Today sees the launch of a campaign calling on the government to help fund the recladding of the private blocks impacted by ACM cladding led by InsideHousing in support of the UK Cladding Action Group (UKCAG). LKP is proud to help support this campaign along with many other groups and MPs including leasehold and commonhold reform APPG co-chairs Sir Peter Bottomley and Jim Fitzpatrick.
Jim Fitzpatrick MP has said
“No one should be left in the position of having worked and saved for years to become a property ‘owner’, to then learn – through no fault of their own – their home is no longer safe. This campaign rightly highlightsthe consequences of inaction and I urge the Government to take responsibility as a matter of urgency.”
As part of the campaign LKP have organised a Cladding Forum to be held in Westminter on the 8th May.
The campaign calls for :
- Government provides a fund to cover the cost of cladding removal and remedial works on private blocks
- A firm timescale set out of no more than two years for the work to be carried out
- Residents reimbursed for the interim fire safety costs incurred, and funding to be provided for necessary internal fire safety measures identified by a competent fire risk assessor
A recent written answer from Minister Kit Malthouse confirms there are about 16,600 flats in private blocks that still have cladding.
It is now 680 days since the Grenfell tragedy and UKCAG has just completed a survey of the stress felt by those living in private cladding sites. The results of the survey speak for themselves:
Key findings:
- As of 22/04/19, a total of 196 leaseholders from 21 building blocks across 10 boroughs had taken part.
- 64.8% (127) of respondents said that as a direct result of the ongoing situation their mental health had been ‘hugely affected’, with 87.8% (172) stating that their mental health is worse now than it was prior to the ongoing situation.
- 69.5% (89) of live in leaseholders said they feel anxious and/or worried on a daily basis when they think of their future in relation to the ongoing situation.
- 92.3% (181) of respondents said they have money worries, 84.7% (166) said they felt unsupported by the Government and 61.7% (121) said they had worries about their own or family members safety.
- 8.7% (17) stated they had had suicidal thoughts or feelings of self-harm as a direct result of the ongoing situation.
- Respondents complained of stress 81.6% (160), anxiety 77.6% (152), difficulty sleeping 65.8% (129) and depression 23% (45), with 25.5% (50) of respondents having sought medical help as a direct result of the situation.
- 36.7% (72) of respondents said that as a direct result of the ongoing situation an existing medical condition had been made worse.
- 77% (151) of respondents said that as a result of ongoing situation their relationships with friends and family have been affected with many using coping mechanisms such as alcohol 38.3% (75) and excessive or restrictive eating 20.4% (40).
- 86.2% (169) of respondents said their service charges have risen as a result of the ongoing situation.
- 57.7% (113) of respondents said they had had to place family holidays and miscellaneous item purchases on hold, 25% (49) said they felt they cannot start a family and 30.1% (59) say they have had to seek financial help from family and friends.
Demographics
- As of 22/04/19, a total of 196 leaseholders from 21 building blocks across 10 boroughs had taken part.
- 62.8% (123) of respondents were aged between 25-44 with 37.2% (73) aged between 25-34 – supporting the argument that the large majority of leaseholders who find themselves in this situation are most likely to be first-time buyers.
- 65.3% (128) of respondents were live in leaseholders.
- 1.5% (3) of respondents were renting tenants.
Mental Health
- 64.8% (127) of respondents said that as a direct result of the ongoing situation their mental health had been ‘hugely affected’, with 87.8% (172) stating that their mental health is worse now than it was prior to the ongoing situation.
- As a direct result of the ongoing situation:
- 92.3% (181) said they money worries,
- 89.8% (176) said they had feelings of anxiety,
- 84.7% (166) said they felt unsupported by the Government,
- 81.1% (159) said they had feelings of anger,
- 62.8% (123) said they felt unsupported by local authorities,
- 61.7% (121) said they had worries about their own or family members safety, and
- 60.7% (119) said they had feelings of hopelessness. Other feelings expressed included those of worthlessness, sadness, frustration, confusion, desperation and feeling of injustice.
- Of great concern was the fact that 8.7% (17) stated they had had suicidal thoughts or feelings of self- harm as a direct result of the ongoing situation.
- Many respondents told us, that as a direct result of ongoing situation, they were experiencing mental health conditions such as:
- o stress, 81.6% (160), o anxiety, 77.6% (152), o depression, 23% (45), and o PTSD 1.5% (3).
