Consultation on a draft statutory code of practice and training requirements for letting agents in Scotland: analysis of consultation responses

4. Part 2 - Training Requirement

4.1 This section of the report analyses responses to Part 2 of the consultation relating to the training requirement which covers:

• Proposal 1 - Matters on which training must have been undertaken
• Proposal 2 - Persons who must have undertaken training
• Proposal 3 - Qualifications which must be held by the applicant or other persons
• Proposal 4 - Period within which training must have taken place

Proposal 1: Matters on which training must have been undertaken

Q10a: Does Proposal 1 appropriately reflect the matters on which staff should undertake training on?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	19	73%	5	19%	2	8%	26	1
Member of public	8	44%	5	28%	5	28%	18	2
Professional/representative	13	93%	1	7%	-	-	14	-
Local authority	9	82%	2	18%	-	-	11	-
Other	8	89%	1	11%	-	-	9	3
Tenant/community	6	74%	1	13%	1	13%	8	-
Total	63	73%	15	18%	8	9%	86	6

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.2 Of the 92 respondents, 86 chose to answer the question about whether Proposal 1 adequately reflected the matters where staff training was required. Of those, seventy-three percent were in agreement with this, eighteen percent disagreed, and a small number (9%) said that they 'didn't know'.

4.3 A significant number of respondents (16) who were in agreement said that the outlined training requirements seemed logical and appropriate, and would help ensure consistency in practice across Scotland, and also compliance with the Code. Some said that many letting agents regulated by other industry approved bodies were already doing this.

4.4 One local authority noted that not only was it good practice for letting agents to be appropriately trained, having highly trained staff would also be good for business. Related to this, another local authority suggested that this training should be extended to all staff.

4.5 Capability Scotland welcomed the specific reference to training for letting agents on equality issues, and suggested that it would be useful to develop a range of case studies as part of this, to help raise awareness of key issues for disabled people, for example, in relation to responsibilities regarding adaptations, and waiving the 'no pets' policy for people who use 'assistance dogs'.

4.6 Others suggested that training for letting agents should also cover repair and maintenance services to ensure that landlords were meeting their legal obligations. In addition, the CIH recommended that the training requirements outlined in Proposal 1 be reviewed, once the new regulations had had time to settle.

4.7 Although not in agreement with Proposal 1, one letting agent organisation suggested that training should cover a wider range of matters, and there should be flexibility in how training was delivered, for example, online, e-workshops, in-house training. It was felt that this would be particularly beneficial for organisations based in the Highlands, and other remote areas, where access to training was sometimes limited.

4.8 Whereas, one member of the public commented that the training proposals did not go far enough, and that higher expectations needed to be built into the training requirement, linked to some kind of accreditation scheme for letting agents.

Q10b: Please specify any other training matters we should include in regulations

4.9 Respondents were also invited to specify any other training matters that should be included in the regulations. Their individual suggestions for additional training are summarised below:

• professional ethics and service excellence;
• awareness of equalities legislation, and how to prevent discrimination;
• awareness of consumer protection legislation, and how to protect the rights of landlords and tenants;
• awareness of tenancy law, and the practical application of this in relation to the extension, renewal or termination of tenancies;
• awareness of legislation relating to HMO, and how to manage HMO properties;
• dealing with properties in common ownership, and the practical application of this in relation to dealing with common repairs; and
• practical training on a range issues, including: financial compliance; gas and electrical safety; referencing procedures, including dealing with potential 'Right to Rent' applications, and dealing with prospective tenants.

Proposal 2: Persons who must have undertaken training

Q11a: Proposal 2 suggests placing a training requirement on:

• The most senior person in the applicant's organisation, unless they have no input to the letting agency's day-to-day running; and
• All persons directly concerned with managing and supervising the letting agency's work.

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	15	58%	7	27%	4	15%	26	1
Member of public	11	61%	3	17%	4	22%	18	2
Professional/representative	8	57%	4	29%	2	14%	14	-
Local authority	7	64%	3	27%	1	9%	11	-
Other	6	67%	2	22%	1	11%	9	3
Tenant/community	6	75%	-	-	2	25%	8	-
Total	53	62%	19	22%	14	16%	86	6

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.10 Of the 92 respondents, 86 chose to answer the question about who should be required to undertake training. Of those, sixty-two percent agreed with Proposal 2, twenty-two percent disagreed, and sixteen percent said that they 'didn't know'.

