SUBMISSION ON THE PROPOSED AMENDMENTS TO THE UNIT TITLES ACT 2010

28 March 2017 Unit Titles Act Review Construction and Housing Markets, BRM Ministry of Business Innovation and Employment PO Box 1473 Wellington 6140 By email: UTAreview2016@mbie.govt.nz SUBMISSION ON THE PROPOSED AMENDMENTS TO THE UNIT TITLES ACT 2010 1. INTRODUCTION 1.1 Property Council New Zealand ( Property Council ) is a member-led, not-for-profit organisation that represents the country s commercial, industrial and retail property owners, managers, investors, and advisors. Our primary goal is the creation and retention of well designed, functional and sustainably built environments that contribute to New Zealand s overall prosperity. 1.2 Property Council supports the formulation and implementation of a statutory and regulatory framework that enhances, rather than inhibits economic growth and development. To achieve these goals, our advocacy and research focuses on urban strategy, infrastructure, regulation and compliance, legislation and capital markets. 1.3 Over the years, Property Council has built and maintained a good rapport with central and local government agencies and is often relied upon for advice, comments and feedback on matters of local, regional and national importance. Our members drive economic and social growth; they are the infrastructure that houses the business, residential and commercial property sectors. 1.4 Property Council supports a review of the current Unit Titles Act 2010 ( Act ) and the wider unit titles regulatory regime. The current building and housing pressures in New Zealand make a review of the Act necessary. 2. GENERAL SUBMISSION ON REFORM PROPOSALS 2.1 Property Council generally supports the proposals set out by the Ministry of Business, Innovation and Employment ( MBIE ) for reform of the unit titles regulatory regime. We recognise there is a need for greater levels of transparency and certainty in the unit titles regulatory regime. It is important that prospective purchasers of unit titles are provided with as much relevant information as possible prior to entering into a sale and purchase agreement. 2.2 The governance and management of unit titles must be transparent, fair and certain. It is also important to ensure that bodies corporate remain self-governing entities within a broad but non-

restrictive regulatory framework. All unit titles complexes face their own unique issues. An overly prescriptive regulatory regime will undermine the necessary self-governing element of unit titles regime. 3. IMPROVING THE DISCLOSURE REGIME 3.1 Property Council generally supports a regulatory regime that ensures unit title purchasers are provided with as much relevant information as possible to enable the purchaser to make a full and informed decision when purchasing a property subject to a unit title. We recognise there are currently issues with what information purchasers are receiving and when they are receiving that information. We therefore support an up-front approach to disclosure of information. 3.2 However, an up-front Pre-purchase Disclosure Statement ( PDS ) alone cannot be relied on as the sole source of pre-purchase information. It is important that a PDS is supported by comprehensive due diligence on the part of a purchaser. 3.3 One issue that Property Council members come across in practice is that purchasers often have a lack of understanding as to the ongoing costs associated with the maintenance and upkeep of a unit title complex. Often, maintenance costs escalate, or are not fully understood at the time of purchase. One mechanism of ensuring that a purchaser fully understands these costs would be to require that a draft version of a Long-Term Maintenance Plan ( LTMP ) be made available to a purchaser prior to the purchase. It is accepted that the LTMP may be modified during and after construction. However, a draft LTMP would be helpful in ensuring a purchaser is fully informed about both the purchase price and about the ongoing maintenance costs they can expect to pay through body corporate fees. Currently, providing a LTMP is not an up-front requirement. 3.4 However, any reform also needs to provide for a situation where a body corporate has not prepared and/or approved a LTMP. In that situation, the vendor should not be liable for a failure by the body corporate to prepare a LTMP. Disclosure requirements must also be balanced with the fact that not all relevant information is known at the time of purchase. Off-the-plan unit titles 3.5 Property Council also has concerns about the effectiveness of a PDS in the context of unit title properties purchased off-the-plan. It is often difficult for an off-the-plan developer to provide detailed information prior to construction. This can be contrasted with the purchase of a property in an existing unit title complex, where there is history of available information to draw upon and provide to the purchaser. Some issues arise during development and construction that may not have been anticipated or foreseen at the design stage. Some information and circumstances simply cannot be anticipated and provided for in an off-the-plan PDS. 3.6 Therefore, MBIE needs to consider how it can make provision for off-the-plan unit titles. A standard form PDS that requires the same level of information for existing unit titles and for off-the-plan unit titles would place an onerous and unreasonable disclosure burden on off-the-plan developers. If the off-the-plan disclosure threshold is too onerous, developers may be placed at risk of breaching disclosure requirements. A bespoke PDS for off-the-plan unit titles could be a means of tailoring

