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

Annex One: Additional detailed comments

Respondents from across all respondent groups made specific comments in relation to individual sections within the letting agent Code of practice and training requirement as detailed below:

Section 1.3

• Clarification sought on who would be responsible for assessing whether a person was 'fit and proper', and what background checks would need to be carried out to prove this.

Sections 1.7 to 1.10

• Suggestion that these sections of the Code would be better presented in steps, or in a flow diagram.
• Comment that local authorities should be able to report to the Tribunal.

Section 1.7

• Change the wording in the first sentence to: 'If a landlord or tenant (including former landlords and tenants)…
• Clarification required on whether Ministers would be required to raise the matter first with the letting agent.
• Clarification required on who would staff the First-tier Tribunal, and on the type of qualifications that would be required by staff.

Section 1.8

• Clarification required on how compensation would be measured?

Section 1.9

• It would be useful for Scottish Government to issue a specimen Terms of Business as guidance for lettings agents.

Sections 1.11 to 1.12

• Noted that there was no reference to maintenance of common property and related legislation, for example, Title Conditions (Scotland) Act 2003, Tenements (Scotland) Act 2004, Anti-Social Behaviour (Scotland) Act, 2004, Housing (Scotland) Act 2006, Private Rented Housing (Scotland) and Property Factors (Scotland) Acts, 2011.
• There should be a requirement to comply with the Equality Act 2010, as it relates to private lettings.
• The language used in the introduction was confusing. Rather than referring to 'you' and 'your' in Sections 1.1 to 1.14, this should be replaced with 'letting agent'.

Section 2: Overarching standards of Practice

Standard 2.1

• It is difficult to prove 'honest', therefore the wording should be changed to 'You must be honest, open, transparent and fair in your dealings…'
• This should also include other agents, contractors, members of the public and third party complainants. In the case of communal owned property, 'other owners' should also be included.

Standard 2.2

• Replace the word 'way' with 'format'.
• Provide examples of how letting agents could provide clear information.

Standard 2.6

• This is a difficult area to evidence and enforce.
• Age discrimination is not unlawful in the letting and management of properties, and should therefore be removed.
• Specific reference should be made to the Equality Act 2010.

Standard 2.8

• More guidance required on what type of records would be acceptable, and how long these records need to be kept for.

Standard 2.9

• Reference should be made to specific requirements, for example, relevant Data Protection legislation.

Standard 2.10

• Clarification required on what is a 'reasonable' timescale.

Standard 2.11

• Define or remove 'Important issues'.
• Add "such as a repair to the landlord's property, an enforcement notice, obligations for the common property and its curtilage, including garden area and buildings in common ownership".
• This is overly specific and might fit better in another part of the Code.

Standard 2.12

• Define the terms 'abusive', 'intimidating' and 'threatening'.
• Add 'other owners or their tenants (tenemental or shared property)'.

Additional Standard

• The following section should be added to the standards of practice: "In your role as an agent for a private landlord, you must comply with all aspects of the Equality Act 2010, as it relates to private lettings".

Section 3: Engaging landlords: Specific Comments

Before taking instructions

Section 3.1

Sub-section c)

• Change 'get' to 'provide' to reinforce that this is a requirement.

Sub-section d)

• This could be amended to read '…or you suspect that the landlord has breached housing law in relation to lettings, inform the landlord of this."What happens if the agent informs the landlord, but no action is taken to address issues relating to the standard of the property?
• Add '…in writing…'.

Sub-section e)

• Clarify that letting agents cannot work for landlords who are not registered, and registration is required before a tenancy agreement can be granted.

Sub-section f)

• Add '…and seek their agreement in writing to act…'.
• As worded, there is already a 'conflict of interest', as the agent is acting on behalf of both the landlord and tenant, this needs to be made clear when discussing any 'conflicts of interest'.

Sub-section g)

• There should be an explanation of 'reasonability', absolute proof of ownership and right to let is critical, and should also assist with landlord registration.

Written Agreement

Section 3.3

• More guidance required on this provision - currently this places letting agents in a difficult position as they are being expected to inform the authorities about landlord's behaviour. The Code needs to be very specific so that letting agents do not exceed their duties.
• Query - if it would be sufficient for a letting agent to say that they cannot act on a landlords' behalf if the they are not meeting their legal obligations, rather than expecting them to act as 'whistle blowers'?
• Greater clarity required on which body is responsible for enforcement, so that the letting agent can inform the tenant.
• Letting agents should notify the tenant, if they are informing the authorities about the landlord not meeting their obligations.