4.11 A significant number of respondents (16) who were in agreement said that it was important for anyone working in letting and property management to have a minimum level of training. One of these respondents added that this would help to improve the image of the sector, and increase the quality of the service provided.

4.12 A few (2) stated that it was important that the most senior person in the agency should be the one that was trained, and therefore should not be exempt from training if they are not involved in the day-to-day running of the business.

4.13 Although, others (2) proposed that some staff might be exempt from the training requirements, for example, some administration staff, temporary staff or part time staff or sub-contractors. Another local authority commented that there should always be someone in the office that was 'accredited', to provide cover for holiday periods, staff illness etc.

4.14 In addition, a few respondents (2) proposed that staff, who already held relevant qualifications, should be exempt from the training requirement, for example, staff who were members of RICS, or the CIH.

Issues Raised

4.15 Although the majority of respondents from the letting agent category were in agreement with the proposal, a higher number of these respondents (7) disagreed, compared to other respondent categories. Respondents provided a number of reasons to back up their views.

4.16 Some respondents (5) that disagreed with the proposal said that it was important that the training requirement applied to staff at all levels, and should therefore be extended to all front-line staff, as they were more likely to be dealing with clients on a day-to-day basis. This view was also shared by a few respondents (2) who agreed with the proposal.

4.17 RICS referred to the training and CPD requirements that their members were expected to meet, reiterating the point that their members should be 'passported' through the registration process. A couple of respondents also suggested that the training requirement should also be placed on the landlords.

4.18 One respondent that said that they 'didn't know', made the point that organisations were best placed to decide the most appropriate person/people to undertake the required training to comply with the Code. It was suggested that the Code be amended to state that at least one person in any organisation should be trained to the agreed standard.

Q11b: Who else, if anyone, should have to comply with the training requirement?

4.19 Respondents were also invited to provide comments on who else should have to comply with the training requirement. Their suggestions are summarised below, in order of prevalence:

• Tailored training should be provided for all front-line staff, who deal directly with the public, tenants and landlords, including contractors and sub-contractors, and maintenance staff (11).
• The most senior person in the organisation should be trained, as the 'buck stops with them' if there are any complaints, or breaches of the Code (5).
• Different levels of training for staff depending on their positions, for example, letting assistants, letting officers and letting managers (1).
• Consideration should be given to different methods of delivering training, for example, use of online training modules (1).
• Training should be mandatory for all non-clerical staff, this will help to raise standards in the sector (1).
• Dates should be set to evaluate the training requirement, to ensure that it is up to date (1).
• The training requirements should apply to 'on-line only' agencies and portals that facilitate lettings (1).

Q11c: Should we include another requirement that there must be at least one person trained per office?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	16	62%	6	23%	4	15%	26	1
Member of public	10	56%	4	22%	4	22%	18	2
Professional/representative	9	64%	4	29%	1	7%	14	-
Local authority	9	82%	2	18%	-	-	11	-
Other	5	56%	3	33%	1	11%	9	3
Tenant/community	6	75%	2	25%	-	-	8	-
Total	55	64%	21	24%	10	12%	86	6

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.20 Of the 92 respondents, 86 chose to answer the question about whether there should be another requirement that there must be at least one trained person per office. Of those, sixty-four percent agreed with this proposal, twenty-four percent disagreed, and twelve percent said that they 'didn't know'.

4.21 A significant number of respondents (19) who were in agreement with the proposal said that this should be a minimum standard, otherwise the training requirement would be undermined.

4.22 A few (3) of these respondents noted that having at least one trained member of staff in each office would ensure that decisions, policies and procedures were dealt with consistently, and that the requirements of the Code were met. Whereas another letting agent organisation said that there should be at least two people who were trained, to cover holidays and sick leave.

4.23 In contrast, some other respondents (6) stated that all staff should undergo training, but timescales for undertaking training would be critical to ensure compliance with the Code. ARLA also suggested that consideration be given to the size of individual firms, and implementation should work to timescales that were workable for the number of offices a firm had.