- 65.8% (129) said they were having difficulty sleeping with 42.3% (83) saying they had experienced increased tiredness.
- 58.7% (115) of respondents said they feel anxious and/or worried on a daily basis when they think of their future in relation to the ongoing situation; amongst the 128 respondents that are live in leaseholders that figure increased to 69.5% (89).
- 25.5% (50) of respondents had sought medical help as a direct result of the situation. 32.1% (63) stated they intended to seek medical attention.
- 15.3% (30) of respondents stated that they had commenced medication or treatment (including counselling) to help them cope.
Physical Health
- 55.1% (108) of respondents stated that their physical health is worse now than it was prior to the ongoing situation.
- 28.1% (55) stated that they had received a formal diagnosis from a health professional as a direct result of the ongoing situation. In these respondents diagnosed conditions included:
- headaches or migraines, 45.5% (25)
- heart disease (including high blood pressure), 20% (11)
- gastrointestinal problems (such as IBS), 25.5% (14)
- skin conditions (such as psoriasis), 31% (17) o shingles, 1.8% (1) o diabetes, 3.6% (2)
- 36.7% (72) of respondents said that as a direct result of the ongoing situation an existing medical condition had been made worse. Responses relating to this question included the worsening or exacerbation of the following conditions: post-surgery healing, asthma, alopecia, psoriasis and other skin conditions, blood pressure, depression, eating disorders, anxiety, stress, insomnia, headaches, fatigue, tinnitus, chronic pain, migraines, IBS, PTSD and pregnancy related problems.
Social Wellbeing & Coping Mechanisms
- 77% (151) of respondents said that as a result of ongoing situation their relationships with friends and family have been affected with one respondent stating the strain the situation has placed on their relationships with friends and family has resulted in them directly seeking help from a psychotherapist. Several leaseholders said that relationships had broken down as a result of the situation.
- Coping mechanisms to deal with the stress and strain of the ongoing situation included alcohol 38.3% (75), excessive or restrictive eating 20.4% (40), smoking 10.7% (21), drugs 3.6% (7) and self-harm 1% (2).
- Coping mechanisms were used in a total of 52% (102) respondents.
Finances
- 86.2% (169) of respondents said their service charges have risen as a result of the ongoing situation, with 25.5% (50) stating that thus far between 50-200K had been spent in their buildings as a result of the failed cladding. 24% (47) of respondents stated that over 200K had been spent.
- As a direct result of the ongoing situation:
- 57.7% (113) said they had had to place family holidays and miscellaneous item purchases on hold,
- 66.3% (130) have been told by surveyors that their property is not currently sellable, o 30.1% (59) have had to seek financial help from family and friends,
- 28.1% (55) said they were unable to move job locations or take a promotion, with 29.1% (57)
- saying they have had to put things that would further their career (such as further education) on hold, o 25% (49) said they felt they cannot start a family,
- 14.3% (28) said they have been refused a remortgage on their property or forced onto a variable rate mortgage,
- 13.3% (26) said they felt forced to cash sell their property,
- 10.7% (21) have had to take a loan out to cover increased costs,
- 5.6% (11) said they had been forced to remain in a relationship because they are unable to sell. Other financial concerns expressed included reduced pension funds, retirement concerns, the need to work a second job and relationship breakups directly related to finances.
Related posts:
Brokenshire wrongly says freeholders have paid for Grenfell cladding removal
Brokenshire announces £200m Grenfell cladding removal fund – hours after APPG meeting of leaseholders
Tchenguiz group dismisses government ‘hollow threat’ to make freeholders pay for Grenfell cladding removal
The show must go on with Grenfell ACM cladding removal, says government … as the fire test it didn’t want YOU to see reveals HPL panels were lethal all along
Grenfell United link up with leaseholder groups to protest cladding crisis and warn next government of Grenfell 2
Freeholders’ ‘cowboy’ insurance commissions at leaseholders’ expense attacked in The Times
Amazes me Government has ducked paying for this scandal long times back.
Hapless citizens buying homes (especially in blocks of flats) have to rely on the safety and standards regulatory framework created by their Government. What seriously could go wrong? This is the UK after all.
If politicians can’t keep citizens safe in their beds they ought to b****r off and keep pigs. God help the pigs, mind.
