Summer '19 England & Wales

Summer 2019 ISSUE

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FIRST COMMENT IN THIS ISSUE: • THE LEASEHOLD BABY AND THE BATHWATER • A ROOM, BUT WITHOUT A VIEW • E-CONVEYANCING: A SLUGGISH PROCESS BUT THE SIGNS ARE PROMISING • REVERTER OF SCHOOL SITES - STILL AN ISSUE? • PRODUCT FOCUS: LACK OF ACCESS (PRE-PLANNING)

Leading Title Insurance

Welcome to the Summer edition of our newsletter for 2019.

In this issue, we’re pleased to welcome a new contributor to our team. John Outram, retired Partner at Taylor & Emmet LLP Solicitors, looks at the rights and wrongs of leasehold property given the recent headlines.

Kevin Lee, of Hill Dickinson LLP looks at the high profile case of the Tate Modern Blavatnik Building extension and invasion of privacy for local residents.

We also look at where we are now with the key advancements in e-conveyancing.

Finally, one of our senior commercial underwriters, Stuart Tooke, discusses a couple of cases around The Reverter of Sites Act (1987).

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FIRST COMMENT

The leasehold baby and the bathwater

by John Outram Solicitor

Whatever happened to considered thoughts, careful consideration and patient debate?

The journalists demand an immediate response to the latest Brexit vote within a few moments as politicians rush from the Commons to the bright lights and the microphones. The sporting star, exhausted from the frantic exertions of the battle, is required to provide a breathless, word perfect, politically correct and considered version of the game before he or she has stepped off the pitch.

The Daily Mail headlines ‘Toxic leasehold deals’, The Guardian leads with ‘the Ground Rent Scandal’ and others talk of ‘Outrage over the Leasehold Barons’, and suddenly the four million leasehold properties in England and Wales apparently become untouchable and any conveyancers, who have ever advised anyone to buy a leasehold property, are negligent and must contact their PI insurers forthwith.

Most things in life which add significant and lasting value to an area of life are also capable of having a serious downside; the internet, social media, knives and medication to name but a few. In its own way, leasehold property is, and has been, of significant value, but is wide open for exploitation by a minority

of unscrupulous individuals or companies. But should we throw the leasehold baby out in an attempt to rid ourselves of the filthy waters of greed or exploitation?

‘Have they all got it wrong?’

Having practised as a solicitor in Sheffield for 36 years, I am well aware of the leasehold issue. Apart from the huge growth in city centre developments of flats and apartments over the last 20 years, which are all leasehold, the majority of the older housing stock in Sheffield is long leasehold, 200 – 999 years and a significant number of newer developments grant to the homeowner a 99 year lease. Have they all got it wrong?

Typically, a lease from 1900 for 800 years might have a ground rent of £3. That would equate to

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about £350 today, but all the old, long-term leases, of which there are thousands, had fixed ground rents, so they remain at £3 for ever, hardly within the ‘scandal’ headline. Similarly many leases have ground rents, which increase by £100 or double every 25 years, again not scandalous or toxic, bearing in mind that inflation has averaged about 4% for the last 100 years and a ground rent of £100, increasing at 4% pa, would be £266 after 25 years.

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Does it work well for houses and flats?

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Subject to the disadvantages outlined below, the basic principles of leasehold title work well for flats and apartments, creating a suitable and workable framework for the various parties involved to manage their shared space and relationships.

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Historically, without appropriate planning and other controls, leasehold developments have enabled a degree of conformity to be maintained, but, apart from creating a financial benefit for the reversioner, which, more recently appears to be the prime goal of the developer / reversioner, there is little benefit that can be argued for the sale of future housing developments adopting the leasehold model.

So, is the leasehold baby worth preserving? To answer that question, we have to answer some others: 1.

What does a leasehold title achieve?

2.

Does it work well for houses and flats?

3.

What are the disadvantages?

4.

Can the problems be fixed?

5.

Is there anything better?

What does a leasehold title achieve?