Section 3.4

Sub-section b)

• This should also include the date of commencement of the agreement, and also make reference to any 'cooling off' period.

Sub-section f)

• Fee setting must be clear and transparent, with explicit reference to renewals, and any relevant renewal commissions due at a later date.

Sub-section i)

• This should also include other owners, in the case of a tenement building.
• Specific timescales should be included, along with a requirement to fully investigate issues; complaint handling procedures should also include the requirement for referral to the appropriate ADR.

Sub-section j)

• Consideration should be given to a model complaint handling procedure for all letting agents which is linked to the Code.
• For the sake of clarity, the following words should be added at the end of the section "or if you do not process the complaint within reasonable timescales through the staged complaint handling process".

Sub-section k)

• Useful to refer to the independent redress element of the complaints handling process, clarifying that landlords can pursue this route for breaches of service, but can go to the FTT in relation to breaches of the statutory code.

Sub-section n)

• CMP insurance should be mandatory for all letting agents.
• Further education by the Government on CMP at all levels is necessary and will reinforce that it is not just insurance, rather it is a properly audited process.
• Might be merit in developing a Scottish Safe Agent brand to provide greater reassurance to prospective clients.
• It should be a mandatory requirement that CMP control, using designated client accounts is mandatory, and a cost the agent builds into their business model.

Section 3.6

• Clarification required on what is meant by 'in most cases', this is vague and open to interpretation.

Section 3.7

• Clarification required on what is meant by the term 'work', does this relate to repairs or any aspect of work undertaken on the landlord's behalf - having to provide a written agreement every time seems excessive.

Section 3.8

• This is not always possible, and puts letting agents in a difficult position, any subsequent changes to the written agreement should be put in writing and/ or email (particularly for overseas landlords) with responses required within 30 days.

Section 3.9

• How can this be evidenced by the letting agent? Need more detail on types of evidence that would be acceptable to the FTT, and also types of evidence that would be acceptable from landlords and tenants.

Ending the Agreement

Section 3.10

Sub-section a)

• Letting agents should inform the local authority that they are no longer managing the property to allow registration information to be updated.

Sub-section b)

• Examples should be given of the types of changes that might affect tenants.

Section 4: Lettings: Specific Comments

Marketing and advertising

Section 4.1

• Add in a requirement that any charges for advertising and marketing should be clearly stated.

Section 4.3

• Remove '…take all reasonable steps to…', and replace the word 'or' with 'and'; add in the word 'written' before 'communications', and add in after the word 'communications' (including emails).

Section 4.4

• Letting agents should not advertise properties where landlord registration is 'pending'.
• There may be reasons when this is not possible, for example, if the tenant goes on holiday after signing for the property, and the letting agent can't access the property.
• Clarification sought on whether the list of requirements is exhaustive, or simply guidance.

Section 4.5

• Reword this section to read: 'You must not advertise in a way that unlawfully discriminates on the basis of a person's age, disability, sex, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief and sexual orientation'. This is in line with the wording of section 33 of the Equality Act 2010.
• Age discrimination is not unlawful in the letting/management of properties, and should therefore be omitted.
• The section should be expanded to prevent letting agents indirectly discriminating against international tenants, some landlords request that tenants have a UK guarantor - this is impossible for some international tenants, who sometimes have to pay months of rent in advance to secure the tenancy.

Giving correct advice and applicants

Section 4.6

• Clarification sought on whether this is this outwith the signed tenancy agreement.

Section 4.8

• For clarity add the wording 'relating to the property' should be included after the word 'tenants'.
• Add 'if asked a question by a prospective tenant and you are not in possession of the information, you should attempt to obtain this information from your client, the landlord'.

Charging fees

Section 4.9

• Query regarding the relevance of 'making loans' in this section?

Section 4.10

• It was suggested that this section was incorrect, as the legislation only prohibits charges to tenants which are 'as a condition of the grant, renewal or continuance of a protected tenancy'. It was proposed that the section should be amended to reflect the types of charges that are illegal.
• This section should be more explicit in stating that tenants cannot be charged for reference checks by a third party, as a condition of securing a property.