disclosure requirements, thereby ensuring compliance. Again, any such PDS should be supported by thorough pre-purchase due diligence. 3.7 Further, it is unclear what consequences arise out of ineffective or the non-disclosure of information. A vendor should be aware of what consequences (if any) there will be for failing to provide information to a purchaser. However, this must be met by realistic disclosure requirements, as discussed at paragraph 3.5 above. 3.8 As discussed at paragraph 3.3 above, we suggest that a purchaser should be provided with a draft copy of the LTMP prior to purchase. Again, this would enable a purchaser to understand the ongoing costs associated with the maintenance and upkeep of the unit title complex prior to entering a sale and purchase agreement. In an off-the-plan sale, the developer is the same person as the vendor, and so is able to control the LTMP process and information better than an ordinary vendor. 3.9 It is our view that while all available information should be provided up front, a PDS alone cannot be a substitute for full pre-purchase due diligence and up-front access to a LTMP. While a PDS creates an obligation to provide all relevant pre-purchase information, some circumstances simply cannot be anticipated. Pre-purchase representation, due diligence and access to a LTMP are therefore vital to ensuring that purchasers are as well informed as they can be prior to entering into a sale and purchase agreement. However, we acknowledge that an up-front PDS is the best available option. 3.10 Property Council also supports the proposal that the accuracy of a LTMP should in some way be verified by a recognised surveying institution. However, it is unlikely that a professional would be willing to provide a guarantee. Instead, verification as to accuracy, having used all skill, care and diligence would be a better mechanism for ensuring the accuracy of information. This would provide another layer of certainty and assurance for a prospective unit title purchaser. 4. BODY CORPORATE GOVERNANCE 4.1 Property Council is generally supportive of the proposals for reforming the governance of bodies corporate in so far as they seek to provide greater transparency and certainty in the governance of bodies corporate. However, we also have concerns over some of the proposed reforms. Conflict of Interest, duties and responsibilities 4.2 Property Council views the proposed conflict of interest provisions as problematic. Conflict of interest provisions are a product of New Zealand s company law regime, which are aimed at ensuring company directors do not advance their own personal interests to the detriment of a company s shareholders. The Companies Act provisions provide protection to shareholders, and enable them to hold directors accountable for the management of a company. A director must therefore disclose an interest from which they will derive a material benefit. 4.3 However, in the context of a body corporate, body corporate committee members are required to be unit title owners, and so will always have a unique personal investment interest in the unit title complex. The role and obligations of body corporate committee members, while similar to those of company directors, also have unique differences. A committee member will be interested to protect

and advance their own investment interest. The personal interests of a committee member will often be different from the interests of the remaining committee members or other unit title holders, making the position of body corporate committee member more analogous to a cooperative or incorporated society. For example, a decision on construction or remedial work to a unit title complex may benefit a ground floor unit holder significantly more than upper level unit holders. The interests of an individual committee member may therefore be divergent from that of the wider group of unit title owners. Despite this, the decision relates to an investment interest that the committee member has in the unit title complex. On that basis, the body corporate committee member should not be required to divulge the nature or extent of the divergent interest. 4.4 In this instance, a committee member should be entitled to vote on the matter that at face value conflicts with the broader interests of the unit title holders within a complex. It is fundamental to the protection and advancement of individual property rights that parties with different interests are nonetheless entitled to advance those interests. That is, there should be no conflict of interest provisions as between owners in their role as owners. Any differences of opinion should be resolved through the governance provisions of the legislation, and through minority relief if necessary. 4.5 However, Property Council also recognises that there are often power disparities amongst body corporate committee and individual title holders, which may lead to the advancement of one groups interests. Any such power disparities should be dealt with by setting out clear duties and obligations on committee members. This could include requiring the committee member to provide all information relevant to the purchase of a property or to a decision regarding a unit title or a unit title complex. This should be a subjective standard, whereby relevance is determined by the person requesting the information. 4.6 A duty to act in the best interests of body corporate members or in the interests of a prospective unit title purchaser may also be a means of ensuring that committee members do not act to the detriment of body corporate members. 4.7 A suite of duties and obligations would provide a degree of transparency and accountability. It is recognised that duties and obligations may mean there is a reluctance to become a committee member. However, with greater education and understanding, these issues can be remedied. Allowing committee members to serve short term committee membership may also be a means of removing the reluctance of becoming a committee member. 4.8 Property Council does not support the proposal for comprehensive duties modelled on the Queensland code of conduct. Having reviewed the Queensland code of conduct, it requires a committee member to acquire an understanding of the relevant legislation. This places a significant burden on committee members, and is likely to discourage unit title holders from wanting to become committee members. Further, it is likely to encourage only those of apparent education or technical legislative proficiency to become committee members. It should be open for ordinary members of the public who are owners to become committee members. 4.9 Instead, Property Council supports some broad, interest-based duties, supported by adequate education and training of committee members. Property Council proposes the following duties:

a. A duty to act in the best interests of the body corporate. b. A duty to act as a reasonable committee member would act in the circumstances. c. A duty not to act recklessly or in a manner that is likely to cause the body corporate loss or harm. d. A duty to provide all information that in the eyes of the person requesting the information is relevant to any decision concerning the body corporate, whether that decision relates to the management of a unit title or the purchase of a property subject to a unit title. 4.10 Recourse for clear breaches by committee members could be in the form of a claim to a specialist Unit Titles Panel, having jurisdiction under the Tenancy Tribunal. Long-Term Maintenance Plan sign off 4.11 The proposed reforms include a requirement that the body corporate chairperson signs off a LTMP. It is unclear what this sign off requirement is designed to achieve, over and above the clear and apparent agreement of the body corporate to a LTMP. 4.12 A further fundamental problem with this requirement is that often the chairperson is merely an individual unit holder and of no specialised skill or expertise. It is therefore unclear whether the chairperson would become personally liable in the event of a dispute or breach. Property Council notes the issues that the Building Owners and Managers Association of North America have had in that personal signoff requirements have acted as a disincentive to occupying committee positions. No personal liability should apply. 4.13 On that basis, we do not support including a provision requiring the chairperson to personally sign off body corporate decisions. If sign off is required, then any such sign off should be done in the name of the body corporate committee. This would provide certainty that a decision regarding a LTMP is made by the body corporate committee, not an individual member of the body corporate committee. Further, any sign-off should not constitute a guarantee. Powers of committee members 4.14 There are also significant issues with the extent and scope of power that committee members hold. Under the Act, it is unclear what decisions committee members are entitled to make. This means that in practice, committee members are potentially making decisions that are ultra vires the Act or body corporate agreement. MBIE should consider providing greater clarity and certainty as to the extent of committee members power, how that power may be exercised and what accountability measures exist for ultra vires actions. Again, this could be incorporated through a suite of duties and responsibilities under the Act. Remedial works approval 4.15 Another issue Property Council sees with the current Act as it applies to remedial works, is the approval process. Currently, remedial work by way of a scheme must undergo a costly and cumbersome approval process via the High Court. While this has been described as a remedy of last resort, there are many such cases, which involve great expense, partly to avoid liability on the part of committee members. This discourages bodies corporate from undertaking such remedial

