Greg Freeman - NSW Fair Trading · 1 From: Sent: To: Subject: Attachments: Greg Freeman Wednesday, 12 August 2015 6:17 PM Policy Submission by PICA Group to NSW Fair Trading in regards

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From:

Sent:

To:

Subject:

Attachments:

Greg Freeman

Wednesday, 12 August 2015 6:17 PM

Policy

Submission by PICA Group to NSW Fair Trading in regards to Strata

Schemes Management Bill Draft July 2015

PICA Submission to NSW Fair Trading - SSM Bill - 12 August 2015.pdf

Attention NSW Fair Trading

[email protected]

Dear Sir / Madam,

Prudential Investment Company of Australia Pty Ltd. (PICA Group) comprises 6 major strata management companies

in NSW which collectively manage 128,000 Lots in 7100 strata schemes and associations, which represents

approximately 10% of the number of existing schemes in NSW.

We have attached for your consideration, the PICA Group’s submission and comments on the recently released Bill for

a new Strata Schemes Management Act.

Please do not hesitate to contact me if you require clarification of any of the material / comments in our submission.

Regards

Greg Freeman GM Strata Excellence and Regulatory

Please consider the environment before printing this e-mail.

PICA’s Legislative Submission to NSW Fair Trading 12th August 2015

Level 27, 66-68 Goulburn Street, Sydney NSW 2000 P (02) 8216 0397

E [email protected] ABN 84 004 266 817

www.picaust.com.au 1

Strata Schemes Management Bill Draft July 2015: Submission by PICA

Attention NSW Fair Trading

[email protected]

Dear Sir/Madam,

The Department of Fair Trading has released the latest Bill for a new Strata Schemes Management Act and

invited public comment and submissions by 12 August 2015.

This submission is from Prudential Investment Company of Australia Pty Ltd. (PICA Group), which is a national

property and financial services company, established over 50 years ago with a core focus on strata management

where it is the market leader.

The PICA Group of companies comprise 6 major strata management companies in NSW which collectively

manage 128,000 Lots in 7100 strata schemes and associations, which represents approximately 10% of the

number of existing schemes in NSW:

BCS Strata Management Pty Limited;

Dynamic Property Services Pty Limited

Robinson Strata Management Pty Limited;

Mason & Brophy Strata Management Pty Limited

New South Wales Strata Management Pty Limited

GK Strata Management Pty Limited

We understand and commend the NSW Government‟s intention to update the strata legislation into the 21st

Century with an overriding philosophy to cut red tape; increase clarity; reduce unnecessary costs in administering

an owners corporations activities and responsibilities; and, uphold the status of the Owners Corporation and its

Strata Committee.

Aim of this submission by the PICA Group

There are many excellent changes and improvements in the new Bill; however we wish to highlight below a few

significant unforeseen consequences that we believe will prove to be contrary to the overriding philosophy of

legislative reform, noted above and will result in increased costs and red tape for owners corporations.

Unforeseen Financial Consequences Summary

In this submission, we have identified a number of impractical consequences of the new Bill listed in the table

format below. In summary we have highlighted below the financial consequences of some provisions in the new

Bill that have a financial impost that should be reconsidered:



E [email protected] ABN 84 004 266 817 www.picaust.com.au 2

Distribution of copies of general meeting notices to tenants:- $15 per lot per annum (assume one meeting

per annum);

Distribution of copies of Meeting notices to First mortgagees and covenant chargees on strata roll (Priority

Vote): -$30 per lot per annum ;

Additional strata committee meeting to extend an expired Agency Agreement: -$320 (6 lot scheme);

Shorter First AGM appointments will add a 30% premium i.e. increase $600 per year to agreed services fees

(based upon an assumed previous $2,000 agreed services fee);

Costs of distributing applications to NCAT Applications:- $100 to $30,000 depending on the size of the

schemes and volume pages in the Application; and

Additional costs to small (non large) schemes in new Bill, estimated cost for 6 Lot schemes per committee

meeting $10 per lot per annum;

1. New provision about the expiry of Strata Management Agency Agreement [Section 50 (4)]

Issue / unforeseen consequence:

The new Bill allows, following the expiry of the contractual term of a strata agency agreement, that a Strata

Committee may extend the term for successive periods of one month (only) and also require 7 days prior notice.

In our view this is impractical and will incur additional and unnecessary costs for an owners corporation to accommodate the new agreement extension requirements.

