He has urged the Government to think again about whether HIPs can still be justified.
The CML has never been anti-HIP. But, despite having dropped the requirement for a home condition report (HCR) in the packs, the Government is still sticking with its original plans for a complex certification system and databank for inspectors producing energy performance certificates (EPC) - which now looks disproportionate and anachronistic.
Coogan commented: "This infrastructure seems a costly indulgence. It is also a clear-cut example of gold-plating. We have therefore written to the Better Regulation Commission to draw its attention to this example of poor implementation of European legislative requirements."
HIPs are due to undergo a dry run to test their effectiveness in practice. However, the CML does not believe this will be a robust test of the new arrangements. It is already well behind the original schedule, and is being operated by the Association of Home Information Pack Providers (AHIPP), which naturally will wish to see success. Government funding has been made available to artificially incentivise take-up, compared with the true cost that will subsequently apply to any universal roll-out. And the Government has published no clear criteria for monitoring or evaluation of the dry run.
Pointing to the recent innovations that have emerged from lenders in making unconditional mortgage offers at the point of sale, using credit reference information about the borrower and automated valuation data about the property, Coogan concluded: "Comparing our experience with other countries around the world, I am even more convinced that market forces should be the primary mechanism for delivering improvements to the house buying and selling process. The current HIPs framework, seemingly justified by the EPC requirements, is simply not proportionate and could not pass a robust regulatory impact assessment.
"It is time for the government to think again ... again."
