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Johnr12
27-06-2006, 00:32 AM
Hello all,

I currently live with my wife and 4 friends in a three storey building owned by myself, with us all sharing amenities. I am aware that this is an HMO.

I am unable to afford the new HMO licence, and certainly would not be able to afford all the building work that would be required for the granting of a licence, (if indeed it were physically possibly to fit all the modifications in, which I doubt), so therefore I am left with the option of reducing the number of people in the house so that it falls under the '5 people or more limit' for licencing.

What I am trying to determine once and for all is how many tenants would have to leave so that I would not need a licence. One of my tenants is looking to leave within the next month, so I do not want to take on one or two new tenants if this will cause problems. My council has been less than helpful with their guidance. So far I have three differing opinions from the same department, on the phone, by email and at a meeting at the local town hall! I have to keep contacting them anonymously as well, which is just ridiculous, but I don't wish to tip them off just in case I end up doing something wrong in their eyes.

In light of this situation, if someone knowledgeable would be able to answer any of the following questions, I would be extremely grateful:

1.) If me, my wife and 3 tenants live together in the building, do we count as 4 people or 5 people for the purposes of licencing? (one council representative informed me that my wife and I only count as one person, however I think he almost certainly meant one household). I am guessing that I will need a licence - correct?

2.) How likely is it that councils will go door to door after the deadline has passed to check up on all the three+ storey buildings in their area? Will the prospect of netting £20,000 for themselves for every infringement mean that they will pursue this rigorously, or is the reality of the situation that they will just respond to complaints from unhappy tenants?

3.) If the Council suspects that a house should be licenced, I understand that they have the power to simply turn up whenever they like and enter the premises with no warning. Is this true? Would I just be able to stand at the doorstep and explain that we are under the 5 person limit, or are they within their rights to barge past me and inspect my house?

4.) If my wife and I claimed that the house was not our main residence, and that our main residence was living with my parents, where would we stand then? I am interested to know when a person is actually considered as 'living' at the premises for the purposes of licencing. If we were to say, for example, that our bedroom was simply maintained in the house for when we decided to visit occasionally, would this prove convincing enough for the council? If it came to a court case, would we have to prove that we did not live in the house, or is our word, and the fact that council tax records showed us as living at my parents, sufficient proof?

5.) If four unrelated people live together, a licence would not be required, but it would still be an HMO. Does this mean that all the building and safety standards prescribed for HMO's would still need to be observed? If so, and with no licence in this situation, how does the council know that all the neccessary work has been done? Do they have another way of tracking all the non-licenceable HMO's in their area, or do they just slip through the net?

6.) I am considering purchasing a large wooden cabin in the rear garden, and using it as a bedroom for one of the tenants, as his current bedroom is about 5 square feet under the 70 sq ft. mimimum. He is more than happy where he is, as there is copious communal space in the house, but I do not wish to risk being pulled up on this by the council should the situation arise. The cabin will be an entirely separate structure to the house, about 6 metres from the rear door of the house. Does the cabin need to be fully self-contained? (shower, toilet, cooking facilities) or is it acceptable for him to continue to use the facilities in the house (which are located on the ground and first floors), even though this journey will be via the garden? Can I just add that the cabin is entirely his suggestion, which he is extremely excited about - I am not forcably jettisoning him into the garden! He would also prefer to be without facilities in the cabin, as it would give him more living space. Once he is in the cabin, is he considered as living under the main house roof for the purposes of calculating how many people live in the house? Or is the cabin treated as a separate building with its own occupant, even though it is on the same piece of land?


Thank you very much for any help you can give me here. Worrying about this licencing has frankly made my life a misery for the past few months. I understand all too well the benefits that licencing will provide for disadvantaged tenants, but we have all lived happily together for years now in a well maintained, modern house. I just wish there was some way that tenants could agree to sign a document to say they are happy with their living arrangements if asked by the council, so that cases could be considered on a more individual basis, but I guess that would have its own problems. I am also concerned about the councils' extra discretionary powers. What is to stop them just saying that they are going to demand a licence for all HMO's regardless of number of occupants? Seems as though the only 100% guaranteed way of me having peace of mind is to get a licence regardless of circumstances...

Thank you, John.

Sandi
27-06-2006, 09:27 AM
According to national HMO network website Exemption from HMO licencing is available For a property where the landlord and their households live with up to two tenants. Further info is available on www.nationalhmonetwork.com. Personally my own view is that you should just get a licence and do the neccesary work. Whilst I understand you can't afford it I would borrow the money to do the necessary work and repay it over a period of time. I fought against the conditions (which I still believe to be ridiculous:mad: ) relating to my property in Scotland and ended up paying out £15,000 after my licence was turned down cost of mortgage payments for voids etc instead of about £4,000 if I had just done what they asked in the first place. I would also advise that in Scotland once the council identifys an unlicensed property they first of all look for payment of the licence they then give you a period of time to complete works and if you don't do these works they turn down your licence and if you continue to let the property unlicensed then they take legal action against you. Once legal action is taken you can expect a sizeable fine in Scotland I believe this to be about £3,500 out of our maximum £5,000. In Scotland I am only aware of two landlords being fined with most complying all be it reluctantly with the council.