Section 4.11

• This is very vague, amend to read '... to use a third party service specified or associated with the agent'.
• Suggest re-wording to: "you must not financially benefit from charges levied on a tenant by a third party referencing service".

Viewings

Section 4.12

• This might not be practical as staffing and business requirements may require changes at short notice.
• Viewing arrangements should be specified in the letting agent's terms of business.

Section 4.13

• Not clear which 'particular groups' this section refers to. It is unlawful to discriminate against the protected characteristics as defined in the Equality Act 2010. However, for other groups whose characteristics are outwith the 2010 Act, the rights of the landlord to freedom to contract should be protected, for example, they may not wish to rent their property to smokers or people with pets.
• The reference to section 2.7 is incorrect, it should be section 2.6.

Section 4.14

• Replace 'should' with 'must'; also add 'When agents are first issued with keys, they must be carefully logged, and labelled in such a way to link to the property but not identify the address to an unconnected party.'

Section 4.15

• Add in, 'the viewings should take place within reasonable hours.
• Provisions need to be balanced against the interests of the landlord and the agent, where the tenant is being difficult, or cannot reasonably be contacted.

Offers

Sections 4.16 to 4.18

• The terminology used is in this section is misleading. It would be more appropriate and clearer to replace 'offers' with 'tenancy applications'. These sections should also clarify the treatment afforded to notes of interest.

Section 4.16

• Acceptance criteria should be covered in the letting agent's terms and conditions.

Section 4.18

• Add in a requirement that any offers/ applications for a property which are not to be processed further / are unsuccessful, must be destroyed.

References and checks

Section 4.23

• Some landlords may not want the letting agent to check the references as part of their service, in this instance the landlord should confirm in writing if they are happy to proceed without the letting agent carrying out the referencing checks.
• Reword the section to read '...If you are to check references and make other checks, you must take all reasonable steps…'.
• Section should be expanded to take account of the regulations coming into force with the Immigration Bill, in relation to 'right to rent' checks.

Tenancy agreement

Section 4.26

• A slight amendment to clarify the position of the letting agent as distinct from the landlord '…such as the name and address of the landlord or the name and address of the letting agent and the identity of the landlord; type and length of tenancy....'.

Section 4.27

• This may create a conflict of interest for the letting agent, the landlord's agent should be under no duty to answer questions about the tenancy agreement, except where instructed by the landlord. The tenant should be advised to seek independent advice if they have any queries about the tenancy agreement.
• A timeframe should be set for this, so that tenants are not pressurised into signing a tenancy agreement too quickly.

Section 4.28

• This should include text suggesting that a tenant information pack, and all relevant certification (in line with repairing standard), is included so it is clear what information should be supplied to the tenant.

Tenancy deposits

Section 4.30

• Specific reference should be made to the Tenancy Deposits Schemes (Scotland) Regulations 2011.
• The terms and Conditions of Business should state clearly who will be responsible for lodging the deposit, and whoever is responsible, must comply with the tenancy deposit schemes legislation and inform the tenants accordingly.
• Reword: 'Your Terms of Business with your client must make it clear who will lodge the deposit and issue the Prescribed Information - the landlord, or the agent (on his/her behalf)'.
• This section should also make clear that if an agent is aware that a landlord has not lodged a tenancy deposit, they must report this to the local authority.

Moving in (inventory/ check-in)

Section 4.33

• This duplicates section 4.36, one of the sections should be removed.
• It should be clear that the letting agent is signing on behalf of the landlord.

Section 4.34

• A timescale should be added for agreeing the inventory, 7 days from signing the tenancy is reasonable.

Section 4.35

• Advice should be provided on what is 'reasonable', as many tenants ignore calls, emails or texts. It would be better to set a deadline of 3-5 days.

Section 4.37

• This is already covered in section 327 of the 1987 Act.
• This obligation is at odds with a Scottish solicitor's duty of confidentiality. Landlords are registered on a publicly held register, so disclosure of an address should be unnecessary. All communications with the landlord should be made by the tenant through the letting agent. More explanation required of the intention and reason behind the provision.
• If another owner of property in the building/tenement asks for the contact details of the landlord, the letting agent must also tell them within 21 days.