So let me ask the question? Government has allowed to create this mess, freeholders jumped in to do cheaper works. The government pays – what do the “custodians of the buildings” – do ?
Sadly that is the whole point of English ‘long’ leasehold. The lease is usually worded so that every potential cost falls on the leaseholder.
No such thing as a ‘custodian’ of the building. Maybe the agent, but guess who pays? The freeholder holding the freehold title of long leasehold is merely a landlord because that is the only term English law allows. The freeholder in practice is an investor. Liable to pay nothing unless volunteers, or a court finds some cost or other is unreasonably incurred or not liable for leaseholders to pay under the lease. Even then, leaseholders might end up paying landlord’s court costs under the lease to get this ruling.
One of the cleverest laws ever invented in ye Old England is long leasehold tenure. Hands up all the freehold ‘landlords’ in parliament?
Ah go on…
The Housing Minister has been facing the problem of combustible insulation on tower blocks and some freeholders are refusing to pay for repair of the building.
The Housing Minister has been facing the problem of toxic leases with ground rent doubling up every 10 years and making the property becoming unsaleable.
The Housing Minister has been running around consulting the the developers and freeholders and still not able to find an acceptable solution. The Minister is out of his depth because he has not recognised the difference between freehold title and leasehold title.
“Freehold title” gives the buyer legal ownership of the property .
But ” Leasehold title” gives the buyer legal ownership of a long term rental agreement which is entered on unfair terms for the buyer and commits the buyer to paying ground rent for the entire term of the lease 99 or 125 years which is 2-3 times the working lifetime of any possible living person.
The lease is a business agreement and the terms for ground rent can be declared unfair if the leaseholder cannot live out 3 times the working life time in the lease . It becomes a VOID contract agreement.
The Government has powers to impose correction on VOID agreements . So here is what the Minister should do :
1. Declare all freeholder companies which refuse to pay the cost of replacing combustible insulation on tower blocks as becoming “insolvent ” and put them into bankruptcy . This includes the entire Group of controlling companies , including ones based in tax havens and all their Directors . Only exclude freeholders and directors living in the building with combustible insulation.
2. Apply 40% tax rate on annual ground rents to pay for replacing defective insulation . No deduction allowed for bank loan interest from ground rent income .
3. Terminate the right to demand ground rent after 2o years from start of the lease. The freeholder companies can be allowed to recover any loss from the Developers.
4. Impose 20% VAT on first sale of new build leasehold property requiring ground rent payment exceeding peppercorn . Its not a sale of new property if ground rent payment is demanded
5. No VAT refund to developers selling leasehold title on new build property requiring ground rent .payment.
6. Remove the 2 years waiting time for leaseholders to qualify for buying the freehold title .
This rule is Housing Ministry’s senior civil servants abusing the public to prevent the developers offering share of the freehold company at first sale.
7. Remove the right to start of forfeiture proceedings at £350 ground rent in arrears .
This rule is Housing Ministry’s senior civil servants abusing the leaseholders because £350 arrears in ground rent can be recovered at the Small Claims Court run by the County Court.
Vauxhall have just recalled thousands of Zafiras due to a danger of fire.
Now if I had rented a Zafira from Enterprise or Avis, would I as the renter of the vehicle be expected to pay for the rectification work?
Would Enterprise or Avis pick up the tab?
Or would they say to Vauxhall ” You built it, you put it right?”
In similar vein would passengers be expected to pick up the bill for the Boeing 737 Max debacle?
Would the airlines be expected to pay?
Or would it be Boeing?
The freeholders are saying its the leaseholders who should pay because they agreed to the terms of the lease and leaseholders made covenants inside the Lease to pay.
The Housing Minister is listening to the freeholders because the leaseholders are committed to pay in the Lease . And the Housing Minister listens to the freeholders because they are legal owners of the property.
But the tower blocks with combustible cladding are death traps for the leaseholders and the Housing Minister should put the freeholder companies of those tower blocks into bankruptcy for leasing dangerous tower blocks and not having the funds to pay for replacing the cladding..
The Housing Minister should put his business hat on and take action to put these freeholders into bankruptcy.
Further to ollies Comments
Economics of Leasehold (East & West England).
1. Sale of New Build Property.
Registration of property at Land Registry may include Freehold, Leasehold, or Commonhold Titles.
