Written evidence submitted by Mr. Jonathan Knowles [PRS 026]

 

•     An extensive property portfolio of >2,000 Lockdown units is being operated by a Cartel of ‘Rogue Landlords throughout Greater London;

•     It is comprised of over 360 property companies with unlicensed HMOs, fixing rental rates and gouging the tax-payer;

•     Substandard housing and outcomes for the poorest and most vulnerable people in our society;

•     There are multiple failures of DCLG agencies and LAs to acknowledge, much less tackle, the problem;

•     A separate enquiry is urgently needed into cartel activities including full audits of all entity accounts by HMRC;

•     An investigation should be commenced by the Charity Commission to determine the involvement of a number of charities in channelling public funds to unknown parties both in the UK and overseas.

•     Property and profit confiscations for serious and/or repeat offences should be instituted;

•     C3-C4 Change of Use must be removed from the GPDO and revert to planning permission;

•     The HCA must be disband or reformed and ‘for-profit’ providers of Social Housing disallowed;

•     Mandatory prosecution of companies operating unlicensed HMOs commencing upon  discovery;

•     Urgent changes in law are required to prevent abuses and destroy the Lockdown business model;

•     Nothing short of a public register of rogue landlord companies and directors, struck off and prosecuted for housing offences must be instituted.

 

Executive Summary

 

A resident of Hanworth Ward in the London Borough of Hounslow (LBH), I have been  campaigning since January 2016 to expose the practices of a cartel of Lockdown Landlords appearing in my neighbourhood. In the face of inaction, denial, opposition and resistance from LBH, regulatory bodies and government departments, I extended my research London-wide. I am shocked and appalled by what I have uncovered. I have made my research available to The Times, The BBC and a number of other media outlets in an effort to raise awareness. I now submit evidence to the Committee because I find the laws and bodies governing the private rental sector are wholly unfit for purpose, systematically circumvented, or ignored with impunity.

 

  1. I am keenly interested in this strand of the enquiry as it relates to Houses in Multiple Occupation (HMOs) subject to mandatory LA licensing or exempt by virtue of the involvement of a Registered Social Landlord (RSL). I shall therefore limit my submission within this area of the private rented sector and to a particular genus of ‘Rogue Landlord’, known to housing wonks as ‘Lockdown Landlords’. The defining feature of such landlords is the sub-division of modest, suburban 2-bed properties into rarely more than 5 or 6 very small bedsits of c.12 sq. m under the guise of Permitted Development (PD).

 

  1. Having studied thousands of property records across all London boroughs in the past year in an attempt to understand the issues, it became clear to me that an aggressive cartel of hundreds of Stamford Hill property companies is behind the entirety of the Lockdown model. It is not an exaggeration to state that they are not part of the problem; they are the problem. In my examination of records of all properties under 20 sq metres across London assessed since 2014[1], I can find scant evidence that, with the exception of a handful of cases, anybody other than this cartel are involved in these practices. That the cartel has been doing so systematically, successfully and unopposed for a number of years goes to the heart of the matter as can be seen from this map of the extensive property portfolio of the Stamford Hill Cartel.

 

  1. The phrase 'Lockdown Landlord' was coined by Roz Spencer, formerly of Lambeth Council and convenor of the London Lockdown Project (LLP) a consortium funded as a charity by the DCLG in 2016. Their mission statement is the laudable aim of ‘Disrupting criminal rogue landlords and their property portfolios’. Apparently, in July 2016 a report was produced for the DCLG and nothing since has been seen or heard concerning it. The LLP, Lambeth Council and the DCLG denied access under FOI to the 2016 report, citing exemption at section 31(1)(a) of the FOIA, and I have been forced to take the matter to the Office of the Information Commissioner (ICO) where an investigation has been commenced (case FS50679570).