Section 5: Management and Maintenance

Rent Collection

Section 5.3

• This section should be expanded to include that receipts must be issued as standard practice when payment is made (either in paper form or email/text), and that a statement should be issued as mandatory at least every 6 months.
• The tenant's right to refer their rent to the Private Rented Housing Panel for a rent determination should also be referenced.

Property access and visits

Section 5.10

• There should be other ways to deal with this that does not require a court order. Often entry is required to undertake mandatory or statutory works, and access could be gained by a simpler procedure through the housing tribunal system.
• This section should make reference to the landlord's new power to apply to the Private Rented Housing Panel for assistance to enter the property to inspect or carry out works to bring the property up to the repairing standard.

Section 5.12

• Clarification sought - if a letting agent is aware that a tenant has damaged the property, or is not looking after it properly, despite being told how to, does this allow the agent to take appropriate action on the tenant's behalf and bill them for the associated costs?
• A written copy of whatever has been discussed/proposed at the time of these visits should be provided to both landlord and tenant.

Carrying out repairs and maintenance

Section 5.13

• There should be a specific requirement for written procedures on handling communal repairs, in accordance with title deeds and Tenements (Scotland) Act 2004, or other legislation where applicable.

Section 5.16

• The first sentence states the letting agent must give clear information about who is responsible for repairs. It is not clear as to what is meant by this. The landlord will usually be responsible, as the landlord cannot contract out of the repairing standard duty. Is the intention that the tenant be given clear information about the identity of the contractor who will carry out the repairs?

Section 5.17

• No timescale provided in this section, which will make it difficult to enforce this provision. Suggested amendment to line 1, 'you must as soon as reasonably practicable carry out the following: inform the landlord in writing....'.
• This is not practicable in relation to small repairs. Delete: 'confirm enough funds are available from the landlord' and replace with 'have sufficient monies in the Client Account to be able to instruct the repair'.
• This is too prescriptive, arrangements for dealing with repairs management up to a certain expenditure level should be set out in the terms of business agreement.

Section 5.18

• This is out of sync with 5.17 where it is stated that the landlord must be informed in writing and quotes obtained etc.

Section 5.19

• This should be expanded to mention that any information on any action being taken to remedy any repairs, should be noted in writing, in addition to any other methods of communication.

Section 5.20

• Text missing after words "reasonable notice". "Reasonable notice" of what? Should it be reasonable notice of the requirement for access.

Contractors and third parties

Section 5.24 + 5.25

• This should be in line with the FCA, who do not require up front disclosure of commission unless the client especially asks. This should be made clear in terms of business agreement.
• It is not clear why this has been included. There does not appear to be a systemic problem with undisclosed commissions. It would be difficult to enforce the provision, and it would be out of proportion with any purported benefits.

Contingency arrangements

Section 5.26

• It is essential that a 'Disaster Risk Assessment' be carried out to ensure continuity of service to landlords and tenants.
• Complying with this clause will be difficult for many letting agents, particularly those who operate as a sole trader without any staff. If retained as a mandatory requirement, further guidance will be required.

Section 6: Ending the tenancy

Bringing the tenancy to an end

Section 6.1

• When negotiating on behalf of a client, the power of the acting agent to make agreement is dependent on the mandate supplied by their client, the landlord. In such cases the ability to be reasonable will be subject to that mandate.
• This section should make clear that letting agents must inform a landlord in writing, and as soon as possible after a tenant decides to end the tenancy.

Section 6.2

• The procedures should be in easy to understand language, free from jargon or hard to understand phrases. This will ensure tenants understand this process.
• After 'you intend to end the tenancy', reference to 'on the landlord's behalf' should be made, given that the letting agent will be doing so in their capacity as an agent for the landlord. The sub-section implies that a letting agent could make the decision to end the tenancy themselves. It is important that situations in which a letting agent would seek to terminate a tenancy agreement are clearly set out in the agreement between landlord and letting agent, for example, where a tenant has breached the terms of their tenancy agreement.
• Suggest that this would better sit in section 2. 'abandoned tenancies'.

Section 6.3

• This is not clear, does this mean pre or post a single event, or events as they unfold. Is it aimed at the landlord, the tenant or both?

Section 6.5

• This requires that the letting agent follow the correct legal process for ending the tenancy. We would suggest that this duplicates that stated in section 6.1.