In selling New Builds, the choice of property title is decided by the developer, purchasers will have no say, what title is to be offered.
Developers used to offer Freehold for housing and Leasehold for flats, mortgage lenders require flats to be covered by a Maintenance Agreement, as in a lease.
2. Terms for Sale for New Leasehold Flats.
It used to be new flats were sold with a 99 years lease. Policy dictated by the UK Council of Mortgage Lenders, these lenders were not to provide mortgages for leases of 70 years or less.
Leaseholders must seek a statutory 90-year extension of the Lease, which enables the original lease to be extended from 70 to 160 years, at a Peppercorn – Ground Rent (GR).
During the past 30 years, National Building Developers sold flats with Leases for 125 years or longer, with annual GR starting from approximately 0.1% to 0.2% of the sale price of a flat, with GR doubling every 25 years.
Today in the Greater London Area, a developer may offer (2 bed 2 baths) Leasehold flats selling at £500,000 with annual GR starting from £500 (125 years) and doubling every 25 years (£8,000) for final 25 years, or every 10 years (£256,000) for final 25 years, as demanded by greedy developers.
Developers revenue for a development of flats comes from the sale of a lease on each flat, and a separate sale of The Freehold Title to a company who is investing for the GR Income. Many developers such as M&S set up companies within the same organisation that purchase the Freehold preventing the S5 – Notice of First Refusal. The figure quoted when purchasing, can increase five or sixfold after this sale.
The Lease includes a requirement to pay an Annual GR possibly set to the highest level to provide GR Income to the Freeholder, but without lowering the sale price of a flat. Leasehold Advisory Service (LEASE) considers GR set at 0.1% of the sale price is fair and RICS considers ground rent at 0.2% is fair, but what is the fair level for setting yearly.
3. Example of Breakdown of Developer’s Leasehold Revenue.
A Developer’s total sales revenue comes from:-
a) Sale of individual leases @ 100% = £500,000
b) Sale of Freehold Title – GR Investor @ 2% = £10,000
c) Refund of VAT paid during the Construction Stage.
Flat purchaser pays a price upfront and in return gets an inferior property title – 125-year lease agreement which requires the purchaser to pay annual GR and annual Service Charges for 125 years, economically good for Freeholder, Bad for Leaseholder.
Continued from the last Posting:-
If Developers choose they could sell Leases, “Commonhold” with Nil GR and could transfer the Freehold title at Nil cost to a Residential Management Company (RMC). If they do in the future they will lose out on all the perks which Leasehold has offered them over the past years.
Fair Contract Terms
Is the Sale of a Flat under a Leasehold title (99-year lease) offered on Unfair Contract Terms, when Developer receives 100% revenue upfront (equivalent to selling a freehold title) allowing the Developer to take full advantage of Flat Buyer’s lack of understanding, how Leasehold works?
Are Developers acting in a Fraudulent Manner, because this is how it was set up to be done?
Could the continued Sale of Flats or Houses as Leasehold, be considered as fraudulent by allowing Unfair Contract Terms (CMA) to investigate?
Most first time buyers are unaware of many Economic Scams that disadvantage them ranging from:-
(a) Forfeit lease” if ground rent arrears exceed £350 in 3 years
(b) Paying, lease extension – below 80 years includes marriage value
(c) 2 years waiting period to qualify for a statutory lease extension
(d) Landlord subletting consent, Exit fees, Allowance Fees etc.
(e) The declining value of the lease premium due to decreasing term
(f) Loss of family inheritance for savings, as value declines.
Typical prices paid for New 1 or 2 Bed Flats with Annual Starting GR Per Anum and % of Cost.
1993 Bellway-Chalfont Court- Harrow – £66,500 – £80 @ 0.12%
1994 Bellway-Knowles Court- Harrow – £65,000 – £100 @ 0.15%
1998 St George North- Goddard Place – £145,000 – £175 @ 0.125%
2002 Crest Nicholson- Perspective Bld – £215,000 – £200 @ 0.09 %
2017 Redrow Plc- Lyon Square- Harrow – £350,000 – £350 @ 0.10 %
2019 Barratt College Road- Harrow – £ 390,000 – £350 @ 0.11 %
*Taylor Woodrow Sisley, Cornwall – £117,000 – £250 @ 0.21 %
*ONEROUS GROUND RENT
The 0.21% is well over the 0.1% of the sale price which is the National Definition of Onerous Ground rent as seen I believe in an article on LKP 09/03/19.