work, through fear of liability or of delays and cost. A simplified process for approving remedial works should be adopted, namely through the Tenancy Tribunal. 5. BODY CORPORATE MANAGEMENT Unit title complex size thresholds 5.1 Property Council has reviewed the unit title complex size thresholds set out by MBIE and supports the proposed size thresholds. In particular, we support the proposal to set the size of medium unit title complexes at 29 units. Research suggests that approximately half of all individual unit titles in New Zealand would be classified as a medium complex with the threshold set at 29 units. At 29 units, 5% of all unit title complexes would be classified as large complexes. 5.2 Property Council does not support stakeholder requests to increase the size threshold of medium complexes for the purposes of allowing medium complex unit title holders to opt out of the Act s provisions. Increasing the medium size threshold would greatly increase the number of individual unit title holders who are able to opt out of certain provisions of the Act (through special resolution of the body corporate). This would undermine the applicability of the Act and would make the proposed amendments redundant and ineffective by increasing the ability to opt out of provisions of the Act. 5.3 It is important that the opt-out threshold is set at a level that does not derogate from the effectiveness of the proposed changes. It is understandable that existing unit title holders would want the ability to opt out of the Act s provisions. However, allowing a greater number of unit titles complexes to opt out of provisions of the Act would erode the effectiveness of the proposed amendments. For example, it would allow owners to opt out of the requirement of having a longterm maintenance fund. This could mean the true costs of maintaining a unit title complex is not being borne fairly, which could act as a disincentive to undertaking maintenance. Increasing the medium size threshold would exacerbate this problem among a greater number of unit titles. This could also reduce the appeal of unit titles to prospective purchasers, who want certainty that rules will mandatorily apply in a large complex context. We therefore support retaining the medium sized complex threshold at 29 units. Body Corporate required to contract a manager 5.4 MBIE proposes making a Body Corporate Manager a requirement for medium and large bodies corporate. Property Council does not see any justification for making a body corporate manager a requirement. It should be open for the body corporate in question to determine whether the issues and matters it deals with require a Body Corporate Manager. Each unit title complex is different from the next. Some may require a manager, others may not. It may be that a unit title complex decides that it requires a manager of some sort. However, this should be a decision for the body corporate in question, based on the unique circumstances and issues it faces. 5.5 However, where a body corporate manager is contracted, then we support the proposed requirement that body corporate managers be part of a professional organisation as a means of holding them accountable. There are frequent examples of manager misbehaviour and/or misuse of funds. It would be unreasonable to place particular responsibilities on chairpersons and

committee members (who are volunteers) without placing similar responsibilities on managers (who are or should be professionals). Requiring managers to become members of a professional organisation or imposing a suite of express statutory responsibilities would be a means of regulating and maintaining the behavioural standards of body corporate managers. 5.6 MBIE has also stated that the obligations of a body corporate manager would be fiduciary in nature. However, body corporate managers are not part of the established categories of fiduciary relationship. Further, is it questionable whether a fiduciary relationship could be established, given that Committee members do not owe fiduciary duties to individual proprietors (and therefore a body corporate manager is unlikely to owe the same duty under any delegated authority). On that basis, the manager s obligations would be contractual, rather than fiduciary. Further, obligations would exist through the manager being a member of a professional organisation or through the enactment of suite of statutory responsibilities. 6. FURTHER CONCERNS AND ISSUES Conversion of 1 unit title complex into 2 unit title complexes 6.1 Property Council wishes to raise concerns over the current procedure regarding the division of an existing single unit title complex (perhaps containing 2 distinct or separate buildings) into two separate unit titles. The current procedure for obtaining consent to do this is complex and cumbersome. Currently, it requires cancellation of the existing body corporate agreement and the commencement of a new consent process. A new agreement for each body corporate must then be put in place. 6.2 There are a range of examples of bodies corporate that have multiple buildings, one example being a combination of a new building (with potential leaky issues) and an older building (with potential earthquake issues). Currently there is no easy way to separate costs for remediation, as the current legislation is very specific on levying obligations. The difficulty of separating buildings into standalone developments creates significant practical problems for owners. 6.3 Property Council suggests a simplified procedure that, for example, enables two new bodies corporate to be created from a single body corporate containing two separate buildings without the requirement of cancelling the unit plan and creating a new unit plan. This would ensure that a new body corporate could be established through consent of the individual unit title holders, by notification, and by establishing a new body corporate agreement. This would in turn enable the two separate bodies corporate to avoid a costly and time consuming process, providing a simplified consent process. Standard Rules for unit titles 6.4 Property Council considers there to be issues regarding standard form rules under the Act. Currently, a standard set of rules and provisions apply to all unit titles, whether large or small, complex or simple. This one size fits all approach is not sufficient to adequately provide for the many diverse unit title structures in New Zealand.

6.5 As we submitted in the Regulatory Systems (Building and Housing) Amendment Bill, we would like to see provisions that provide for the following property types: residential (including medium-density housing); commercial; light industrial; mixed use; shopping malls; hotels; and rural lifestyle blocks. 6.6 Targeted provisions would provide greater certainty and transparency regarding the rights and obligations of those property types. Currently, the provisions of the Act are general, and lack the level of specificity to adequately provide for a variety of property types. 7. CONCLUSION 7.1 Overall, Property Council supports ongoing reform of the Act. It is important the unit titles regulatory regime is clear, certain and transparent. 7.2 However, we do note several issues with the proposed reforms. It important that the purchasers of properties subject to a unit title are able to purchase with confidence and should be fully informed when entering a sales and purchase agreement. We therefore support the proposed reforms, with the suggestions outlined above. 7.3 Property Council would like to be heard on this submission during any further consultation. Yours faithfully Connal Townsend Chief Executive Officer Property Council New Zealand Should you require further information on any matter contained within this submission, please contact Tom Anderson, Policy and Advocacy Advisor for Property Council New Zealand tom@propertynz.co.nz.