Financial / Opportunity Cost:

Non-large schemes Unnecessary cost of convening, running meetings of the Strata Committee. Note the minutes of Strata

Committee meetings of small schemes will now have to be sent to all owners and other parties (tenants) listed

on the strata roll. Previously minutes were sent to committee members and placed upon the notice board only. The cost to hold a Strata Committee meeting and distribute both the notice and minutes of meeting to all

owners and tenants inclusive of photocopying, postage and the strata manager‟s time to convene the meeting could be as much as $320 per meeting for a 6 lot strata scheme with say 3 tenants. #1

Extra administration and delays: with the new requirement to distribute notice and minutes of Strata Committee meetings to all owners and tenants an additional 4 business days notice period will need to be allowed for

postage requirements.

All Schemes Given the difficulties with Strata Committees holding meetings we believe the committee will need to arrange

more than one extension.

It is highly unlikely for all schemes will be able to administratively organise to hold a Strata Committee meeting

to extend an agreement, and then convene a general meeting (7 clear days, which in effect requires a

1 If all lot owners and tenants comply with the law and register the names of tenants on the strata roll, the additional cost to the

owners corporation in sending material to tenants will add a loading of at least 50% to the cost (“Residential Strata in NSW” – City

Futures, note that in 2011 “Just over half [52.8%] of the residential strata lots in NSW were investor-owned”). Estimated

distribution costs $30- 40 per lot per annum.




distribution of the meeting notice 14 days prior to the general meeting) to approve a new a strata management agreement within one month.

In the event that the Owners Corporation wishes to go to tender for strata management services, one month

would be insufficient time to do so and hold a general meeting to approve a new agreement.

Recommended change: Option 1: Allow the Strata Committee to extend the expired Agreement term until the next general meeting of

the Owners Corporation.; OR

Option 2: Allow the Strata Committee to extend the expired Agreement term for a 3-month period (in line with

Property, Stock and Business Agents Act 2002 – PSBA Act). We suggest a maximum of 2 extensions.

Either option will reduce the number of meetings required and give more time for the administrative steps to

approve a new agreement. Option 1 will also keep the strata legislation in line with the PSBA Act which also allows expired agreements to be terminated with 3 months notice.

2. Reporting Commissions received by Strata Manager [Schedule 1 Clause 9(g) also Section 60]


A conflict exists between Section 60 and Schedule 1 Clause 9(g) and commissions are already

dealt with in other legislation. Section 60 requires the managing agent to provide a report at the AGM on commissions that have been paid and are likely to be paid in the upcoming 12 months.

Schedule 1 Clause 9(g): requires a form of motion at an AGM is to consider a report by the agent on

commissions. Under common law, such a motion should be ruled out of order, as it is incapable of resolution.

Putting such a motion invites comments and potentially opens the approved existing agency agreement for re-negotiation – making contracts yearly rather than for a maximum of 3 years.

Transparency could be achieved by a compulsory disclosure and notation on the AGM agenda and in the strata

agency agreement.

The Bill‟s proposed inclusion of such an AGM motion, seems to unfairly promote and singled out strata managers

as being untrustworthy, unprofessional and acting only in self-interest. Other service providers that assist Owners Corporations, have no such restrictions other than those contained in the general law which applies

equally to strata managers. The proposed change does little to enhance the public image of a group (strata

managers) that is vital to the good governance of strata in NSW.

Financial Cost /other consequence:

Additional administration This increased regulation and regime of legislative surveillance around reporting

commissions will ultimately be passed onto to the consumer as additional management fees /expense. The PSBA legislation appropriately deals with agents – extra regulation is neither desirable nor required.

The „tone‟ of this clause, when taken with other provisions in this Bill, belies a promotion of a poor image of the

strata management industry that is not deserved on the evidence on show in practice and in judicial

proceedings.




Recommended change:

Schedule 1 Clause 9(g) should be deleted from the Bill, keep Section 60 with the additional requirement in Schedule 1 requiring a further disclosure of commissions be placed in the statutory required notes for the AGM

agenda.

Any changes to Reporting of Commissions should be placed in the Property, Stock and Business Agents Act 2002 unless it is the intention to single-out strata managers for less favourable treatment to other forms of agents.

3. Acceptance of Gifts [Section 57 (2-3)]


The proposed provisions are unworkable and inequitable. We agree with the sentiment of eliminating any undislclosed financial benefits to strata managers.