The article feature a case study of the Sisley family in Cornwall, whose £117,000 Taylor Wimpey flat has Annual GR of £250 so well over the 0.1% of sales price, which is the Nationwide definition of Onerous GR and doubles every ten years up to the first 50 years so then the GR will be £8,000?
Continued from Above:-
Are Governments in Silent Collusion with Developers?
A Developer can sell New Flats to Leaseholders depending on the location for and for the highest price. The sales turnover will allow the Developer to recover all of its Capital Costs for financing the development and may provide a decent profit of between 15% to 20%.
The separate sale of the Freehold Title to a Company of Ground Rent Investor, from the same Organisation, may provide the developer with an extra 2-3 % extra revenue. This is based on initial GR beginning at 0.1% of the sale price for the property. It assumes Ground Rent Investment Companys pay for the Freehold Title @ 18 to 25 times Annual GR priced on 4 to 5.5 % yield?
Is it Fair for the developer to separately sell off the Freehold Title to a Commercial Ground Rent Company for only 2-3% cost of the whole development on top of them receiving the full price paid by the Leaseholder?
Potential Losses
Is the flat purchaser entering into a Contractural Agreement which may be a financial “total loss” of Investment?
The first buyer of a flat pays the top price, where the idea is when all flats are sold, fully covers the Capital Cost layout. So is there any justification for selling a lease which requires payment of ground rent for 125 years to sustain an exploiting Freehold Company, then after the lease expires the flat is to be handed back to the final Freehold Owner.
(i) By introducing Unfair Contract Terms within the Lease and then selling the Freehold Title, is the developer then selling on the Unfair Contract Terms to the GR Company?
(ii) Is there any justification for the Developer to demand GR in the leases because the Developer knows the entire building including the Freehold Title has to be disposed of in order to qualify under HMRC rules for claiming back VAT paid during the Construction Stage. The developer does not receive the GR unless they retain the Freehold, but then would lose the VAT refunds?
(iii) HMRC should be allowing Nil % VAT for First Time Purchases with no GR. It is believed, HMRC have got their basic understanding wrong over Section 4.2 of VAT Notice 708 which fails to include Commonhold Titles. Can this be considered Collusion by a Government Department as it promotes the sale of Leasehold under Unfair Contract terms?
(iv) Are the majority of leases sold as Leasehold Flats & Houses defective from the very start date, as after 29 years on a 99 year Lease, falls below 70 years term, and no longer allow the Leaseholder to apply for a mortgage, another Collusion by Government?
Continued Again
(v) If we comparing Commercial and Residential Leases it can be seen the tenant enters into a Commercial Lease without paying the Capital Cost upfront. The Residential Lease is where the first purchaser and then subsequent purchases possibly (5 in a 99 year Lease) pay a Capital Cost of the value of the flat.
Example Same 2 Bed Flat
1987 Cost Paid for 2 Bed Flat – £38,000
1997 Cost Paid for 2 Bed Flat – £60,000
2007 Cost Paid for 2 Bed Flat – £90,000
So after 33 years, the Freehold Value, paid by just three purchasers was £188,000 to-date.
A flat which is now 33 years old and the GR doubles from £48 to £96 until 2052 then doubles again until 2085 when it will be returned to the Freehold Owner.
With 66 years left on the Lease, an extension to include a further 90 years at circa £13,000 for the extension, would allow a total of 155 years and possibly selling another 8 times.
In the meantime, the development has to pay into a Sinking Fund (Contingency Fund) some £6,000 a year, and Management Fees of £13,300 totalling £19,300 a year over the next 33 years will be £636,000, each resident paying over £22,000.
Then there are the Annual Service Charges of circa £21,700 over the next 33 years another £716,100, another £25,500 for each resident.
The total number of leasehold properties in E & W is arguably over 6 million not the 4.2 million the Government say.
Pensioners and over 60s invest savings into Leasehold properties some £800,000,000. On the Lease expiring the value to each flat becomes zero and the next generation may have nothing to show.
Other countries in Europe use Commonhold Title and property owners do not suffer this loss. Only England & Wales in Europe continue to use Leasehold Titles, even Scotland stopped in 2003.