4.24 The NLA and UK Association of Letting Agents noted that in the first instance, focusing on ensuring that an individual with oversight, regardless of physical location, was a logical approach. At a future date, it was recommended that a review of compliance with the standards of the Code should be undertaken by Scottish Government to determine whether further requirements were necessary.

4.25 Finally, a few respondents (2) proposed that qualified staff, for example, chartered surveyors should be exempt from the training requirement. In addition, RICS offered its support to help develop the proposals on training in more detail.

4.26 Although the majority of respondents from the letting agent category were in agreement with the proposal, a higher number of these respondents (6) disagreed, compared to other respondent categories. A letting agent organisation commented that evidence of competence, whether gained through experience, or in-house training, should be sufficient.

4.27 One respondent from the 'other' category that said that they 'didn't know', commented that although 'one person per office' seemed reasonable, this would depend on the size of the office, and the scale of the portfolio within the office, for example, one office could manage thousands of properties.

Proposal 3: Qualifications which must be held by the applicant or other persons

Q12a: Proposal 3 suggests the phased introduction of a mandatory qualification. Do you think we should introduce a mandatory qualification?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	16	61%	9	35%	1	4%	26	1
Member of public	12	67%	2	11%	4	22%	18	2
Professional/representative	9	64%	3	21%	2	14%	14	-
Local authority	10	91%	1	9%	-	-	11	-
Other	7	78%	1	11%	1	11%	9	3
Tenant/community	7	88%	-	-	1	12%	8	-
Total	61	71%	16	19%	9	10%	86	6

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.28 Of the 92 respondents, 86 chose to answer the question about the introduction of a mandatory qualification. Of those, seveny-one percent agreed with the proposal, nineteen percent disagreed and ten percent said that they 'didn't know'. Although the majority of respondents from the letting agent category were in agreement with the proposal, a higher number of these respondents (9) disagreed compared to other respondent categories.

4.29 A significant number of respondents (29), who were in agreement with the proposal, said that it was reasonable, and it made sense to have a mandatory minimum standard. Many of these felt that this would ensure that staff were professionally trained to an agreed standard, and this would lead to greater consistency across the sector. Some of these respondents also believed that it would help to raise quality and standards in the sector as a whole.

4.30 One letting agent organisation commented that by developing a suite of qualifications for the private rented sector, this would open up career pathways within this growing sector. Related to this, one member of the public suggested that there should only be one accredited training provider. In addition, TPOS proposed that following consultation, the syllabus for the proposed qualification should be set by Scottish Government.

Issues raised

4.31 There was a degree of common ground across some (8) respondents, whether they agreed or disagreed with the proposal to introduce a mandatory qualification, that there should be varied and flexible ways of meeting the requirements of the proposed mandatory qualification, especially for those who have significant experience in the industry, or those who already have relevant professional qualifications. For example, the Ombudsman Services highlighted that it would be important to recognise the qualifications, training and CPD that many people working in the sector already had or were required to undertake, as part of their membership of professional bodies or trade associations. In many cases, it was likely that this would be at a higher level than the proposed mandatory qualification.

4.32 Some of these respondents also suggested that evidence of competence, whether gained through experience, in-house training, relevant professional qualification or development, should also be taken into account, and where relevant, exemptions should be granted. One respondent also sought clarification on how the qualification would be obtained, for example, through online resources, or time out of the office at specific locations to sit an exam.

4.33 In addition, one local authority expressed concern that although the proposal was a good idea, it might have the effect of driving 'unscrupulous' landlords 'underground'. Others who disagreed with the proposal expressed concern at the likely costs attached to this. Meanwhile, one letting agent organisation qualified their response by stating that the requirement should be that 'at least one member of staff' should hold the mandatory qualification.

4.34 Finally, the Law Society of Scotland suggested that it should be the responsibility of the senior person to ensure that all staff are working to the required standard. In addition, it was felt that formalised qualifications might deter potential employees.