The new Bill‟s definition and approach to gifts and benefits appears to be derived from the requirements for employees of the public service. We understand from a recent government briefing, that the regulations will

prescribe that the maximum value that can be accepted by a managing agent as a gift or benefit will be $50 – the same as that prescribed for public servants.

It is our view that strata management is a private enterprise business in which some activities could be construed as „gifts‟ and „benefits‟, given its wide definition. These activities arise in dealing with customers and

service relationships that are of a completely different character to that of the public service and provide beneficial consequence that flows onto the strata manager‟s clients the Owners Corporation.

Examples:

1. The current broad definition would eliminate situations where legal companies providing seminars and

training to strata managers on new legislation, legal cases of note and the complex elements of strata management such as dealing with disputes and building defects These seminars and training are

provided free of charge to strata companies and count for CPD points. 2. The strata insurance industry provide training, currently free of charge, to ensure strata managers are

well equipped and knowledgeable as to insurance policies and the constraints imposed upon them in

dealing with their Owners Corporations in matters of insurance.

Networking, which is a significant issue for management in private enterprise, is similarly adversely captured by this draft provision and will have a detrimental affect on the potential advantages to the Owners Corporations

and to effective strata management.


The unforeseen consequence is this provision in its current form will lead to an administrative nightmare to

regulate and comply and will capture legitimate and beneficial activities.

Corporate sponsorship is also important for some events to occur. For example, recently the Minister for

Planning launched „the vision‟ of where government planning was headed in the coming years. This event was an important industry-wide update, which was promoted on the basis of corporations booking tables for their

staff and invited guests. Such events may not be viable without corporate sponsorship and for those sponsors

realising a benefit of being able to invite clients.




Recommended change:

1. Remove Section 57 (2-3). OR

2. Strata management companies maintain its own internal register of gifts and benefits which could be open for examination and inspection by its client.

4. New provision about Contributions (levies) not being due and payable for at least 30 days after the date of (contribution) notice [Section 83(3)]


Inability of an owner corporation to raise levies to pay for an urgent specific expense within 7 weeks.

Timing: in a best case scenario, it takes 2 weeks to convene a general meeting required to a raise additional monies, allow a further 5 business days to prepare minutes and issue the levy contribution notices for the

additional funds required and then allow a further 30 days for the due payment due date, means the owners

corporation will not be able to raise urgently required funds with 7 weeks.

Examples of urgent fund required for:

Payment for insurance in circumstances where the normal budget / owners corporation funds have been

spent on urgent unexpected items or where the owners corporation under budgeted; Meeting Council orders for fire compliance and alike:

Items of public health and safety; defence of a legal action;

legal costs to prepare for and/or attend mediation; and, any other emergency transaction where the owners corporation has insufficient funds.

This new provision (i.e., not in previous draft of the Bill) is similar to the Supreme Court intervention to resolve the problem that was posed with overcoming difficulties of obtaining an owners corporation approval for legal

action / services under the current section 80D of the Act. The Section 83(3) requirements will constrain the Owners Corporation in raising monies which may pose a

similar obstacle for an Owners Corporation to defend itself.


Owners Corporations may find themselves unable to meet specific immediate expenses associated with complying with Council orders, a timely legal defence of itself or commence legal proceedings to protect the

interests of owners. Recommended change:

Section 83 (3) should be deleted from the Bill.

5. Period of appointment of strata manager at first AGM [Section 50 (1a)]


The result is likely to be higher fees paid by Owner‟s Corporation for one year agreements at First AGM.

The period for appointment of a strata manager at the first AGM has been restricted to a maximum of 12




months which is inconsistent with the Bill‟s maximum appointment term for a building manager (a maximum period of 10 years) and is an unnecessary intervention into normal free market transactions.

If the intention is to curb developers from appointing their own strata company, then such a restriction on a

maximum 12 month appointment at the first AGM should only be applied solely in regards to developers.


1. Longer contracts allow the owners corporation to negotiate better terms of engagement. Fee charges

for a one year agreement at the first AGM will most likely be 30% higher in the first year.

(Considerable cost and time is spent by a strata manager in the first year in establishing a strata scheme 2 which a strata agents will no longer be able amortise over say a 3 year period. Given the

recent changes to the Home Building legislation and the additional defect provisions contained in this

draft Bill, the first twelve months is likely to be considerably more demanding period for strata

managers. A discontinuity of / disruption to the management of the defects process may arise from 12 month appointment.