Freeholders will always say the Leaseholders have to pay because Leases are written to allow all costs to be paid by them. The terms of a Lease have for hundreds of years been such that the Freeholders are King and Leaseholders Peasants.
The latest Housing Minister (HM) has attempted to square the circle that is Leasehold Exploitation. Problem is as always, Freeholders are in the driving seat and no need for insurance either as the Leaseholders pick up all costs, as designed by the Freeholders Legal Teams.
Freeholders own a building development and pretend to listen to Leaseholders, but in the end, they know what the Leases say, so the Law is on their side.
Tower blocks with combustible cladding are potential death traps for Leaseholders, but the Freeholders, are reluctant to accept they are at fault and instead say the Lease states they are to pay for everything.
Developers, Designers, Building Control and Planners all have a part to play in the Scandals, along with Construction Firms using failing Design Criteria. The Health & Safety Executive has not been seen or heard of much, yet they are the main investigators?
I agree with the Freeholding Companies who refuse to pay for and replace the Cladding should be Financially Sanctioned and the threat of the Companies Directors should be in line with Bankruptcy.
The Competition & Markets Authority (CMA) along with the Housing Ministers:-
The Competition & Markets Authority (CMA) and Housing Ministers (HM) could have helped Leaseholders escape from Leasehold Exploitation. The CMA is another Organisation set up by Government and replaces the OFT which was pretty useless in Leasehold Exploitation.
The CMA could:-
(i) Ensure all GR is at Peppercorn Rate (£10 or less)
(ii) Declare GR over 0.1% an Unfair Contract term
Housing Ministers could:-
(i) Provide backing and give 100% backing to Justin Madders MP for his BILL for ending GR payments and for collective purchase of the freehold title by the leaseholder paying 10 x annual ground rent.
(ii) Recognise that leaseholders have paid 100% upfront for their block of flats and should introduce legislation giving everyone a right to become a Director of a company owning their freehold.
(iii) Every leaseholder must be given right to pay ground rent reduced to 3% of the original Cost of the Flat as the original flats purchasers collectively paid 97% of all costs for financing the development including any profit.
09/03/2019 a very good Daily Mail story revealing that last November Communities Secretary, James Brokenshire was demanding inquiries into 100,000 House Buyers were trapped in toxic leases. So, no reason not to get on with banning leasehold houses – the easy bit – and reducing new ground rents to zero.
Of course, Ground Rent Grazers and other Private Equity Speculators including the Truly Greedy PLC top ten House Builders for obvious reasons will not agree.
Developers can then stump up to provide the Freeholds Housing from the Leases as promised to their customers who asked, before promptly being flogged off.
Under Freedom of Information requests, The Mail reveals that Mr Brokenshire was warning the CMA that up to 100,000 people were ‘trapped’ in homes they could not sell. Mr Brokenshire said: “Leaseholders cannot sell and cannot move. They struggle to purchase their Freehold or extend their Lease, as the cost of future ground rents must be met. He added: “This shines a light on the culture of consumer exploitation rife in the housing industry. “In the past, the CMA used its influence to tackle this type of exploitation, and it is my hope it will do so again.”
Mr Brokenshire also wrote to the Solicitors Regulation Authority to complain about lawyers – many recommended by developers – who failed to warn buyers about contracts with “extortionate” terms. He said: “I am troubled by some of the evidence I have received.”
The business secretary, Greg Clark, said: “Andrew Tyrie is a proven consumer champion and competition advocate, with a strong record of independence as select committee chair, ideally suited to leading the CMA at this critical time.” ( Guardian 11 April 2018. )
Last night a CMA spokesman said: The issues around ground rent clauses are well known and a market study would shed little further light. ( Daily Mail 9 Mar 2019 ) The CMA spokesman should not be blocking any requests from Government, The CMA Spokesman must step aside and let Andrew Tyrie consumer champion make the decision.
Problem is leaseholders don’t have consumer protection rights.
Consumers are protected if they purchase a damaged can of baked beans but a leaseholder can live in a potential cladding death trap but have no protection. In fact the leaseholder is expected to pay up irrespective of who caused the defect in the first place.
Brokenshire and all the previous Housing Ministers don’t care because they know the leaseholder can always be blamed and asked to pay up. What’s not to like if you are a freeholder or Housing Minister.