Response 506579050

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Part 1 – Prescribed information

1a. Do you think that landlords should have to confirm whether they comply with each of the requirements specified above?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
Please explain your answer.
This should be added to the application process, so that when a landlord completes the application progress their completed application acts as legal confirmation that they have complied with legislation.

1b. If not, which requirement(s) do you think landlords should not have to confirm that they comply with and why?

Please explain your answer below.
N/A

1c. Do you think that landlords should be required to provide evidence of compliance with any of the requirements specified?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
Please explain your answer below.
but only if a LA asks for this.

2. What other questions, if any, do you think should be included in an application for landlord registration?

Please explain your answer below.
N/A

3. Do you think that landlords should be asked to provide the domestic EPC rating for property?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
Please explain your answer below.
but only if tenant or LA asks for a copy.

4. Do you think that the applicants should only be required to provide a home address and a correspondence address?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
If not, why is this?
It will get too messy and confusing it they have to provide more than this. LAs are having enough trouble with Gazetteer and addresses as it is without causing more.

5. Do you think that applicants should be required to provide an email address, home and mobile phone number (if they have one)?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
If not, why is this?
We use landlords email address more than any other, but if they don't have one then we rely on a telephone number and if this fails their current home address.

The system currently only allows for a mobile number, but a home phone number and any other contact numbers would be very useful.

Part 2 – Landlord Registration Application Fees

6. Do you think it is reasonable to increase registration fees in line with inflation, to reflect the increased cost to local authorities?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
Please explain your answer below.
However, the price needs to be reflective of each landlord ability to pay. A landlord with a single property should pay less than a landlord with several.

If the pricing structure goes up too high for a single property landlord it will not be worth that individuals money, time and effort in renting the property out and in turn the Government will need to find housing for these individuals at a substantial cost to the already struggling economy.

7. Do you think it is reasonable for local authorities to charge a lower additional fee, in cases where the maximum set fee exceeds the costs of the work undertaken to prompt a landlord to make an application?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Unsure
Please explain your answer below.
LAs simply need to given more powers to be able to deal with landlords who fail to comply with legislation rather than having to rely on PRHP, etc. and in these cases a separate fine should be imposed, which is not tied to the registration fee or late fee.

8. Do you think that the 10% discount applied to on-line applications should be changed? If so, what should be changed?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
If so, what should be changed?
Landlords who are compliant and take ownership of their registration in a responsible manner to ensure they renew timeously should perhaps receive a larger incentive/discount.

9. What are your views on including an amount in the application fee to cover the operating costs of the on-line registration service?

Please explain your answer below.
I thought that some of the registration fee was for the on-line registration service; otherwise what of the landlords who renew on-line and never need LA assistance in doing this?

Perhaps the application should ask (prior to payment) "have you had to contact your LA for assistance in completing this application Yes/No?" if they tick the yes option the system charges them a larger fee and if they tick no a lesser fee.
Or perhaps we should look at fining those landlords who knowingly fail to comply with legislation who have properties already registered, but then fail to add further rented properties to their portfolios when they buy them and rent them out. It's these landlords that cost the LA time and money as we have to carry out investigations, write to them, phone, email, etc.

We also need to be aware that times are getting harder for everyone and with Brexit round the corner times will only get harder. To keep expecting landlords (especially the good landlords) to keep paying higher and higher prices is not the answer. If you do this you will not only alienate landlords, but find that as time goes on landlords will become fewer and fewer as they will simply sell off their properties rather than rent them out and if this happens who is going to house these homeless tenants, especially when LAs do not have the required resources.

In 2016 we emailed all HMO landlords asking them for their opinion on fees and the structure. We asked whether they thought it farer that those landlords with larger HMOs and therefore more occupants should need to pay more than those with less occupants. The response was not only outstanding, but by a clear margin voted that landlords with more occupants should pay more for their license. The new fees were implemented with no issues and to this day we still have the respect and confidence of our HMO landlords. Based on this why not let the landlords have their say on fees and fines.

10. Do you think that a local authority should receive an application fee when they carry out a fit and proper person test on a joint owner?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Unsure
Comments:
The only time we carry out a fit and proper test is if a landlord/joint owner has convictions or their has been issues with PRHP, etc. The tests are far and few between and I do not think this warrants a fee.

If you're looking to start charging for every possible contingency, then the pricing structure is going to have to be different for every landlord/joint owner and will cause no end of confusion for everyone. It will also mean that going forward landlords/joint owners will not be able to register themselves on-line as they will not be in a position to know whether a fit and proper test has been carried out nor any other expenses incurred by the LA, which means they will need to contact us and we will need to register for them, which in turn is defeating the object of expecting landlords to register themselves on-line thus obtaining the 10% discount.

11. Do you think that each local authority should receive the full application fee when a person applies to more than one local authority, and the fit and proper person assessment is required?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
Comments:
A full registration fee for each LA is acceptable, but again how will the system or the landlord know whether a fit test has been carried out and therefore amend the fee appropriately on-line. This would again need to be carried out by the LA hence then also incurring admin fees, etc.. This does not work!

12. Do you think that landlords should receive a 100% discount on the application fee for a letting agent who has applied to be registered with the Scottish Government?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Unsure
Comments:
If you're looking to increase fees and finding new ways of obtaining even more money's from landlords then you really don't want to be giving 100% discounts to anyone.

13. What are your views on charging a fee for specific changes in circumstance to an existing registration?

Comments:
It's a good idea in theory, but as mentioned above the system is never going to be clever enough to work this out for itself, nor could the landlord ever be expected to know what charges they'd incurred e.g. fit and proper test and therefore the only way of ensuring that all fees had been accounted for is for the LA to complete the landlords/joint owners application for them, which then fails the objective of a landlord/join owner being able to and expected to register themselves on-line .

Also, even if the LA did complete the landlords registration it is not an absolute that this individual would be aware of all the charges incurred, especially if prior to registration the landlord had dealt with another colleague(s).

14. What are your views on offering incentives to landlords and agents to apply for registration and/or improve their practice?

Comments:
This is definitely the way forward, especially if the fees go up quite considerably, then we have the "Ace card" to play. The landlord would need to be made aware of the fees and how they could themselves reduced these.

Part 3 – Impact Assessments

15. Are there any proposals in this consultation which impact or have implications on ‘equality groups’?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Unsure

16. Do any of the proposals in this consultation have any financial, regulatory or resource implications for you and/or your business (if applicable)?

Comments:
N/A

About you

Are you responding as an individual or an organisation?

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(Required)
Radio button: Ticked Individual
Radio button: Unticked Organisation

What is your organisation?

Organisation
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