Q12b: If we decide to introduce a mandatory qualification, we propose this would come into force three years from the date of the Letting Agent Register comes into force. Do you think this is an appropriate timeframe for a mandatory qualification's introduction?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	12	46%	11	42%	3	12%	26	1
Member of public	7	39%	6	33%	5	28%	18	2
Professional/representative	8	57%	4	29%	2	14%	14	-
Local authority	9	82%	2	18%	-	-	11	-
Other	7	78%	2	22%	-	-	9	3
Tenant/community	2	25%	4	50%	2	25%	8	-
Total	45	52%	29	34%	12	14%	86	6

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.35 Of the 92 respondents, 86 chose to answer the question about whether the mandatory qualification should come into force three years from the date of the Letting Agent Register coming into force. Of those, fifty-two percent agreed with the proposal, thirty-four percent disagreed, and fourteen percent said that they 'didn't know'. In particular, letting agents and members of the public were fairly evenly split in terms of their views on the proposal.

4.36 A significant number of respondents (16), who were in agreement with the proposal, said that the timeframe was appropriate and reasonable, and would allow adequate time for training providers to put training in place, and for staff to be trained.

4.37 In addition, one letting agent organisation noted that it would be important that training was available nationally, locally and online.

Issues raised

4.38 There was consensus across a significant number (19) of respondents, who said they agreed or disagreed with the proposal, that the three-year timescale was too long, and that the qualification could be achieved in a shorter time period, say within two years of the register being set up. Although some (2) commented that this would be dependent on the appropriate training infrastructure being in place across Scotland.

4.39 Others who disagreed with the proposal suggested that existing relevant professional qualifications should be recognised and provide exemption from the training qualification. Whereas, an individual letting agent was of the view that it was not appropriate to introduce a mandatory qualification that did not recognise experience.

4.40 One respondent who said that they didn't know, noted that the qualification would only be achievable if the training requirements and expectations were flexible, affordable and relevant. A few others (2) stated that it would depend on the level of the qualification. One member of the public called for smaller letting agents to be exempt from having to achieve the mandatory qualification.

Q12c: We propose to set the mandatory qualification at Scottish Credit and

Qualifications Framework level 6. Do you think this is the right level?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	15	58%	1	4%	10	38%	26	1
Member of public	10	56%	3	17%	5	28%	18	2
Professional/representative	9	69%	1	8%	3	23%	13	1
Local authority	6	60%	-	-	4	40%	10	1
Other	3	33%	1	11%	5	56%	9	3
Tenant/community	4	50%	2	25%	2	25%	8	-
Total	47	56%	8	9%	29	35%	84	8

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.41 Of the 92 respondents, 84 chose to answer the question about the level the qualification should be set at. Of these, fifty-six percent agreed with the proposal, ten percent disagreed, and one third (34%) said that they 'didn't know'.

4.42 A significant number of respondents (20), who were in agreement with the proposal, said that this was adequate as an entry level qualification. However, a few of these respondents (2) suggested that there should be encouragement to progress to a higher level.

Issues raised

4.43 A significant number (37) of respondents said that they either disagreed with the proposal (8), or 'didn't know' (29). The main issues highlighted by some of these respondents are summarised below.

4.44 A few respondents (3) who disagreed with the proposal suggested that the qualification should be set at a higher level, for example SCQF Level 7 or 9; college level (HNC or HND), or even at university degree level. The CIH also suggested that the regulations should make clear that only accredited or regulated qualifications would satisfy the requirement within the Code. Similarly, one letting agent organisation who agreed with the proposal, noted that the qualification needed to carry some 'weight' to be recognised nationally, otherwise this would defeat the purpose of gaining the qualification.

4.45 One member of the public proposed that there should be greater flexibility in the type of qualification required, to reflect the role of the individual within the organisation. Whereas, one individual letting agent said that experience should be just as relevant as obtaining a formal qualification.

4.46 Some respondents (4) said that they needed more information on the course design and content, to be able to comment on whether level 6 was appropriate. A few others (2) called for 'credits' to be given for previous training or relevant qualifications.

4.47 One local authority stated that, in the first instance, it would be important to identify who would be responsible for setting the curriculum, and which higher or further education disciplines would provide the training.

4.48 The Scottish Property Federation recommended that, based on feedback from their members, existing qualifications and/or industry memberships, should be reviewed to determine their framework level, both as a means of benchmarking, and also as a means of determining what training gaps may exist.

Q12d: Those applying to the Letting Agent Register will need to have met the requirement to be admitted.

What type of evidence should applicants provide to show they have met the requirement?