2. Given this Bill grants an Owners Corporation the ability to change its AGM date, the expiry date of the

Agreement may become out of synchronization with the AGM and thus require the Owners Corporation

to convene an extra general meeting (i.e. an extraordinary general meeting) to approve a new strata management agreement.

Likely cost to small schemes: $300-500 (including Strata Manager‟s time, photocopying, stationary and

postage) to convene a meeting other than the AGM to extend an existing agreement or enter into a new

agreement.

Likely cost to large schemes: $1,000-2,500 (including Strata Manager‟s time, photocopying, stationary and postage) to convene a meeting other than the AGM to extend an existing agreement or enter into a

new agreement. Recommended change:

(1) The Owners Corporation should have the choice of negotiating an agreement for a term of up to 3

years. Change the maximum strata management agreement term at the first AGM to 3 years, the same

as the maximum term permitted for approval at general meetings other than the First AGM; and

(2) Keep the maximum 12 month appointment at the first AGM where developers appoint their own strata company only.

6. Service / Copies of Notices to Priority Votes (First mortgagees and covenant chargees on strata

roll [Schedule 1 Clause 7(3), Clause 24and various]


Notice of meetings where a priority vote is considered, must be sent to first mortgagees and covenant charges.

(A Priority vote is defined very widely in Schedule 1, Clause 24 as a motion regarding insurance, budgeting

levies and special and unanimous resolution). Whilst this is a carry-over provision from the present legislation, it

2 With the recent changes to the Home Building legislation and the additional defect provisions within this draft Act, the first twelve months is

likely to be a more demanding period for a strata manager. Inconsistency in the management of the defects process may arise from a short period of appointment and is further reason not to truncate the period of appointment to 12 months.




is a requirement that is an unnecessary impost upon a strata scheme. It is our experience that financial institutions ask why are such notices are being sent and request that they no longer be sent as they are deemed

unnecessary.

This is both impractical and if administered fully incurs additional and unnecessary cost for an owners

corporation.


Although the provision is in the current legislation, in our experience, it is seldom complied with by owners

corporations. If enforced, this requirement will be an added cost for a „service‟ not sought by financial institutions and covenant chargees estimated at $30 per lot per annum. Recommended change:

1. Amend Schedule1 Clause 7(3), to limit the circumstances where notice of meeting are required to be sent to First mortgagees and covenant charges; and / or

2. Amend Schedule1 Clause 24 to limit the definition of a priority vote such as where a scheme is to be

dissolved or the subject of renewal.

7. Service of Notices to tenants [Section 14 (3) (b) and Schedule 1 Clause 11]


Increased cost to an owner corporation in distribution of notices of general meetings.

Tenants registered on the strata roll must receive copies of notices of the first AGM, under Section 14 (3)(b),

and other general meetings (AGMs and EGMs) pursuant to Schedule 1 Clause 11.


The costs associated with the conduct of meetings will increase significantly increased – the degree to which will depend upon owners with tenants complying with requirements under this proposed legislation, and that of the

residential tenancy legislation to notify the Owners Corporation of their lease.

Estimated cost of distributing notices of general meetings assuming 1 meeting per annum - $15 per lot per

annum.

This provision to be contrary to good governance as it encourages an Owners Corporation not to seek / promote the registration of tenants on the strata roll as it will simultaneously increase the Owners Corporation‟s costs

associated with sending copies of notices. Recommended change:

1. Notices to tenants should limited to those tenants who make a request it in writing to do so and delivery

is in electronic form; and

2. notification of all Notices of meetings should, can be provided by requiring all owners corporations to

place copies on the notice board 3 days prior to the meeting; and

3. Notices of meetings could be made available to tenants on a website maintained by the strata scheme as a „bulletin board‟ or on a website for such notices maintained by the strata company.




8. Inconsistency in service of minutes of strata committee meetings and notices [Schedule 2 Clause 4, 5 and 17 – note also Schedule 1 Clause 7]


There are a number of costly, inconsistent and inequitable prescribed forms of communication with those on the strata roll (See also item 7 below).

a) Inconsistency in service of minutes of Strata Committee meetings between large and small schemes:

Small schemes: copy to each owner and committee member Large schemes: copy to committee member but owners must make a written request for a copy within 7 days of each meeting

b) For general meetings, notices of meeting have to be given to “each owner” (Sch 1, cls 7) and to “each

tenant” on the strata roll (Sch 1, cls 11). Minutes of general meetings are to be distributed through the same inconsistent requirement provision as minutes of Strata Committee meetings.