 

  1. In January 2016, nineteen London Local Authorities received over £2,500,000 to specifically target the problem of ‘rogue landlords’. the London Borough of Hounslow (LBH) received £67,500 whilst Lewisham Borough Council (LBC) received £151,378. It was before, during and after this time that the Stamford Hill Cartel moved into these two boroughs unopposed. At time of writing Lewisham alone has in excess of 50 unlicensed Lockdown premises in the Wards of Bellingham and Whitefoot. Since Universal Credit (UC) has yet to ‘rollout’ in Lewisham it follows that in these cases it is the local authority who is currently managing the payment of Local Housing Allowance (LHA) directly to the Lockdown Landlords involved. That they do so directly to the landlords will be discussed elsewhere in this submission. It is deeply shocking that despite receiving substantial public funds to combat abuses of exactly this kind, LBC were directly paying Lockdown Landlords a sum of money much greater than the 2016 grant to end the abuse. My research indicates that there are a total of 275 Lockdown units in Lewisham alone which are being rented for approximately £900 pcm. Assuming that all units were tenanted by LHA recipients this would be generating approximately £250,000 per month.

 

  1. In March 2017, Environmental Health News published a feature on Lockdown which claims, inter alia, that councils have “started to find weaknesses in the model that are enabling them to stem the housing benefit abuse” and that “they are starting to win the battle’” I am bound to say that I see absolutely no evidence of this whatsoever. Indeed there appears to be a certain timidity towards the pursuit and prosecution of these landlords which is reflected in the title of the article. The then chair of the Lockdown Project, Carlene Thomas, says: “one of our main concerns is that we don’t want to create homelessness, so our primary aim is to improve these properties and ensure compliance with the law.” I take great issue with this statement. Every council official I have spoken believes that what the Cartel is doing is within the law and therefore the Lockdown Project’s primary aim is moot. Nor do I subscribe to the view that these practices are within the law as we shall soon see. Ms. Thomas’ laudable aim of “not creating homelessness” is also problematic. The vast majorities of these Lockdown ‘flats’ are held on 6 month Assured Shorthold Tenancies (ASTs) and in any event ‘rogue landlords’ cannot rely on Section 21 notices to evict tenants under the circumstances. It seems that the London Lockdown Project prefers to approach the problem as a fait accompli. Later in the article Bexley’s Head of Housing, Kevin Murphy, hits the nail on the head: “It’s down to the correct interpretation by our colleagues in housing benefit. They have looked at the regulation and interpreted it in the way that I think it is written, which is that the properties are just not self-contained. The key is around the cooking facilities and the interpretation is that they don’t have cooking facilities for their own use.”

 

  1. Given the foregoing, the question arises as to not only whether local authorities have the powers and capacity to deal with ‘rogue landlords’, but whether even government departments do. It has been estimated that £12 billion in housing benefit payments will flow to rogue landlords in the next five years. Millions of pounds have been awarded to LAs and other bodies to address abuses that have exponentially increased during the time they were ostensibly being addressed. Over 110 of the Cartel’s house purchases and their subsequent re-banding as ‘band-A flats’ by the Valuations Office Agency (VOA) occurred in 2016.  At least another fifteen have taken place in 2017. This reduction has less to do with enforcement and far more to do with the time it takes to convert and commission the properties and for documentary evidence to become available. Meanwhile, all we have for succour are rumours of a 15 month old secret report commissioned by the DCLG and no sign of any of the prosecutions which are said to be among the reasons why I cannot have sight of this report.

 

  1. By far the most damaging reduction in the power of Local Authorities to deal with the problem of Lockdown HMOs was the April 2010 change to the General Permitted Development Order (GPDO). This gave PD rights for changes of use from C3 to C4, thereby allowing a change of use from a dwelling-house to a small-scale HMO without the need for planning permission. This single change opened the door to systemic abuse. Article 4 Directions (A4D) are only of use against Lockdown if declared immediately and most LAs are extremely reluctant to grant A4Ds at all, much less with immediate effect. LBH cited the unfounded fear of litigation by landlords over the loss of PD rights. All my attempts to persuade LBH to declare an immediate direction were opposed by Ward Councillors and by Council Officers more broadly. In any event, even an immediate A4D does not undo damage and only kicks the problem back into Planning. LBH eventually did declare an A4D for Hanworth in November of 2016 (effective November 2017) effectively closing the gate after the horse had bolted.