RJL
27-06-2006, 10:03 AM
To try and answer some of your questions.

1. If there are more than two unrelated households and five or more persons in a three storey house then the property nedds a mandatory HMO licence. You must apply to the council for this. Failure to do so will result in a fine of £20,000, plus you will not be able to serve any notices on your tenants. The powers also mean that you may be required to pay back all rents received back to a date when the property should have been licensed.

You will also not qualify to be the License Holder as prescribed as a "Fit and Proper Person"

2. If there are less than five persons in a property of three storeys then it will be Licensed as Additional Licensing and therefore you will not escape the rules.

3. The HHSRS applies and therefore you would have to statisfy the council's policy ofr HMO's anyway A court order would be required to enter the property. However again, if it is classed as an HMO you will not be able to be the License holder as you will not be a fit and proper landlord.

Your qestion 5: You will have to satisfy the HHSRS (House Heath and Safety Rating System) which would mean fire doors, L2 alarms etc.

6. The room is too small to be a bedroom anyway, so reduce the occupancy by 1

As these are new laws councils are keen to make a test case - do not let it be you

Johnr12
27-06-2006, 12:43 PM
Hello, and thank you both for your responses. It is very much appreciated.

While I agree with virtually everything you have said, the one point that I am unsure on, and am seeking clarification on with the Council is the following:


"If there are less than five persons in a property of three storeys then it will be Licensed as Additional Licensing and therefore you will not escape the rules."


When one takes a look at the exact wording on the government pages, it has this to say about additional licensing:

"An LHA can make an additional licensing scheme that may apply to HMOs (other than those that are exempt from licensing/ definition or subject to mandatory licensing) in its area, or any part of it."

It says that it can enforce additional licencing - not that it certainly will. If what you say is true, I am sure there would be more word of this from various sources. My own council's webpages and those of many other councils that I have checked all say that they will be primarily concerned with
mandatory licencing, and that additional licencing would only come into play in particularly poorly managed areas, or as stated on the Camden Council pages,

"generally cover smaller HMOs, ie those fewer than three storeys."

If this was indeed a widespread intention, surely Council guidelines online would state that they definitely wanted to license ALL 3 storey HMO properties and thereby avoid any confusion or dispute whatsoever. To be honest, I am suprised that they haven't. I can find no evidence of this possible course of action in anything I have read or in anything that I have been told. I can only follow the official wording above, communicate my concerns to my Council, and (hope) that there is some room for manouvre in individual cases.

Clearly I would be naive and reckless to think that these vague proposals would cover me in any way whatsoever if my council suddenly said that it was going to use additional licensing where I am concerned. If they decide for whatever reason (or maybe no reason?) that they want me to be licenced, then so be it, and the application will be in hte post asap. I am not going to take that risk, either for myself or my tenants. What I am going to do is the following:

I am seeking written confirmation from the Council that I will not be subject to additional licencing with 4 people in a three storey house, and ensure that they know where I am located and that they will not be implementing additional licensing where I am. I have already received verbal confirmation of this at a meeting for landlords from a member of the Council's private sector team dealing with HMO's and licencing. Obviously, his word won't count for much somewhere down the line if they decide to go with additional licencing, which is why I would like written confirmation. Whether or not that would have any legal weight to it in itself I do not know, but at least it would demonstrate that I had made every effort to find out what their opinion was, and to confirm that I was abiding with the decision they had given me.

If I am not able to get written confirmation, then I will apply for the licence. I do not see why I should pay for a licence if I have confirmation from the people who are setting out the rules that I am not subject to mandatory OR additional licencing. Simply getting a licence to be 100% safe seems at the moment to be overcautious, but obviously my appraisal of the situation may change depending on the Council's response.

Thank you very much for your replies, and for presenting the worst case scenario. While I was well aware of the consequences should I ultimately require a licence and then not have one, you have confimed the importance of not taking anything for granted when the stakes are so important. Glad to hear your words of wisdom and caution.

Thank you, John.

Johnr12
27-06-2006, 13:26 PM
Sorry, I neglected to say that some of what I just mentioned comes under the selective licensing scheme, rather than additional licensing :o

I have read on Camden Council's website, that as far as additional licensing is concerned, LHA's can choose to introduce it, but they have to consult local landlords first, and they have to publicise it when it comes into force. As far as I am aware, neither of these things has occured where I am. (Yet!)

I will of course confirm this when I speak to them today.

Thanks, John.