The new Bill makes no provision (as is the case under the current legislation) for notices and minutes to be

placed on the notice board for any meetings. This is inconsistent with the requirement to erect and maintain a notice board that is required of most schemes under the existing standard by-law 18.


Additional cost for small schemes to deliver notices and minutes of Strata committee meeting to all owners

(currently no such requirement). Estimated cost for 6 Lot schemes per committee meeting $10 per lot per

annum; Inequitable to large scheme owners; and

Administrative nightmare for Owners Corporations and strata managers to keep track of owner requesting

copies of large scheme meeting within 7 days

Recommended change:

Reinstate the notice board as being an alternative means of notification of meeting notices and minutes. Expand the provision to also explicitly allow for the alternative the communication the existence of such notices by email

which can accessed / made available on a website maintained by the strata scheme as a „bulletin board‟ or on a website for such notices maintained by the strata company.

9. Distribution of NCAT application for orders [Sections 226 and 239] to all owners and tenants


Inconsistency and a significant cost to Owners Corporations.

Section 226 of the draft Bill requires that copies of NCAT applications be sent to all on the strata roll – which,

will include tenants and owners. On the other hand, the Notice of Orders made only have to be displayed on the

notice board provided the scheme is required to maintain a notice board (Notice board is required under By-law 18 in Schedule 1 of the current Act).

The financial impost upon strata schemes is significant and hard to justify, refer to the example below.





The costs associated with sending copies of NCAT applications to all on the strata roll (all owners and tenants) is illustrated by way of the following example:

A lengthy application (over 50 pages) by a lot owner in a 155-lot scheme was required by the CTTT(NCAT) to be sent to those on the strata roll under the current legislation. The strata manager

initially sent the first six pages only to all those on the strata roll and not all the attachments. The attachments were made accessible through the caretaker if an owner/occupier wished to view them.

The CTTT wrote to the strata manager and declared this was inadequate and did not comply with the legislation, ordering that the attachments be sent to all on the strata roll. The costs to the scheme for

this mail-out, was $17,000 (see Nunes v SP 13672 – SCS 09/44262). The case was dismissed and a

request for re-imbursement for mail-out costs was dismissed.

The additional requirement for tenants who are added to the strata roll, in the case above would have added a further $8,000 to the bill to the strata scheme assuming 50% of tenants on the strata roll.

Recommended change:

Section 226 should be amended such that applications to NCAT are required to be placed on the strata scheme‟s notice board and / or be available on a website maintained by the strata scheme as a „bulletin board‟ or on a

website for such notices maintained by the strata management company.

10. Plethora of Different By laws – all schemes should be prescribed to have the one set of

standard by-laws adopted by this bill / legislation to apply for all schemes retrospectively[Section 134]


Confusion and lack of clarity over which set of by laws apply to each strata scheme.

Section 134 of the Bill stipulates that the existing „standard‟ by-laws were adopted at the time of registration of

each scheme will remain in place. This is a recipe for confusion for owners and managing agents alike. Unfortunately there are currently many different standard sets of by laws adopted by legislation over the last 50

years that is extremely difficult to accurately establish which set of by laws apply to each scheme.

In addition, by allowing the existing “set of by laws” of each strata schemes to remain in place will lead to

unnecessary costs to owners corporations when those existing standard by-laws are contradicted by changes to the Act (or other Acts) or judicial interpretation that renders them invalid or of restricted application.

Government is presently inhibited in amending by-laws, and has to resort to amending the Act to appropriately respond to changes in community attitudes and expectations of standards of behaviour and other compliance

issues – the attitudes towards smoking is one such example. Financial Cost /other consequence:

Confusion and lack of clarity. This is because a variety of sets of standard by-laws exist, that are often similar in

content but are alternatively numbered – causing issues with serving notices to comply and alike. This will an unnecessary administrative impost and form of red-tape.

Recommended change:




There be one common set of by-laws (the “standard set”) that should apply to all strata‟s in NSW, to which a

scheme may retain or add other “special” by-laws. A standard set of by-laws that is retrospectively applicable to all existing strata schemes will provide clarity and may be updated by government from time to time will

minimise confusion about which set of by laws apply provide government with the flexibility to respond to future

changes in community attitudes.

