Consultation Responses

We have responded to a HM Treasury consultation on improving the effectiveness of the Money Laundering Regulations. In our response, we raise awareness of a number of practical challenges that businesses have in applying the regulations, and suggested some options to remove ambiguity and streamline the process to reduce the administrative burden on businesses.

We have responded to the Government’s consultation on locally-led development corporations. We support the locally-led model, and welcome the increased flexibility that this model can provide. We have, however, highlighted the need to ensure that corporations have the right powers if they are to be truly effective and note that there is huge insight and experience on development corporations within the BPF membership.

We raised concerns over the impact that removing certain LTT reliefs (including multiple dwellings relief (MDR) and the ‘6 or more’ commercial treatment for transactions of 6 or more dwellings) could have on the Build to Rent and Purpose Build Student Accommodation markets. These tax treatments are critical for supporting investment rental homes and ensuring that Wales’ transaction taxes are competitive compared to other jurisdictions.

We strongly support Government’s overall aspiration to accelerate the planning process for commercial development to drive economic growth and create jobs. Our response provides constructive comments on how the measures proposed in the consultation could be improved as well as suggestions on how the wider planning consenting regime could also be accelerated.

The BPF response to the DLUHC consultation on introducing a competence and conduct standard into the social housing sector.

Our short response to the 2023 consultation on the Future Homes and Buildings Standards. This draws on our response to the 2021 consultation, which you can find here.

The BPF's response to the Department for Levelling Up, Housing and Communities' consultation on strengthening planning policy for brownfield development.

This sets out the BPF’s views on aspects of the draft guidance for local authorities undertaking High Street Rental Auctions, and is a supplementary response to the main consultation response that was submitted via an online survey tool.

Our response to the Basel Committee on Banking Supervision's (BCBS) on proposed new climate related disclosures for banks we expressed concern that the proposed disclosures could incentivise bank lenders to divest their exposures to 'brown' buildings rather than support their borrowers in decarbonising those buildings. We recommended disclosures instead focus on the extent to which borrowers had plans to decarbonise their properties.

We support the broad policy of encouraging the development of low carbon heat networks, which align with the sector’s net zero ambitions. We do, however, want more transparency and reassurance on cost and quality and want maximum visibility and certainty over the development and roll out of individual heat networks. It will be important that local authorities are sufficiently resourced to deliver any new responsibility and further consideration needs to be given to landlord and tenant issues.

The BPF response to the Government’s second technical consultation on the Building Safety Levy

We welcomed this initiative to boost transparency of land and property ownership through trusts. We stressed the importance of ensuring that the administration and compliance requirements were streamlined and efficient for investors (especially widely held funds); that agencies registering the information had sufficient resources; and that enforcement agencies have sufficient powers to ensure widespread compliance.