Mr. John-Mark McCafferty:

I thank the Chair and members of the committee for the opportunity to present on the Residential Tenancies (Greater Security of Tenure and Rent Certainty) Bill 2018 and the Anti-Evictions Bill 2018. Threshold has advocated for increased security of tenure, affordability, improvement in standards and a sustainable private rented sector since its foundation by Fr. Donal O'Mahony in 1978. We are working towards a vision whereby private rental is an equal tenure status with other tenure options in Ireland. The two Bills tackle many of the varied issues and seek to improve the rental sector for those who have made their homes in it and for those who will make their homes there. Both Bills seek to include lending or financial institutions in the definition of a landlord. The Residential Tenancies (Greater Security of Tenure and Rent Certainty) Bill 2018 goes further to include receivers in the definition. As the committee will be aware, Threshold has long called for the recognition of banks and receivers as landlords in the case of repossession of homes subject to buy-to-let mortgages. It is essential that both banks and receivers are recognised as landlords to ensure tenants' rights are respected in the case of repossession or the appointment of a receiver.

The establishment of such security is essential if private rental is to exist as a legitimate tenure alternative to owner occupation and social housing.

We welcome the proposal to include licences for student accommodation in the definition of tenancies and licensees in student accommodation in the definition of tenants. It is our position that all licences and licensees, and not exclusively those living in student accommodation, should be added to the definitions of tenant and tenancy.

It will be of no great surprise to the committee that Threshold supports the proposed definition of a deposit as outlined in the Residential Tenancies (Greater Security of Tenure and Rent Certainty) Bill 2018. At this time of increasing unaffordability, where tenants are being asked for the equivalent of two months' rent as a deposit in addition to their first month's rent to secure a home, a legal definition is vital to ensure tenants can afford to access the private rented sector. We have called for this definition for some time and for it to work alongside a dwelling specific rent register, which is essential for the protection of tenants and the enforcement of the rent pressure zone, RPZ, rules.

Linking rent increases to the consumer price index, CPI, will link rents to a tangible measure, reflective of supply and demand. We are in favour of the proposed amendment. We propose, however, that the increase should be subject to an overall limit of 20% over the course of five years. In addition, we support the proposal to designate the State as a rent pressure zone. We recommend that the designation be extended beyond the three years as Dublin and Cork will cease to be RPZ areas in December this year followed by the remaining areas in 2020. The enforcement of such measures is key, assisted by the dwelling specific rent register that I mentioned.

We see merit in extending Part 4 rights to tenants once they have been in occupation for two months. In addition to this, we fully support the creation of indefinite tenancies through the removal of section 34(b) which has been a long standing position of Threshold. This is an essential step in making the private rented sector a viable, sustainable tenure choice.

Sale as grounds for termination has no place in a modern rental sector. This has been the number one reason for tenants to contact Threshold in 2016, 2017 and 2018. Continuing to permit sale as a grounds for termination prevents the establishment of a sustainable private rented sector and undercuts the effectiveness of housing assistance payment, HAP, as a social housing support. We support the proposed removal of sale as a grounds of termination as proposed in both Bills.

Threshold supports the extension of notice periods for tenants, particularly those who have been in occupation for less than six months and for long-term residents who may have lived in a home for a substantial period of their life and are possibly at a later stage in life.

If renting is to become a tenure of choice and given that an increasing number of people are renting into older age, one year or more is not an unreasonable notice period. The committee may well be aware of our view on this matter. Threshold has long called for the creation of a publicly available rent register. It is essential that it be dwelling specific, allowing a tenant or prospective tenant to determine the rent on the property prior to moving in.