4.49 Respondents were also invited to comment on the type of evidence that applicants to the Letting Agent Register should provide to show that they have made the requirement. Their suggestions are summarised below:

• Relevant qualification certificates from awarding bodies, for example, higher or further education institutions, Scottish Qualifications Authority (SQA), CIH (25).
• Confirmation of relevant training undertaken through an accredited training provider, for example, individual training logs, proof of attendance, training certificates (hard or electronic copies) (13).
• CPD records (hard or electronic copies) (9).
• Evidence of membership of accredited industry representative or professional bodies, for example, RICS, ARLA, NALS (8).

Q12e: When would you want this evidence to be provided - for example,with every application or on request from the Scottish Government when it appears an applicant or registered letting agent is not complying?

4.50 Respondents were also invited to comment on when this evidence should be provided. Their suggestions are summarised below, in order of prevalence:

• at the point of application (55).
• information should only be provided on request, particularly if a letting agent is suspected of non-compliance, or in the transition period (5).
• information should be resubmitted at re-registration (4).
• information be updated and resubmitted annually (3).
• at the end of the three-year period after registration (3).

Proposal 4: Period within which the training must have taken place

Q13a: Proposal 4 says that if we were to introduce a mandatoryqualification requirement, those with an existing relevant qualification more than three years old would also need to have undertaken at least 20 hours of training in the previous three years.

Do you think 20 hours of training is appropriate to enable a relevant agent to keep their knowledge and skills up to date?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	12	44%	10	37%	5	19%	27	-
Member of public	9	50%	4	22%	5	28%	18	2
Professional/representative	7	50%	2	14%	5	36%	14	-
Local authority	8	80%	-	-	2	20%	10	1
Other	6	67%	-	-	3	33%	9	3
Tenant/community	7	88%	-	-	1	12%	8	-
Total	49	57%	16	19%	21	24%	86	6

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.51 Of the 92 respondents, 86 chose to answer the question about whether 20 hours of training was a reasonable time for people, with existing relevant qualifications to complete additional training. Of those, fifty-seven percent agreed with the proposal, nineteen percent disagreed, and almost one quarter (24%) said that they 'didn't know'.

4.52 Many respondents (10), who were in agreement with the proposal, said that this was reasonable. A few (2) suggested that it would be important that training be provided by an accredited trainer. Others (3) noted that it was essential that letting agents keep up to date with changes in legislation and best practice.

4.53 A few respondents (3) also noted that 20 hours of training was consistent with RICS requirements in relation to CPD. Whereas, ARLA highlighted that their members were required to carry out 12 hours of CPD per annum.

4.54 Respondents from the letting agents category were fairly ambivalent towards the proposal, and a higher number of these respondents (10) disagreed, compared to other respondent categories. Some of these respondents (7) felt that 20 hours of training was too much, and a few of these proposed that 10 hours would be sufficient. One letting agent organisation suggested that evidence of attainment should be more important than evidence of attendance.

4.55 Some respondents (4) who said they 'didn't know', commented that this would depend very much on an individual's knowledge, experience and qualifications, and therefore it would be difficult to quantify a precise number of hours.

Q13b: Do you think three years is a reasonable time for people to complete this additional training?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	13	50%	5	19%	8	31%	26	1
Member of public	8	47%	5	29%	4	24%	17	3
Professional/representative	10	77%	2	15%	1	8%	13	1
Local authority	8	80%	1	10%	1	10%	10	1
Other	7	78%	-	-	2	22%	9	3
Tenant/community	3	38%	3	38%	2	24%	8	-
Total	49	59%	16	19%	18	22%	83	9

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.56 Of the 92 respondents, 83 chose to answer the question about whether three years was a reasonable time for people to complete this additional training. Of those, fifty-nine percent agreed with the proposal, nineteen percent disagreed, and twenty-two percent said that they 'didn't know'. A higher number of letting agents (5) and members of the public (5) disagreed with the proposal campared to the other respondent categories.

4.57 Although in agreement with the proposal, many respondents (11) commented that this seemed generous, and could perhaps be achieved within a shorter time period. A number of respondents stated that if the training infrastructure was in place, the training could be done within two years. A few (2) commented that a time limit should be set once an individual starts the training, to ensure that it is completed as quickly as possible, and not spread out over the three years.

