The Council of Mortgage Lenders’ (CML) Director General Michael Coogan, has said that the HIP infrastructure now looks like “a costly indulgence”, and urges the government to think again about whether it can still be justified.

Since the government dropped the requirement for a home condition report in the packs, but stuck with plans for a complex certification system and databank for inspectors producing energy performance certificates, the CML thinks is a move that now looks disproportionate and anachronistic.

Michael Coogan comments: “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, 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, Mr Coogan concludes: “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.”

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