 

  1. A particular side-effect of the 2010 change to PD has been to render Local Authority Plans absurd. LBH’s fully signed-off 15 year Local Plan specifically prohibits the subdivision of properties with original floor space of less than 130 sq. m for use as HMOs. There are numerous other prohibitions which apparently simply no longer apply because C3-C4 is immune from enforcement action by statute. Furthermore, in the case of LBH they consider the Local Plan to be ‘merely advisory’ when it suits their purposes. It seems that LAs either no longer have the power to enforce their Local Plans or simply choose not to. Not a single one of the dozen Lockdown HMOs within a square kilometre in Hanworth TW13 comes even close to 90 sq metres.

 

  1. In August 2017 I wrote to the Mayor of London concerning minimum space standards for new dwellings, conversions and changes of use. Senior Strategic Planner Andrew Russell replied informing me that despite the evident change of use and conversion into ‘flats’, despite the VOA including Lockdown units in its New Homes Bonus figures “under planning law the London Plan policies only apply to planning applications. Planning policies do not apply to development proposals that is already "permitted development"

 

  1. The proliferation of HMOs in the private sector has understandably lead to an increase in regulation which ostensibly aims to protect the health and rights of the tenants. A great many UK boroughs have at least mandatory licensing and sometimes additional licensing. But where a landlord involves a RSL regulated by the Homes and Communities Agency (HCA) they are completely exempt from any LA licensing. No central register of addresses is maintained by the HCA and neither local residents or authorities will be able to easily determine who is responsible for a problematic address. The situation is exacerbated by the entry of ‘for profit’ providers into the landscape of RSLs creating financial incentives for abuse and the avoidance of scrutiny. As the recent C4 Dispatches programme amply demonstrated, no tenant is likely to have ever heard of the HCA much less have any idea of how they might initiate a complaint.

 

  1. The HCA is, by their own admission, a financial regulator with scant interest in the conditions of tenants and the behaviour of landlords. Its ‘serious detriment’ benchmark is so severe that nothing short of negligent death would warrant it to find against a licensee. I have a nine month old complaint ongoing at the HCA concerning the behaviour of a Lockdown Landlord company, Green Park Property Management Limited (07830370) (GPPML)  who have obtained a ‘for-profit’ RSL license (4710) - a very worrying development indeed. If local authorities themselves involve for-profit RPs of ‘Social Housing’ then they are immediately repudiating any and all ‘powers and capacity required to enforce standards’. Yet in spite of the HCAs claim to be chiefly interested in financial rigour they have been unable to provide me with GPPML’s accounts. This is because they are now some 6 months overdue. More disturbingly they appear not to have noticed that the company is wholly owned by another company of a similar name, Green Park Property Ltd (09907777) who do not have a RSL certificate. This second company is, according to the published abbreviated account of 30 November 2016, in turn, wholly owned by the first company, GPPML.

 

  1. It should be noted that the failure to license a HMO is a criminal offence the seriousness of which is underlined by the levying of an unlimited fine upon conviction. This all sounds well enough but if LAs do not enforce but prefer to ‘negotiate’ and ‘appease’ as per the 1998 Enforcement Concordat then the ‘unlimited fine’ is purely theoretical since LAs will always work with the offender to ameliorate the situation. Moreover, no enforcement action can commence if a licensing application is in progress[2]. Since systematic evasion of licensing is a sine qa non of the Stamford Hill Cartel then clearly the law contains no threat and no force. I can think of no other criminal statute whereby if an offender is identified and caught in flagrante they are so readily forgiven or else the penalty is so weak it is viewed as ‘merely the cost of doing business’. You will struggle to find meaningful penalties to deter the Cartel from the record of recent years. In LBH for example, not a single Rent Repayment Order (RRO) has been obtained in the last 5 years. Bexley Council, at the bottom of the housing enforcement league table when compared to all London Boroughs, has at least 60 unlicensed Lockdown premises and have undertaken no prosecutions or RROs in the past seven years. The overall picture is stark: an average of only one rogue landlord per council is prosecuted each year despite 700,000 privately rented properties which are deemed to behave a category one hazard.

