Committee publication · Correspondence · 26 March 2026
Letter from the Leasehold Knowledge Partnership to the Chair dated 9 March 2026 following up oral evidence given before the Committee on 3 March
From: Housing, Communities and Local Government Committee
Inquiry: Pre-legislative scrutiny of the draft Commonhold and Leasehold Reform Bill
Summary
The Leasehold Knowledge Partnership writes to the Housing, Communities and Local Government Committee following oral evidence on 3 March 2026, detailing failures in property managing agent regulation. The letter argues that voluntary self-regulation is inadequate, that freeholders lack accountability, and that existing redress schemes cannot address core leaseholder concerns about service charge validity and reasonableness. It also challenges evidence given by the Residential Freehold Association regarding ground rent caps and fire safety compliance.
Key findings
- Voluntary regulatory schemes are ineffective: former Labour MP and ARMA adjudicator Sally Keeble resigned because voluntary regulation was inadequate and prevented her investigating a building where a fatal accident occurred.
- Critical gap: freeholders are entirely unregulated and not subject to redress schemes; redress schemes cannot adjudicate on service charge validity or reasonableness, forcing leaseholders to pursue expensive First-tier Tribunal cases where landlords can recover legal costs exceeding £250,000.
- The statutory code of practice for managing agents (administered by RICS) is 'meaningless'; FirstPort has claimed it is not bound by it despite being appointed by regulated members.
- Trade body The Property Institute (TPI) provides inadequate protection: FirstPort remains a TPI member despite sustained leaseholder complaints and only faced short concurrent suspensions in 2024-25 for issues unrelated to leaseholder complaints; LKP continues documenting FirstPort withholding service charge balances and reserves for 18+ months.
- RFA's ground rent cap evidence may be misleading: office buildings and trade union premises likely fall outside the £250 cap's legal scope (requiring single dwelling status and restrictions on business use); Committee should seek clarification on specific examples cited.
Tone
AdversarialTopics
Key actors
Leasehold Knowledge Partnership, Florence Eshalomi MP, Sally Keeble, Association of Residential Managing Agents (ARMA), Residential Freehold Association, FirstPort, The Property Institute (TPI), TIME Investments
Notable line
“We consider the TPI is an inadequate protector of leaseholders' interests. The chief example of its failure is that FirstPort remains a TPI member despite the enormous volume of complaints made by leaseholders against it over many years.”
Key Quotes
“Ms. Keeble resigned from her adjudicator role with ARMA before her contract ended because she considered voluntary regulation was inadequate and subject to too much pressure that was preventing her from investigating an ARMA member running a building where there had been a fatal accident.”
“… the critical gap in the current system of regulation is that freeholders are not required to be subject to any redress scheme”
“In our experience the statutory code of practice is meaningless. We are aware of at least one example where FirstPort, appointed as managing agent by an RFA member, has asserted it is not bound by the statutory code of practice because it is not regulated by RICS.”
“In the worst cases we have seen the amounts involved run to hundreds of thousands of pounds and have been ongoing for 18 months or more.”
“Freehold Managers pled guilty and was fined £50,000 by Birmingham magistrates”
Source · parliament.uk record ↗