Whilst a “Review” of the current by-laws is required to be undertaken within 12 months under the Bill pursuant to Schedule 3 Clause 4, in itself will probably prove to be ineffective and too hard for most owners corporations.

However with a new prescribed set of standard by laws the review would allow the opportunity of the Owners Corporation to identify existing additional /special by-laws that are in addition to the statutory standard set, that

will need to be registered as part of the revised complete set of by-laws for the scheme.

11. Lot owner to recover damages against owners corporation for breach of statutory duty or any loss incurred [Section 106 (5)] Issue / unforeseen consequence:

This provision is contrary to recent Supreme Court and Court of Appeal decisions that an owners corporations‟

failure to maintain the property does not give rise for an action for damages as there are other remedies to deal

with such a failure including obtaining orders from the Tribunal for the Owners Corporation to repair common property. Section 106 (5)] is so broad that it may increase litigation and other dysfunctional outcomes

for Owners Corporations.

Example: Matters relating to the management of building defects, under the new Bill may result in individual

owners seeking unnecessary orders to have their defects dealt with before those of other owners (i.e. the collective action by the owners corporation.

In the previous draft of the Bill, section 230 (4) made a somewhat similar action for compensation possible, but

it was subject to the Tribunal being satisfied that the Owners Corporation was aware of the need for repair and repair was not made within a reasonable time.

An order for damages should not be provided for, as has been observed by the Courts, the Tribunal can make other effective orders for remedy.


1. The proposed provision will lead to individual owners making unnecessary and frivolous applications to the Tribunal and undermining the powers of the Owners Corporation to appropriately manage repairs

and maintenance to the common property in a timely and cost effective manner.

2. The section will be in conflict with other sections of the Act and also any insurance-related action may

be compromised or otherwise detrimentally affected.

3. Inconsistency between the inter-relationships of some of the new sections in this Bill. Under the proposed section 106 (1) and (2) the Owners Corporation is to maintain the common property, but if

the Common Property Memorandum is adopted (s. 107) the responsibility for repair and maintenance

can be transferred to the owner of the lot. Such a transfer would be in direct conflict with the intentions of Insured “building” property under section 161 (3) and (4). Section 106 raises the additional potential

for the Owners Corporation to resolve not to repair and maintain certain parts of the common property or in the alternative to defer compliance to repair and maintain the common property. Thus, the ability

of a lot owner to exercise a „right‟ to recover damages may be at odds with the rights provided to the

Owners Corporation not to repair or to defer repair.

Recommended change:



E [email protected] ABN 84 004 266 817

www.picaust.com.au 11

1. Section 106 (5) should be deleted from the Bill.

2. Arising from the inter-relationship of the new section of the Bill discussed above, it is suggested thatsection 171 would need to be amended to match the Owners Corporation‟s rights under section 106 (4)

to allow insurance related claims to be subrogated on the Owners Corporation‟s behalf.

12. Obtaining Owners Corporation Consent to Development Applications [Section 228 (6)]


Contrary to existing Supreme Court decisions. The Supreme Court has upheld the Owners Corporation‟s right not to affix a seal to a Development Application

(DA) from a lot owner and, thus, not give consent for a Council to consider a DA from a lot owner. The draft Bill

contains the new provision that undermines the Supreme Court rulings and undermines the Owners‟ Corporation determining how common property should be developed.

Currently only a simple majority vote of the Owners Corporation at a meeting is required to approve or not

approve a Development Application matter.

The new Bill‟s provision effectively provides one lot owner with a „veto‟ power over the collective wishes of the

owners in a strata scheme.


The proposed change will be divisive and undermines the decision making of strata schemes by the majority of

owners. Adverse Tribunal decisions will also lead to significant costs for Owners Corporations in appeals to the Supreme Court.

In addition, giving power to the Tribunal to decide building development matters appears in conflict with the

specialist jurisdiction of the Land and Environment Court which is charged with the responsibility for such

matters and contains the relevant expertise.

Recommended change:

Remove this provision and allow the status quo to remain.

Yours Sincerely,

Prudential Investment Company of Australia Pty Ltd

Greg Freeman

General Manager

Strata Excellence and Regulatory

Documents

Greg Freeman - NSW Fair Trading · 1 From: Sent: To: Subject: Attachments: Greg Freeman Wednesday, 12 August 2015 6:17 PM Policy Submission by PICA Group to NSW Fair Trading in regards