 

  1. As long as LAs are requesting the VOA to designate tiny bedsits as Band-A flats  in Lockdown properties they will be working in the interests of the cartel in these matters. The VOA do not re-band at the request of the owners. The latter route requires the completion of a form which is in the public domain and FOI requests to the VOA have confirmed that the completed request forms do not exist. With the destruction of a small mid-terrace family home (a scarce resource in the affected boroughs) comes a VOA windfall for cash-strapped councils in the form of New Homes Bonus. What was once one home now becomes five or six and the government’s own homebuilding figures receive a deceptive uptick. Moreover, the LA now receives a significant annual uplift in the multiplication of Council Tax for each ‘flat’. This would appear to be a considerable disincentive to dealing with such Rogue Landlords.

 

  1. Under current planning rules the cartel’s ‘flats’ would be unlawful. It is my contention that if they are permitted to masquerade as unlicensed HMOs for five years they would become de facto flats, immune from enforcement. Perhaps this is the hope of the landlords? In any event it is a powerful incentive  not to seek licensing. After all, in the unlikely event they are caught out, they can simply apply for a license.

 

  1. Indeed it is the VOA’s statistics which determine the Broad Rental Market Area (BRMA) maps of London and ultimately the amount of LHA payable within each. Consider that house price and sale data, average private market rental figures and other crucial numbers are being fed into these calculations. When the VOA is re-banding thousands of tiny Lockdown HMO units as ‘flats’ for which the highest end (and more) of the self-contained LHA is being paid by either LAs or the DWP, they are party to rent inflation and price-fixing. Furthermore, the purchase by this cartel of perhaps 500 two-bedroom homes across all boroughs of London, often for higher than asked for prices, is distorting the housing market and pricing-out first time buyers. What is clear from overlaying maps of the locations of properties purchased by the Cartel with BRMAs is just how contiguous the maps are. It is a clear that the controlling mind(s) behind the Cartel have studied the BRMA maps with the express intent of acquiring property with higher rates of LHA in order to maximise their profits from charging the self-contained rates. The consequence of this is that the tax-payer will be charged at the very top end of the LHA for the Broad Rental Market Area (BRMA) - sometimes even more - as ‘self-contained’. If Local Authorities do not have the capacity and, just as importantly, the appetite to investigate such abuses  they will continue.

 

  1. Many LAs are struggling with issues of housing and homelessness. There have been referrals from LAs to charities such as St. Mungo’s Broadway who then refer to the cartels’ lettings agents. As long as the temptation to solve pressing housing problems by colluding with Lockdown landlords exists there will be continued tensions between the competing needs of enforcement and housing. I have seen this in Hanworth where I believe that the needs of housing has trumped enforcement and lead to a culture of impunity for Lockdown Landlords.

 

  1. In 2016 a charity called Nesta, set up by the government to support public-sector innovation, began work with the GLA and half a dozen London boroughs to ‘predict which properties might be HMOs.’ Since then they claim to have developed an algorithm ‘500% better than picking properties at random’. Nesta have access to a range of datasets not available to activists and yet it would seem that they can have little or no knowledge of the scale of the Stamford Hill Cartel. One of the reasons behind this may be that some of their assumptions are misplaced. They incorrectly assume that HMOs would only involve properties with higher council tax bands as they would be larger. “The key predictive datasets include council tax, electoral registration, benefit claimants, structural data on how many storeys a property has – and complaints, including on fly tipping. 'Anything else tends to be white noise,’ … The council used eight datasets for its predictive model. Phil Canham, an insight and data scientist for the council, says that the useful ones include council tax band, as higher-banded properties were usually larger ones that could be used as HMOs” In the case of Lockdown HMO units nothing could be further from the truth. In fact it is the very division of single addresses into 5 or 6 flats which often betrays a lockdown HMO when searching VOA Council Tax bands. Cross referencing ‘Band-A’ postcodes which show 5 or 6 ‘flats’ with the Energy Performance Certificate Register confirms a Cartel Lockdown address in respect of the very small unit size - on average 12 sq m.