Inventory/ check-out

Section 6.6

• Offering clients, the opportunity to be present at the check-out visits should not be mandatory. Letting agents have a duty to protect themselves and their staff against difficult tenants and /or landlords, as there may be some circumstances where is not advisable for staff to attend check-outs, or where additional staff need to be present.
• A pre check-out visit, a week before the tenant leaves, might give more time to address issues.

Section 6.7

• Should say 'preferably in daylight hours' after 'ensure it is conducted thoroughly.'

Section 6.8

• Any offer made to the tenant giving them the opportunity to be present at the check-out visit should be in writing, so that all parties have proof of such an offer.
• This section mentions 'reasonable time, the tenant and letting agents understanding of this is likely to differ, therefore, a minimum time period would be useful. This would allow a tenant to make any necessary arrangements re work, childcare etc., so that they can be present at the check-out visit.

Tenancy deposits

Section 6.10

• It is important to make clear that an agent may have this role only where they have lodged the deposit and are managing the tenancy.
• Clarification is required here, as it is assumed that a landlord could only apply for access to the tenancy deposit scheme if there was damage to the property.

Section 7: Communications and resolving complaints

Communications

Section 7.1

• This could be strengthened to say that letting agents 'must' include their registration number in all relevant documents. It is not clear what a 'relevant document' is. Does this mean that the letting agent's registration number should be listed on every letter, email and text message sent by the company? It will not be practical to include this in text messages.
• Remove 'take all reasonable steps'.

Section 7.2

• More guidance required on what would be a 'reasonable' timescale to respond to enquiries and complaints. Scottish Government should specify a clear timeframe, for example, within 28 days this would create a level playing field for agents, tenants and landlords alike.
• The timescale for responses should either be defined, or stated as a 'no later than' rather than 'within a reasonable timescale', as letting agents will have differing definitions of reasonableness, and it would therefore be better if all parties were working to roughly the same timescales.
• It is not satisfactory to expect a quick response to continuous 'unreasonable complaints'. This may become an issue if the proposed grounds for possession in the new model tenancy do not cater for such circumstances.
• Responses should be made in writing, as often agents will ignore emails, and will only speak to tenants on the phone. This means that there is no accurate record of what has been discussed, and the tenant cannot evidence that they have met their responsibilities and the agent has not met theirs. This type of evidence would be essential for any complaint to the Tribunal.

Section 7.4

• The Code should be much more widely available in order that all can see what is covered, and should not just be made available on request.
• Suggest landlords and tenant are made aware of the purpose of the Code - they may then be interested in the content. The Code should be included in the Tenant Information Pack (TIP) and be included as an appendix in an agencies Terms of Business, and also be displayed on the Agent's website, as well made available to the public on the Renting Scotland website.

Complaints resolution

Section 7.6

• 'Landlord and tenant' should be 'landlord or tenant'. Otherwise this could be interpreted as applications need to come from both landlords and tenants, if they are to be considered by the tribunal.
• More detail required on the 'ADR services'. What will be the interplay between this and the 'FTT'? Is it the intention to actively promote ADR services, as a way of preventing calls on the statutory tribunal?
• This section needs to be clearer about the role of ADR schemes as the logical second step (the first being the agent) in dispute resolution, and the fact that does not compromise further referral to the FTT, being the third step.
• Scottish solicitors are subject to the Scottish Legal Complaints Commission (SLCC). Will the Code accept the SLCC as a FTT?
• There is no mention of a potential landlord or a prospective tenant here - do they not have a right of redress? There will be prospective tenants who have been charged administration or referencing fees, and have been unsuccessful in their application - how do they take forward a complaint?
• There should be reference to TPOS.

Section 7.7

• It is not clear why the correspondence needs to be kept for six years, as claims prescribe in Scotland after five years.

Section 8: Handling landlords' and tenants' money, and insurance

Client accounts

Section 8.2

• A letting agent will be receiving money from a tenant which is either a deposit (tenant's money) or rent (landlord's money), and as such it must be lodged in separate bank accounts. The wording of this clause is misleading, and maybe the clause itself is unnecessary if 8.3 is properly worded.

Section 8.3

• The Scottish Government should ensure that these types of account are readily available, reasonably priced and have conditions which letting agents will be able to comply with before making them a mandatory requirement of the Code.

Section 8.5

• It would be useful to state how frequently client accounts should be reconciled, monthly would be reasonable - frequent reconciliations enable errors to be identified quickly, and remedial action to be taken.