4.58 Although not expressing a view either way, Edinburgh University noted that this would allow enough time for training to be planned and completed, although it was recognised that smaller businesses might struggle with the proposed timeframe.

4.59 In addition, one tenant/ community group said that achieving the timescale would depend very much on the training resources that were available.

Transitional arrangements

Q14a: Before the qualification comes into force we propose that thosesubject to the requirement, who have not obtained the mandatory qualification, would need to have undertaken at least 30 hours of training, covering all the matters prescribed by Ministers, in the previous three years. This would be to ensure that all letting agents admitted to the register had undertaken relevant training on all the areas identified as essential to the effective management of a letting agency.

Does our proposal ensure that those subject to the requirement will have had sufficient training in this initial period before the mandatory qualification is introduced?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	7	29%	5	21%	12	50%	24	3
Member of public	9	48%	5	26%	5	26%	19	1
Professional/representative	8	67%	1	8%	3	25%	12	2
Local authority	7	70%	2	20%	1	10%	10	1
Other	7	78%	-	-	2	22%	9	3
Tenant/community	3	43%	3	43%	1	14%	7	1
Total	41	51%	16	20%	24	29%	81	11

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.60 Of the 92 respondents, 81 chose to answer the question regarding transitional arrangements for training. Of those, fifty-one percent agreed with the proposal, twenty percent disagreed, and twenty-nine percent said that they 'didn't know'.

4.61 Many respondents (10) who were in agreement with the proposal said that this was adequate and satisfactory, and would ensure that all letting agents on the register were trained to an adequate standard. However, some of these respondents said that it would be important that training was delivered by qualified and accredited organisations, to ensure the quality and consistency of training being delivered.

4.62 Although in agreement with the proposal, the NLA and UK Association of Letting Agents expressed concern that 'well-meaning' and professional agents who had chosen not to affiliate to a professional body offering accredited training programmes, would be disadvantaged by the need to demonstrate 'retroactive' compliance with the Code, regardless of the training that they might have undertaken.

4.63 A higher number of respondents from the letting agents (5) and member of the public (5) categories disagreed with the proposal. These respondents presented a range of views, some expressed concern about the 30-hour training requirement, others felt that it was not sufficient, whereas a few said that it would be sufficient as an introductory course, but would need to be backed up with more detailed training. A member of the public highlighted that a likely consequence of this type of requirement, would be to drive small scale letting agents out of the sector.

4.64 One letting agent organisation felt that the proposed transitional arrangements were unnecessary and over-complicated. One housing association that did not express a view either way, commented that the 30-hour training requirement did not take account of the skills and experience of staff in letting agents.

4.65 The CIH sought clarification on whether only formal training, as opposed to other forms of learning, would be considered relevant in meeting the requirement in the transitional period. It was noted that it would also be critical, when training had been undertaken in the previous three years, and how much had changed since the individual had undertaken training or CPD.

4.66 A few respondents queried how this would be monitored or checked, pointing out that staff may not have kept records of the training that they have undertaken over the last three years. Another respondent from the 'other' category expressed concern at the time and cost implications of staff having to undertake 30 hours of training a year.

Q14b: Is it appropriate that those subject to the requirement must have undertaken training on all of the matters (see Proposal 1) set by Ministers?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	15	60%	3	12%	7	28%	25	2
Member of public	13	72%	2	11%	3	17%	18	2
Professional/representative	13	92%	-	-	1	8%	14	-
Local authority	9	90%	-	-	1	10%	10	1
Other	8	89%	-	-	1	11%	9	3
Tenant/community	6	86%	-	-	1	14%	7	1
Total	64	77%	5	6%	14	17%	83	9

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.67 Of the 92 respondents, 83 chose to answer the question on whether it was appropriate that training should cover all matters as set out in Proposal 1. Of those, seventy-seven percent agreed with the proposal, a small number of respondents (6%) disagreed, and seventeen percent said that they 'didn't know'.

4.68 Many respondents (11) who were in agreement with the proposal said that this was essential and it seemed appropriate. A few of these respondents (3) commented that this would ensure consistency, and also help to raise standards and professionalism across the sector.

4.69 One member of the public felt that the proposals were too onerous for agents with small portfolios, whereas another respondent suggested that the proposal should only relate to training on 'legal obligations'.