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It allows the reversioner to give up possession of the property while retaining control over the state / fabric of the property and the behaviour of the leaseholders. It should be borne in mind that most of the pre 1947 leases were designed, among other reasons, to restrict unusual development as the main Planning Act did not appear until that date, hence the very unusual, but common, prohibitions on using the back garden of your terraced house as a slaughterhouse or for ‘tempering saws’.

What will our great grandchildren make of that in the next century or in 2800 when the lease expires?

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It allows the reversioner to collect an annual income or sell a capital asset.

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It allows all leaseholders to be sure that they are governed by the same set of rules and obligations, of which they are aware at the outset.

It allows the enforcement of positive covenants, which, with freehold properties, can render various obligations unenforceable.

What are the disadvantages of leaseholds?

In an ideal world, there would not be any problems.

However, as in any walk of life or industry, there are problems that appear without anyone’s fault but there are also unscrupulous individuals and companies. Thus we have:

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Homeowners with wasting assets (who may or may not have been advised properly).

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Homeowners trying to sort out their shortening leases, being faced with a costly process to extend their leases or buy their freeholds, and in many cases being faced with greedy, intransigent and arrogant landlords.

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Some landlords, in some cases with the help of ruthless professionals, imposing outrageous

FIRST COMMENT administration charges knowing full well that most homeowners will pay up when their ownership or peace is threatened, as the time and cost involved in arguing is just not worth the fight.

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The lack of control of the leaseholder over the cost of contributions to the ‘collective’.

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The inability of flat owners to be able to sell their home in a timely fashion, because of the delay by an unregulated landlord / management company in providing information in a timely manner or at a reasonable cost and similar problems for conveyancers trying to deal with the post completion process by satisfying restrictions on the Land Register.

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Escalating ground rents and the inability to mortgage such properties.

Can the problems be fixed?

Successive Governments from 1967 onwards have made legislative efforts to fix one or more of the outlined problems, but as with online fraudsters, a loophole is fixed and they find another way to be dishonest. Each of the fixes has provided some success, but in each case, the cost and time involved severely disadvantages the leaseholder.

Taking advantage of leasehold homeowners has been a growing enterprise over the last 25 years. Some would deem it a legitimate business enterprise to squeeze as much as they can from their financial assets, and if they have paid fairly for their investment, who can argue against that?

But we are not debating a bond, stock or another financial asset. We are considering the largest single investment for most homeowners, in which they have invested money, family and their lives. The security of that investment demands a system weighted much more heavily in favour of the leaseholder owner / occupier. However good the legal advice at the outset, it is impossible for the potential leasehold homeowner, in the midst of a complex acquisition and with no knowledge of titles, to weigh up the future problems and the effect

that they might have, and, unless the conveyancer is incompetent, there is no point in blaming the conveyancer for all or any of the problems above.

‘..there is no point in blaming the conveyancer...’

Some of the issues outlined have been partially fixed.

The others can be fixed if considered as a whole and indeed, the whole issue has now gained some significant attention at Westminster (when they are not considering the B issue). In particular, the Conveyancing Association has been at the forefront of pursuing an agenda to change the leasehold landscape and created a blueprint for reform in 2017. Notwithstanding the unbalanced approach of the press to the subject, the publicity does at least appear to have caught the attention of politicians.

Is there anything better?

Commonhold was created in 2002 with a view to fixing many of the outlined problems. The uptake of commonhold has been like the drop in the proverbial bucket, almost non-existent.

There are many reasons for this, but essentially, unless commonhold is mandated, developers are not going to opt for something which does not create an asset for them and is, at least initially, going to slow down the house selling process and conveyancers will be reluctant to dip a toe in the water unless they are going to do a few lengths on a daily basis.

As for throwing out the baby, it is possible with the current impetus to refresh the water relatively quickly and easily by dealing with rents, terms, right to manage and administration charges to name but a few, and that would be my choice in the current climate.

