Friday 26 May 2023
In the Special Bulletin dated 18th May we indicated that we are disappointed in parts of the package of preferred options proposed in the C-RIS which was released on Monday 15th May.
As promised a brief example of the reasons behind our reactions to the preferred options, including our objections appears below.
If you prefer to read the below in a table format please Click HERE for our PDF version.
The Governments’ preferred package includes the following options, we include brief comments:
Proposal – Option 2
Require residential parks to publish a comparison document.
We believe that this could be advantageous to both new and existing home owners. It will have our support subject to further detail being available about the information to be included and how it will be verified.
Proposal – Option 3
Simplify the sales and assignment process.
Under this option, all site agreements for prospective home owners will be new agreements with updated terms and information. However, buyers’ agreements must carry over prescribed terms (such as site rent) from sellers’ agreements.
We support this as a means of ensuring that the new contracts for purchasers of home are not able to be used to increase site rents or reduce the levels of service provided to home owners.
Our support relies on the extent to which these goals are achieved.
Proposal – Option 4
Limit site rent increases to a prescribed basis.
This option limits site rent increases in new site agreements to bases prescribed by regulation, this may include;
CPI-based calculations, increase in expense based calculations, and or fixed percentages
Park owners must use one of the prescribed bases and disclose the basis to home owners, increasing transparency and reducing complexity of future site rent increases.
This would apply only to new site agreement.
We believe that this proposal may provide greater clarity for new home owners about how their site rents will be increased.
We are in favour of the idea of not allowing park owners a free rein in deciding how site rents are increased. However given the limited detail, our full support for it will be reliant on further information.
We are also concerned about what methods of increasing site rents will be prescribed as being allowed.
Proposal – Option 6
Prohibit market rent reviews.
We very much welcome and strongly support this proposal.
Proposal – Option 7
Limit site rent increases to the higher of CPI or a fixed percentage (for example, 3.5%)
We support the concept of having a cap on site rents which will limit the size of any increases that result from the calculation method included in existing site agreements minus market reviews.
However we believe that setting a cap at the higher of CPI or 3.5% would disadvantage home owners while benefiting park owners.
We will advocate strongly for setting any cap in a way which does not disadvantage home owners.
This is one of our major concerns about the proposals being put forward. We do not want to allow these changes to the Act to result in home owners paying increasing proportions of their income on site rent every year.
Proposal – Option 10
Require maintenance and capital replacement plans.
We proposed this measure in our submission to last year’s Issues Paper as a way to ensure that the standard and quality of facilities and amenities in parks is maintained.
Proposal – Option 11
Establish a limited buyback and site rent reduction scheme.
We are strongly in favour of site rent reductions when homes are unoccupied. However, we will advocate for them applying after a much shorter period of time than at least 12 months, as is proposed here.
We are also in favour of the idea of buy backs of homes which parks owners fail to sell on behalf of home owners. However we have some concerns about the ways proposed to do this here, particularly the timelines suggested.
See pages 8 -13 of the C-RIS Summary Paper HERE
As promised, QMHOA intends to provide members with a copy of our draft full response to the C-RIS for your consideration and feedback when it is available. We will do this in ample time for you to provide feedback before the deadline of the 26th June 2023.
At this stage we have limited our comments to the options included in the preferred package put forward in the C-RIS. We draw the attention of member to the 8 additional recommendations which are also included in the C-RIS on page 16 of the Summary. These are an important part of the overall set of changes being proposed. Our draft of our full response will include our views on these.
We welcome any and all feedback, comments and suggestions on the above and the C-RIS document generally to firstname.lastname@example.org or click on the button below.
Roger Marshall | President
Queensland Manufactured Home Owners Association Inc.
Interim Management Committee
26 May 2023
Keeping Manufactured Home Owners in Queensland Residential Parks informed and represented.