4.70 One letting agent organisation proposed that firms regulated by an approved professional body would already be compliant with the Code, and would not require additional training. A few (2) commented that as part of this, there should be a refresher course and related CPD training options available.

4.71 One letting agent organisation that did not express a view either way, commented that it would depend on what was meant by 'training', for example, would CPD relating to updates in relevant legislation, and current best practice be sufficient?

Q14c: Do you think 30 hours of training is appropriate?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	12	48%	4	16%	9	36%	25	2
Member of public	9	48%	5	26%	5	26%	19	1
Professional/representative	9	75%	2	17%	1	8%	12	2
Local authority	7	70%	1	10%	2	20%	10	1
Other	5	56%	-	-	4	44%	9	3
Tenant/community	3	43%	3	43%	1	14%	7	1
Total	45	55%	15	18%	22	27%	82	10

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.72 Of the 92 respondents, 82 chose to answer the question about whether 30 hours training was appropriate. Of those, fifty-five percent agreed with this, eighteen percent disagreed, and twenty-seven percent said that they 'didn't know'.

4.73 Many (11) who were in agreement with the proposal said that the proposal was reasonable and appropriate, although some (4) said that this should be achieved in a shorter timescale. It was noted that letting agents that were already registered with an approved industry body should already be compliant with what was proposed in the Code.

4.74 One member of the public questioned whether this transitional training would lead to a formal qualification. A few tenant/ community groups said that for new employees coming into the sector, there should be a higher level of qualification, and that 30 hours training was not enough.

4.75 The Central Association of Agricultural Valuers called for the development of a broader framework embracing existing higher qualifications, this would cater for a wider range of training needs depending on whether staff were qualified or unqualified.

Issues raised

4.76 Some of the respondents (4) who disgreed with the proposal thought that 30 hours of training was too high, and proposed that 20 hours would be more achievable. Another respondent said that this was not enough for staff without a qualification.

4.77 Some respondents (4) who did not express a view either way, commented that this would depend on type of training, the availability of suitably qualified trainers and the quality of the training to be provided. A few (2) expressed concern at the potential impact of the additional training requirements on the sector, particularly on smaller letting agents.

Q14d: Do you think three years is a reasonable timeframe for relevant training to count towards meeting the requirement?

	Yes		No		Don't Know		Total Answered*	Not Answered
Letting agents	15	60%	6	24%	4	16%	25	2
Member of public	9	50%	6	33%	3	17%	18	2
Professional/representative	9	75%	3	25%	-	-	12	2
Local authority	9	90%	-	-	1	10%	10	1
Other	8	89%	-	-	1	11%	9	3
Tenant/community	3	43%	3	43%	1	14%	7	1
Total	53	66%	18	22%	10	12%	81	11

*Percentages of yes/no/don't know are calculated based on the total who answered this question.

4.78 Of the 92 respondents, 81 chose to answer the question on the proposed timescale for training to count towards meeting the requirement. Of those sixty-six percent agreed with the proposal, twenty-two percent disagreed and twelve percent said that they 'didn't know'. Although overall the majority of respondents from the letting agent and member of the public categories were in agreement with the proposal, a higher number of these respondents (letting agents (6) and members of the public (6)) disagreed, compared to ther respondent categories.

4.79 Many respondents (9) who were in agreement with the proposal said that three years was reasonable and adequate.

Issues raised

4.80 There was consensus across a significant number (16) of respondents, who both agreed and disagreed with the proposal, that the timeframe should be shorter, say up to two years. Whereas, a local authority commented that it would not be beneficial to spread the 30 hours of training over the three year period, calling for a clear time limit to be set for completing the training once it had been started. However, a few respondents who disagreed with the proposal, expressed concern at the time and cost implications of the training requirement, particularly for smaller letting agents.

4.81 One member of the pubic that said they 'didn't know', suggested that this would depend on whether it was envisaged that the final approach would be a 'one size fits all' qualification, or one that was modular, and could be supplemented with different modules.

4.82 One local authority noted that it would very much depend on the experience and track record of the letting agent, some had been operating for years, whereas others had only been in existence for a short period of time. More time may be required for the newer letting agents to obtain some sort of acceptable qualification and training prior to registration.