Delaney-Cowley & Dean Cowley (), section 2
118 Mr Robert Bater ()
119 (Beth Rudolf, Conveyancing Association)
120 Mr Joel Da Costa ()
121 Dr Ellen Fry ()
122 Mr Dan Hamer ()
123 County Personnel (Employment Agency) Ltd v Alan Pulver & Co  1 WLR 916, 922. See also, Crozier R, , (Sep 1998) 168 NLJ 7809, p15
124 (Jennie Daly, Taylor Wimpey)
125 (Jonathan Smithers, Law Society of England and Wales)
126 (Jonathan Smithers, Law Society of England and Wales)
127 (Beth Rudolf, Conveyancing Association)
128 , Department for Communities and Local Government, December 2017, para 71
129 National Leasehold Campaign (), para 32
130 (Martin Boyd, Leasehold Knowledge Partnership)
131 (Jo Darbyshire, National Leasehold Campaign)
132 Limitation Act 1980 s 14A(7) and 14B
133 National Leasehold Campaign (), para 32
134 Which? ()
135 (Jonathan Smithers, Law Society of England and Wales)
136 Letter from Rt Hon. James Brokenshire MP, Secretary of State for Housing, Communities and Local Government, to Paul Philip, Solicitors Regulation Authority, 2 November 2018
137 (Heather Wheeler MP, Minister for Housing and Homelessness)
Published: 19 March 2019