 

  1. EPCs are required legal documents for every property sale and rental. The Stamford Hill Cartel have fraudulently produced over 2,000. Every single Lockdown property for which EPCs have been produced takes no account of the largest energy-producing area of any residential building: the kitchen. The assessors are simply omitting them as an inconvenient obstacle to ‘self-containment’. Furthermore, there is a ‘related party’ disclosure which is being violated. There is a clear evidentiary trail between the Quidos assessors and the directors of Stamford Hill Cartel companies. Attempts to raise these serious matters with Quidos the energy assessor (another creature of the DCLG) fell on deaf ears. Ultimately I spoke at length with the director of Quidos who took an extraordinarily relaxed view about the matters I raised. Perhaps this is not surprising given the recent revelations concerning wholesale EPC fraud. Since the Cartel appear consistently to employ the same EPC assessors for their properties (in short, their close associates) I requested that the DCLG release to me the addresses of all London properties for which they had produced certificates. This was refused and is now subject to an appeal to the Office of the Information Commissioner (ICO).

 

  1. I have compiled a spreadsheet with the details of over 360 Stamford Hill Property Companies who I contend are operating a cartel of unlicensed HMOs, fixing rental prices and gouging the tax-payer whilst providing substandard accommodation and outcomes for the poorest and most vulnerable people in our society. These companies and their directors are systematically  exploiting existing laws and gaps in legislation to generate unearned wealth via LHA. All of the directors originate from the Charedi community of Stamford Hill and are connected by ties of community, business, family and religious association. That a number of these directors are also trustees of charities with connections to the Lockdown HMO businesses they operate should be of great concern. That these directors and trustees include respected and leading figures of the Charedi community who profess to religious ethics whilst exploiting the homeless for the profit of their community is shameful.

 

  1. Many of the officers of the companies in this cartel have been shared at one time or other as have the trusteeships of the associated charities. Loans and gifts have flowed between the  entities such that it is not clear where the vast sums generated are destined. For each property there is generally a ‘tax-efficient’ holding company entitled to submit abbreviated accounts. Layered above this company are management companies to whom the rents are being directly paid by either LAs or, more recently, the Department of Work and Pensions (DWP). Chief among these companies is Manlow Property Management Limited (08609660) to whom LBH has granted HMO licenses despite convictions for housing offences in Brent.

 

  1. Despite blandishments from various authorities to the contrary, criminal convictions appear to be no bar whatsoever to continuing abuse. A case in point is that of Mr Joel Zweibel who was convicted in November 2016 of a campaign of harassment and illegal eviction against a tenant. Mr Zweibel is currently the director of a company Omniville Limited (05239381) operating two Lockdown premises in Lewisham. As we have previously noted Manlow Property Management Limited seems unperturbed by their conviction in Brent. Nor does Mr. Chaim Solomon Goldberg seem unduly troubled for his company, Primegold Estates' (06634175) 2013 conviction. Of course these are just the very few who were so egregiously bad, unlucky or stupid enough to warrant prosecution.

 

  1. Various Charedi lettings agents intimately connected with the cartel have been responsible for  sourcing homeless and vulnerable tenants. Among these are Liberty Housing Group Limited  (09934893), Pointview Estates Ltd (07600151), Choicelet Ltd (10872043) and Prime London Lettings (08668358). It is no coincidence that Liberty Housing shares its address with over a dozen Lockdown companies. Mr. Moses Koppel, a director of Pointview, is also the director of at least four Lockdown holding companies. Choicelet was not registered until July 2017 but had routinely advertised Lockdown properties for the Cartel on Gumtree long before that. Prime London Lettings was dissolved in January 2017 yet continued to conduct business well into 2017. Its director, Mr. Simche Teitelbaum, previously shared another directorship with a Mr. Aron Teitelbaum. It is my contention that they are either brothers or cousins and that Mr. Aron Teitelbaum is the same individual who is responsible for the issuance of at least a dozen of the aforementioned fraudulent EPCs. This is merely one demonstration of the strong connection between all of the characters in this drama. A visual demonstration of the connections of only a small part of the cartel can be seen here.

 

  1. Having interviewed a number of Lockdown tenants I have a clear idea of the modus operandi of these lettings agents. They certainly actively seek referrals of homeless via charities and from existing (formerly homeless tenants) to whom they offer voucher incentives. However i have clear evidence that Local Authorities are referring homeless clients to charities under the Care Act 2014. Specifically, Peter Matthew, Director of Housing, wrote to me in June 2016 confirming that LBH were referring to St Mungo’s Broadway. St Mungo’s have independently confirmed this and other charities may well be following suit.