Section 8.6

• This section should mention that money will made available once deductions are made for invoices already allocated to the statement.
• Control and release of client funds should be as agreed in the agency contract. It is common practice for a float to be held, or other means to discharge landlords' commitments to payment of accounts.
• Reword this section to read: 'You must ensure clients' money is available to them on request and is given to them without unnecessary delay or penalties, unless agreed otherwise in writing'.

Section 8.7

• Interest cannot be accrued on a proper client account.
• Remove 'if feasible', interest should be paid on any money held.
• This is very onerous for letting agents. The administrative burden far outweighs any benefit from interest earned. The Estate Agency Act 1977 seemed to deal with this more pragmatically.

Section 8.8

• Clarify the meaning of a clients' money protection scheme. If this is required, agents should be obliged to inform potential clients of a relevant insurance policy under section 3.

• There is no reason why this cannot be displayed in an office and included in the Terms of Business etc.

Debt recovery

Section 8.10

• Does this refer to late or unpaid rent? The terms 'unreasonable' and 'excessive' are subjective, and therefore unclear.

Money laundering

Section 8.12

• This section should say 'that if your organisation carries out any of the roles (letting agent selling to tenant in situ, letting agent selling landlords property to other landlords or anyone else, letting agent acting on behalf of a landlord to source property for buy to let, investment etc.) or duties caught under the definition of estate agency then it must register with HM Revenue & Customs'.
• Currently letting agents are not subject to money laundering legislation, this only applies to estate agents and solicitors, and therefore it should not be included within this section of the Code.

Section 8.13

• Police Scotland should be the first point of contact, rather than National Crime Agency, in relation to suspected criminal activity.

Section 8: Handling landlords' and tenants' insurance

Professional indemnity arrangements

Section 8.14

• The wording should be clearer: 'Written confirmation of the following should be obtained from the banks at which client accounts are held:

1. All money standing to the credit of that account is clients' money.

2. The bank or building society is not entitled to combine the account with any other account or to exercise any right to set-off or counter claim against money in that account in respect of any sum owed to it on any other account of the agent or his/her firm.

3. Any charges or interest levied in respect of the account should not be debited to it'.

Section 8.15

• This requirement is too weak, a letter detailing their insurance provisions should be provided with the application to be on the register.
• Professional Indemnity Insurance cover must be 'retroactive', in order to fully protect landlords and tenants. This could be achieved by removing 'if feasible' from clause 8.15 and replacing 'should' with 'must'.

Provision of insurance products

Section 8.16

• This may be more relevant to the FCA regulations. If agents are advising on cover, obtaining information, collecting money etc. then they need to be registered in some form, either direct with FCA, or as an Appointed Rep of a FCA registered Broker.
• A section needs to be added to ensure that the landlord has adequate buildings insurance, including where relevant, communal insurance. Tenants should be given proof that the landlord has buildings insurance in place, and there should be a copy of this appended to the tenancy agreement.
• Clarification required on the meaning of 'lawfully authorised'. Does this mean that the letting agent must be accredited as an Independent Financial Adviser or insurance agent?

Section 8.17

• There may be cases where an agent arranged insurance for the letting agent, and there is a commission sharing arrangement. This is the practice for factors who arrange buildings insurance through a third party agent, rather than direct with the insurance company providing cover. Therefore, the wording of this section should be changed to read 'or agent arranging the insurance cover', after the words 'providing insurance cover and after 'insurance provider'.

Part 2 - Training Requirement

Proposal 1: Matters on which training must have been undertaken

Sub section 9.1a

Legal Obligations

• Health and safety standards need to be more explicit - suggest more prescriptive wording, such as 'compliance with all current health & safety requirements, including gas, electrical, water and fire prevention regulations'.
• Awareness of responsibilities under the Equality Act 2010 regarding protection against discrimination.
• Implications of Universal Credit need to be covered.
• An understanding of the implications of all relevant housing law on private letting.
• An understanding responsibilities relating to cyclical maintenance of property in common ownership.

Proposal 2: Persons who must have undertaken training

Respondents also suggested additional areas that might be covered in Proposal 2, as follows:

• A number of organisations proposed that the second bullet point should be expanded to include frontline staff, and suggested the wording be changed to: 'managing, supervising or undertaking the letting agency's operations.