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FIRST COMMENT

A room, but without a view:

Fearn v. Board of Trustees of Tate Modern [2019] EWHC 246 (Ch)

by Kevin Lee Hill Dickinson LLP

The Neo Bankside development is an award winning scheme located on the South Bank that was completed in 2012. It comprises over 200 apartments and penthouses in four pavilion style buildings rising in sequence. The sales literature describes it as having unparalleled views towards the City and St Paul’s Cathedral and it’s won more awards than Gone with the Wind. A key feature was floor to ceiling glass cladding, allowing superb views across London town. In 2018 a one bedroomed apartment, barely extending to a mere cosy 540 sqft would set you back £800,000. A two bedroomed apartment extending a more spacious 1,600 sqft will set you back a cool £2.5m; a three bedroomed apartment will set you back a cooler

£4m and a 4 bedroomed 7,000 sqft penthouse went for a truly wallet busting £11.5m. So, it is an expensive development.

It is adjacent to the Tate Modern Gallery, which for those of you who are not aware of it, is housed in the old Bankside Power Station building. It is a monument to modern art. A few years ago, the Tate Modern decided to build a new extension known as the Blavatnik Building. On the 10th floor of this extension there is a walkway, around which visitors to the Tate Modern can enjoy 360-degree panoramic view of London. Unfortunately for the residents of some of the flats in Neo Bankside, that panoramic view includes a view directly into the

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living areas of their flats. Four of the flat owners in question felt that their privacy was being unlawfully invaded and accordingly launched a legal claim against the Tate Modern. The case, which has created a lot of public interest, was brought in the law of nuisance and under the Human Rights Act 1998, seeking an injunction requiring the Tate Modern to close the part of the gallery which gives the view into the flats and they also sought damages. The case occupied five days in the High Court in November 2009, with judgment being delivered in February 2019.

The four individual flat owners who brought the action were highly distressed by the situation that they found themselves in. Mr McFadyen owned an apartment on the 19th floor of Block C of the Neo Bankside development, which was roughly on the same level as the viewing gallery. He bought his flat in 2014, at which point the Blavatnik Building was not quite finished. He lives in the flat part of the time, having another home elsewhere. His evidence was that he and his family were ‘more or less constantly watched’. He claimed that they could not leave washing out and had to be ‘properly dressed’ at all times. He said that people on the viewing gallery, watched, photographed, filmed and even used binoculars to look into his flat. He said that the intrusion was relentless and that his family felt as if they were in a zoo. His wife found the situation so intolerable that she seldom stayed in the flat.

Mrs Fearn and her husband acquired their flat in August 2014 and their flat, like Mr McFadyen’s, was roughly on the same level as the gallery. The flat was to be a second home. She said that the actions of people in the gallery made her feel ‘sick to her stomach’. She claimed that people waved, made obscene gestures and photographed and filmed her family in their apartment. She decided that her young children should not visit the flat any more and indeed she said she now hardly visits the flat herself.

Mrs Urquhart lives in a flat which was slightly below the level of the gallery. She purchased two flats in 2013 and 2014 which she then knocked together.

When she purchased the flats, she knew that the Blavatnik Building was being built, but she did not

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know there was to be a public viewing gallery.

Since the viewing gallery has been completed, she said that she has experienced visual intrusion and photography. She said that people waved and made obscene gestures. She said the coverage in social media was very upsetting to her and when she visited the gallery incognito she overheard one visitor say that the ‘rich b******s’ who lived in the flats deserved the intrusion that the gallery afforded.

Without keeping her blinds closed, she said that she felt completely exposed in her kitchen. She felt that she could no longer host children’s parties in the property, which she said she used to do.

So, the intrusion into the apartments was clearly very upsetting to the owners. The issue was whether the law could help them. As mentioned above, the action was brought on two bases, but both were arguably speculative, at best.