 

  1. There are serious issues to be raised surrounding these referrals. Chief among them are those prompted by the Homelessness (Suitability of Accommodation) (England) Order 2012 SI No 2601. Article 3 of this Order applies to any final accommodation offer during the relief stage, and to any accommodation secured from a private landlord to a person who has a priority need offered to end relief or prevention duties. Article 3 contains a 10-point checklist governing suitability and specifically rules out the use of unlicensed HMOs and those without valid EPCs among other stipulations. LAs and charities have clearly been acting unlawfully in making such referrals for several years. I note that a ‘on-off’ session examining Homelessness Reduction Act will be held on Monday 27th November and it will be most interesting to see if this serious matter is raised.

 

  1. The insistence on direct payments of housing benefit as a condition of tenancy is also a feature of the Stamford Hill Cartel. That vulnerable tenants are obliged under duress to sign away their right to receive direct payments of LHA cannot be right. The circumstances in which the prospective Lockdown tenants find themselves in relation to Local Authorities and the sharp practices of lettings agents such as Liberty Housing et al, raise serious issues. It should be remembered that any offer of accommodation involving an LA in these circumstances will be a first and final offer. The rejection of such an offer will provide the pretext for the LA to claim that it has ‘discharged its duty ‘ under the relevant acts. Clearly the Lockdown tenant can become trapped in expensive and cramped accommodation which they cannot escape without serious detriment to their rights or recourse to public funds.

 

  1. Since the disastrous roll-out of UC we have seen dramatic change in the administration of Housing Benefit. Lockdown Landlords, abetted by the VOA’s willingness to classify their bedsits as ‘flats’ are emboldened to advertise ‘self-contained studio flats’ and charge accordingly. They specifically target those on UC with adverts on popular classified sites such as Gumtree, routinely violating trading standards. For some time I have been collecting copies of all such advertisements which I have connected to physical addresses. These represent important corroborating evidence of the various sharp practices I have cited. Examples include the misrepresentation of the nature of the lettings, i.e. ‘self contained’, ‘fully tiled bathroom and kitchen’; the routine targeting of a specific kind of tenant, i.e. ‘you must be over 35 and eligible for Universal Credit’; zero or negligible cost, i.e. ‘full amount will be covered by Housing Benefit’; and the helpful ‘our experienced team will assist you with your housing benefit claim’. I have corroborated anecdotal evidence from tenants in separate properties as to the nature of this ‘assistance’. It involves a visit to a Lockdown HQ in North London, ***********               ** where an ‘interview’ takes place and the prospective tenant is asked, at some point, to sign a signature on a tablet device. It is with this signature that all documentation relating to the tenancy is then produced as if it had been read and signed in the usual way.

 

  1. In October of 2017 I visited various Lockdown addresses in Lewisham and met with tenants to understand their plight and confirm certain facts about the properties. I had been providing detailed research concerning Lockdown to the BBC’s Inside Out for some weeks and was now able to offer them access to two properties, one in Hanworth and the other in Lewisham. In early November 2017, a week before the broadcast of Inside Out, I met with Cllr. Damien Egan, Cabinet Member for Housing for LBC and made my research available to him. A week later I met with Bobby Dean, Liberal Democrats’ spokesperson for Lewisham Deptford, to share the same concerns. I hoped that, if given the opportunity, LBC would respond in a more open and courageous fashion than did my own Local Authority, LBH. Inside Out was broadcast on 7th November 2017 and I understand that this Committee is in possession of a copy of the programme.

 

 

  1. The will and resource to enforce on existing regulations is key to intervention in the private rented sector. The silo mentalities of Council departments undergoing budgetary cuts of 12% the joined up thinking and information-sharing which might enable more effective enforcement. Additionally, the sharing of information between councils in respect of Lockdown Landlords, other ‘Rogue Landlords’ or those with criminal convictions for housing offences is woefully overdue. Whatever current processes are in place are not nearly sufficient, as I have demonstrated.

 

  1. Licensing regulations for HMOs are poorly enforced and the ‘forgiveness’ of gross breaches seems commonplace. In the case of the Lockdown Landlords we have routinely seen shared kitchens of criminally small dimensions - far below the minimum requirements - with insufficient space for appliances and food storage. Hallways are too narrow to comply with fire regulations and domestic supplies have been dangerously split between 5 or 6 units, risking overload. Even though I have forced LBH’s hand on some HMOs via improvement notices, many of the breaches remain after they have granted licenses.