ANNEX 1 MBIE QUESTIONS AND PROPERTY COUNCIL RESPONSES MBIE QUESTION We propose that the following legislative requirements apply to complexes with 10 units and over. The body corporate for complexes between 10 and 29 units, may, however, resolve against adopting any of these requirements by special resolution. Bodies corporate must: - report on the performance of delegated powers at the annual and any other general meeting; - contract a body corporate manager to perform functions as specified in the UTA; - have LTMPs signed by the body corporate chair and a qualified person; - have a LTMF to finance the long-term maintenance plan already required under the UTA; and - have body corporate accounts and LTMFs audited annually. Do you agree? If no, why? Do you consider that it is appropriate for complexes between 10 and 29 units to be able to opt out of the above proposed legislative requirements by special resolution? If no, why? Please comment on: - how government agencies might achieve a more joined up approach; - how we can improve the services we provide; and - whether you think a separate dedicated entity is warranted; and if yes, what functions and responsibilities would a dedicated unit titles entity deliver? Please list. PROPERTY COUNCIL RESPONSE We propose retaining the medium-sized unit title complex threshold at 29 for the reasons outlined in our submission above. There may be unique circumstances that mean unit complexes of this size need to opt out of some or all of these provisions. Property Council would suggest that bodies corporate of these complexes should be required to provide an opt out notice, outlining reasons for opting out of these provisions. However, we support the ability to opt out. Achieving a more joined up approach through greater national oversight and legislative provision must be balanced with the overarching and fundamental aspect of unit titles complexes, which is self-governance. The services could be improved through continual development of disclosure notice templates and other standard form documents. Review of the tenancy tribunal jurisdiction would also be a means of upholding a credible and suitable dispute resolution system. Property Council agrees that a separate body corporate governance office is not required. The self-governance element

Do you agree that the current pre-contract, presettlement and additional disclosure step should be consolidated into one step? If no, why? Do you agree that these additional requirements should be included in disclosure statements? Do you consider any other requirements should be included? Do you agree that bodies corporate should certify that all disclosed information is complete and correct? If no, why? We propose to add provisions to the UTA that address conflicts of interest that achieve similar aims to the provisions included in the Incorporated Societies Bill. Do you agree? If no, why? should be retained where possible, with suitable oversight and legislative provision. Property Council would support consolidation of the disclosure requirements into one pre-contractual process. This would ensure that the information is well set out, and takes precedence as a fundamental aspect of the purchase process. However, this cannot be seen as a comprehensive information standard, and should not substitute thorough due diligence. Therefore, there must be flexibility in what information is required up front and what accountability measures are put in place. Property Council takes no issue with the information that MBIE have set out as proposed disclosure requirements. However, we do question whether there is any merit in providing full meeting minutes and agendas. This is a significant amount of information that is unlikely to be read. Instead, focus should be placed on creating a well-structured, comprehensive PDS and greater education in the need to undertake thorough due diligence. Providing a draft LTMP would also be suggested. Property Council agrees with this requirement, however notes that there must be flexibility to recognise that not all information and circumstances can be fully understood at the pre-purchase stage. There must therefore be measures to provide for such unknown circumstances. This certification should not constitute a guarantee As outlined above, Property Council supports a suite of duties and obligations being placed on committee members, rather than conflict of interest provisions. We are of the view that conflicts of interest are better dealt with through prescriptive provisions requiring certain levels of conduct, rather than an interests register.

