Policy

Housing Rights notes that several aspects of our response to the previous ‘Review of Rate Liability in the Domestic Rental Sector’ have not been incorporated in the draft proposals. The specific issues raised, which largely relate to rates liability in the rental sector as well as rates recovery, are significant concerns for those who contact our advice service for assistance. It is with disappointment, therefore, that we note that none of these points have been progressed to the proposals contained in the current paper.

The substance of this response therefore contains specific comments on particular proposals contained in the ‘Rates Rethink’ paper, as well as reiterating points made in relation to the previous review of rate liability in the domestic rental sector, which the current proposals are silent on.

Housing Rights broadly welcomes the Financial Conduct Authority’s response to this issue, which aims to provide a framework which lenders can use to ensure ‘fair remediation for customers.’ We welcome the FCA’s characterisation of lenders’ practices as ‘automatic capitalisation’, leading to customers making overpayments, and the recognition that this may have led to unfair customer outcomes. Housing Rights also welcomes the FCA’s statement that they ‘expect firms to put this right, and ensure the practice ceases.’

Housing Rights is pleased to offer several further comments on particular aspects of the proposed guidance framework, with the aim of ensuring that the framework fully provides fair remediation for affected customers.

Housing Rights offers comments on the draft Programme for Government (PfG) (see particularly paragraphs 3-4) and the Delivery Plan for Indicators 8 and 48 (see particularly paragraphs 5-8) in this consultation response.