 

  1. Serious criminality has increased in Hanworth as a direct result of the dozen Lockdown HMOs in the Ward. Among other offences have seen a marijuana cultivation operation uncovered at *********     ****; arrests for Class A drug offences, threatening behaviour and possession of knives at *************; constant police visits to and from *************; and accounts of a ‘pop-up brothel’ at *************.

 

  1. Even more disturbing is the as yet unexplained death of a vulnerable woman in the top floor ‘flat’ at ************* whose body lay undiscovered for some time. Tenants and neighbours raised suspicions surrounding the death in February 2017. I have three times written to the Coroner in attempt to register these concerns but without any response.

 

  1. Complaint mechanisms are wholly ineffective as they relate to Lockdown Landlords. I have seen a tenant forced from his ‘flat’ days before Xmas by raw effluent flowing throughout the ground floor. Published phone numbers for repairs either do not function, are never answered or are rudely logged with no action taken. I have spoken to tenants where workmen, if they show up at all, are unannounced. Landlords routinely gain access to tenants ‘flats’ with their spare keys. The entire attitude where formerly homeless tenants of Lockdown HMOs are concerned appears to be one where the tenant is ’lucky to have anything at all and should be grateful accordingly.’

 

  1. Overflowing rubbish has been a constant theme of Lockdown properties in Hanworth where neither the LA nor the Cartel provide bins of sufficient capacity to cope with 5/6 separate households. Recycling facilities are similarly affected and remain unused owing to the lack of coordination. The effect of garbage strewn across the gardens degrades the well-being and cohesion of the local community. I have written to HBC innumerable times over the past year to explain their obligations regarding enforcement and little changes. Their reduction of collections to fortnightly exacerbates the problem.

 

  1. I have repeatedly raised the issue of liability for Council Tax (CT) with LBH who are pursuing the Lockdown tenants for non-payment. Since it is the LA which triggers the re-banding of each unit by the VOA it is perverse that they do not adhere to the well-established hierarchy of liability wherein the owners of HMOs are liable for CT. They appear to rely on the VOA banding of a property as a 'flat' within a building as their continued justification. I am beginning to suspect they prefer to chase tenants for CT, driving them further into debt, rather than take on the cartel who are soaking up the LHA. This is particularly vicious considering that even on those few occasions where Council has belatedly required a cartel company to obtain a HMO license they persist in their pursuit the tenants. It is the role of the VOA to determine whether a property is rateable; it is for the LA to correctly assign liability, however inconvenient LBH may find that fact.

 

  1. I have found it almost impossible to intervene on the part of a vulnerable tenant in these circumstances. It is not possible to make a complaint to the Housing Ombudsman unless one is either a tenant or a landlord. There is nowhere to go with a complaint on the part of a tenant in a Lockdown HMO. I was eventually able to act as an advocate for a vulnerable adult in Hanworth in a complaint to the HCA where GPPML were involved in the Lockdown property. As has been noted, this complaint is still unresolved and an investigation is still ongoing months later.

 

  1. In holding my Local Authority to account for their pusillanimous response to the Cartel’s expansion into Hanworth I appear to have become an annoyance to them. Since they could not adequately answer the questions I was raising, they decided to restrict my communications under a misguided ‘vexatious and persistent complainant’ policy. That they acted unfairly and unreasonably and did not follow their own procedures when so doing has lead to a nine month’s long investigation by the Local Government Ombudsman (LGO). The investigator has already issued a draft verdict in my favour but LBH prefers prevarication. It is my contention that Hounslow spent more time, energy and funds obstructing my efforts than seeking to assist residents in their struggle against the Lockdown Cartel.

 

 

 

APPENDIX

 

Lockdown: The nexus between Housing Benefit and Charedi charitable trusts.

 

  1. Cui bono? Where do these tens of millions of pounds of tax-payer funded Housing Benefit go each year? Certainly some of the money seems to be directed into many of the innumerable Charedi charities which support the orthodox community's institutions in Stamford Hill. There is also evidence that large sums flow overseas to other charities, notably in Israel. A charity, Biala Synagogue Trust (1071797) owns a Lockdown HMO at **************. The Trust is currently under investigation by HMRC in respect of the sum of £230,000 they saw fit to make to two unnamed Israeli charities in 2011.