We propose that bodies corporate of large sized complexes (30 and over) should report on the performance of their delegated powers at every general body corporate meeting? Do you agree? If no, why? We propose including additional provisions on the duties and responsibilities of a body corporate committee similar to those included in the Queensland s Code of Conduct for committee members. Do you agree? If no, why? Do you consider that the risk of proxy farming is sufficiently high to warrant amendment of the UTA to limit the number of proxy votes one person can hold at a time? If yes, why? We propose to amend the UTA to: limit service contract timeframes; and specify a renewal period for service contracts after the control period. Do you agree? If no, why? Do you agree with the proposals made above as they relate to: Minority relief no change warranted; Alteration to units sections 79 and 80 (i) to be amended if necessary to align with section 65; Quorum section 95 to be clarified; Resolutions section 101 to be amended. If no, why? Do you agree that industry bodies such as those mentioned have the ability to increase professionalism and help address body corporate management issues? If no, why? Do you support requiring body corporate managers to be members of a professional group We have no opposition to this proposal. We understand that there is a requirement of ensuring that powers are exercised in accordance with body corporate interests. A reporting system would help support this. We support including some broad duties and responsibilities on body corporate committees. However, as outlined in our submission, we do not support the comprehensive Queensland approach to duties and responsibilities. We do not have any particular concerns with the current proxy voting structure or provisions. It is important to ensure all unit title holders are able to vote on matters impacting them. It is our view that the small cases of abuse does not warrant amendment. Abuses could be dealt with through the duties and obligations provisions that committee members would be subject to. A duty to notify other unit title holders of the nature and extent of proxy votes is an example of how these duties could operate. We have no particular concerns with the proposals regarding service contracts. We have no specific concerns with these proposals. Making it a requirement that body corporate managers become a member of a professional industry body will ensure those managers are subject to a code of conduct and would ensure that professional standards are maintained. As an accountability measure, we support the requirement that body corporate managers be members of a professional

and being subject to the codes of practice of the group? If no, why? group and so subject to a code of conduct or code of practice. Do you support body corporate managers being mandatory for medium and large complexes? If no, why? We do not support this mandatory requirement for reasons outlined at paragraph 5.4 above. Do you support the functions of body corporate managers being set out in the UTA? If no, why? What functions, if any, do you think should be prohibited from being contracted to a body corporate manager? This would provide clear parameters to what is required of body corporate managers. In order to support and protect the interests of unit title holders, we are of the view that this is a positive proposal. Do you support the setting of additional requirements in regulation for body corporate managers? If no, why? Do you agree that a member of a recognised surveying institution or professional group should be required to guarantee the accuracy and completeness of the LTMPs? If no, why? Do you agree that the body corporate chairperson, on behalf of the body corporate, should be required to sign LTMPs to guarantee accuracy (to the best of their knowledge)? If no, why? Are there mandatory fields/information you consider should be included in the revised template? If so, please list. Do you agree that 30 years is an appropriate timeframe for LTMPs for medium (unless they resolve not to) and large complexes? If no, what threshold or timeframe do you consider appropriate? We support this proposal as a mechanism to protect the interests of unit title holders and to ensure that body corporate managers are subject to clear obligations and duties. We support verification that a LTMP is accurate, however do not support accuracy being guaranteed by the professional. We do not support this proposal, but instead propose that a LTMP should be signed in the name of the body corporate so as to avoid undue accountability on an individual committee member. This would discourage people from holding the position of chairperson. Property Council is of the view that information is better provide through thorough due diligence, proficient representation and by providing the purchaser with a draft copy of the LTMP. We are conscious that making PDS information mandatory may lead to breaches where information is simply not available. We agree with this timeframe on the basis that there are inevitably going to be changes and amendments to that plan for that period. However, this must be met with a degree of flexibility as to what

We propose that medium sized bodies corporate comprising 10-29 units are required to establish and maintain a LTMF (unless they resolve not to by special resolution). Large complexes comprising 30 units and over units would be required to have and maintain a LTMF. Do you agree? If no, why? Do you agree that LTMPs for medium and large complexes should be reviewed every three years? If no, what threshold or timeframe do you consider appropriate? information can be provided and what can be anticipated. We agree that a LTMP should be a requirement in these circumstance (unless, in the case of a medium complex, it resolves not to). A LTMP is a relatively cost effective mechanism of ensuring that a unit title purchaser understands the likely costs they will incur in the course of owning a unit title. We are satisfied with a 3-year timeframe for review. We propose that the LTMFs of medium and large bodies corporate are audited annually. Do you agree? We agree with this proposal and are of the view that it will help ensure the accuracy and transparency of LTMP s.