 

  1. An typical example of the kind of blurring of finances between these charities and the Lockdown cartel can be seen in the July 2016 financials of Starlow Charities (1081386). Here substantial sums are owed by a Lockdown company, Timesquare Properties Ltd (06707404). The financial statement is clear that: “These loans were made to companies connected to the trustees or their families and all loans are secured against properties of the various companies.” Timesquare is currently directed by Israeli national Mr. Yoel Yehoshua Heilbrun although the offices of this company have rotated between the Low family and the Mr. Heilbrun during the company's history. The company has disbursed over £2 million pounds to more than a dozen other Charedi charities since 2015.

 

  1. On 02/11/17 The Guardian published an article about Hackney Council designing property for the needs of the Charedim in Stamford Hill. In it Rabbi Abraham Pinter is quoted as a 'spokesperson for the Charedi Community in Stamford Hill'. He is also a director of a number of companies registered with Companies House. One such company is The Union of Orthodox Hebrew Congregations (08341721) (UOHC) of whose charitable arm (249892) Rabbi Pinter is also a trustee. A fellow trustee, Mr. H. Konig, is a director of a company called Woodbury Down Ltd (08439430) which owns a Lockdown HMO at ***************************** The property was re-banded by the VOA on or about 23 May 2016. It has no mandatory HMO license as is required by the Borough of Greenwich nor does it have any history of planning permission to account for its conversion to flats.

 

  1. Some of the same directors of The UOHC are officers of another company called The Interlink Foundation (03852756) which also has a charitable arm (107931). Its officers include further directors of unlicensed, unplanned Lockdown HMOs throughout the boroughs of London. These include Mr. Jacob Moshe Grosskopf who has two 6 ‘flat’ properties in Bexley and Havering: **************** and ********************* through Uptown Development Ltd (09891001). Abraham Schecter owns another unlicensed 6 ‘flat’ Lockdown HMO at ************************* through his company Star of London Ltd (05080033). As to the charitable arm of The Interlink Foundation (1079311) we have Mr. Grosskopf and Mr. Schecter as trustees but we also have a Mr Y. Y. Herzka. I contend that this is the self same Yidele Herzka who is responsible for producing dozens of fraudulent EPCs for the Cartel.

 

  1. In February 2010 the Interlink Foundation produced a 33 page document as part of a planning appeal submitted by John Stebbing Architects. Essentially it is an exercise in special pleading on behalf of leading members of the Charedi community in Stamford Hill for consideration by Hackney Council with respect to planning law. Two of the directors of Interlink, Jacob  Moshe Grosskopf and Abraham Schecter are directors of Lockdown cartel property companies. One of the signatories of Appendix E, Rabbi Jonah Perelman, owns a Lockdown HMO through his company Newbay Properties Limited (09950551) in Hounslow managed by Manlow Property Management Limited (08609660) and licensed as a HMO by Hounslow.

 

  1. The Interlink document sets out the many reasons why the Charedi Community require special consideration from the LA - predominantly the ‘spatial’ needs of the title: larger kitchens for Kosher religious observances, larger families, space for prayer rooms and associated facilities within homes, provision for succahs and ritual baths. Of the many requirements from the document one will serve to illustrative the general theme: “Orthodox Jews generally need larger homes with more bedrooms and larger living space than a smaller family would need. At least one bedroom should be at least 14 square metres and the hallway should be able to accommodate prams/buggies.” It is beyond hypocrisy that those pleading for special consideration in Hackney - particularly that of a ‘spatial’ nature - should be instrumental in the profitable destruction of small family homes outside of their community for their own enrichment - especially so given the size of Lockdown units and the associated denial of communal space within them.

 

 

 

November 2017

[1] Energy Performance Certificates (EPCs) provide solid evidence of floorspace, perhaps the best indication where 5/6 ‘flats’ exist at a single address. https://epc.opendatacommunities.org This is explained in detail later.

[2] s.61 and s.72 of the Housing Act 2004