Taking the claim under the Human Rights Act first, this was on the basis that the Act gave the flat owners convention rights of privacy under Article 8. However, that would only found a claim if the defendant was a public body or non-public body exercising functions of a public nature. The claimants relied upon a number of arguments to show that the Tate Modern should be considered to be a public authority. For example, they argued that it was founded by statute; it receives public funding towards part of its operating costs (for example, in 2016/17 the Tate received public funding of £35 million against total operating costs of £104 million); it provides a public service to the nation; it is subject to a high degree of accountability to the State and is subject to a Management Agreement between the Department of Culture, Media & Sport and the Tate.

On this the Court was clear. None of this transformed the Tate Modern into a public authority for the purposes of the Human Rights Act 1998.

The Court found that these factors showed that the Tate displayed, to some degree, some of the factors which may be relevant to the question of whether or not it is exercising public functions, but none of them were individually determinative and at the end of the day the key question is whether or not the activities of the Tate were governmental in their

FIRST COMMENT nature and the Judge came to the clear conclusion that they were not. The Tate ran a number of museums, but that was not a governmental activity.

The Tate was not carrying out public functions.

Accordingly, as the Tate Modern was not a public authority and there was no cause of action under the Human Rights Act. All this left was a claim in nuisance. Remember that the nuisance was said to arise from the interference with the claimants’ quiet enjoyment of their land and the fact that the amenity of the land had been interfered with by the frequent invasive inspections of the flats by the visitors to the Tate Modern. On this point, the Claimants got half way home. The Court found that external prying into a home was capable of contravening the law so as to amount to an actionable nuisance. But, this did not mean that all overlooking became a nuisance. Whether anything was an invasion of privacy depended on whether and to what extent there was a legitimate expectation of privacy. In this case, the locality was an inner city urban environment with a significant amount of tourist activity. An occupier in that environment could expect less privacy than a rural occupier might. The operation of an art gallery or a viewing gallery was not an inherently objectionable activity in such a neighbourhood. Whilst the viewing gallery did allow people to view the interior of the flat, this was not its purpose. If the Claimants lived in flats which did not have floor to ceiling glass then they would not have a nuisance claim because their flats would not be likely to attract external viewers in the same way. In choosing to buy these flats with floor to ceiling glass, the Claimants had created, or submitted themselves to an increased sensitivity to privacy. Accordingly, it would be wrong to allow that self-induced exposure to the outside world to create a liability nuisance. Part of the flats were in the nature of internal balconies and one did not expect as much privacy on a balcony. By moving living activities into these internal balcony areas the Claimants had created their own additional sensitivity.

blinds or net curtains. Accordingly, there was no actionable nuisance and the claims were dismissed.

Taking a step back, whilst this a very interesting case to the general public it was perhaps always one that was going to struggle on legal grounds. A nuisance of this kind, to be actionable, must be a real interference with the comfort or convenience of living according to the standards of the average person. An interference which causes harm to something of abnormal sensitivity does not itself constitute a nuisance and context is of course everything.

The case will have been a very expensive exercise for the unsuccessful claimants. Both sides were represented by both leading and junior counsel and had occupied the High Court for five days. As losers the owners would pay the Tate’s costs.

Finally, one aspect of the case which may have been slightly inaccurately reported is that it is said to have supported the notion that, as a matter of law, there is no right to a view. That is not entirely correct. There are, for example, authorities which say that there is a right to a view if it is supported by an easement or a restrictive covenant. For example, in Dennis v. Davis [2009] a very common restrictive covenant ‘not to cause nuisance or annoyance’ was found to be sufficient to prevent an extension to a property being built which would impede a pre-existing view of the River Thames enjoyed by the owners who benefited from the covenant. The Court of Appeal ‘unhesitatingly’ accepted the submission that a nuisance or annoyance covenant was sufficiently wide to include building an extension which when built would become an annoyance.

Finally, some obvious remedial measures could be taken by the Claimants, such as installing

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E-Conveyancing: a sluggish process but the signs are promising The digitalisation of the conveyancing process (e-conveyancing) has, for so long, seemed far off but the latest developments are a positive sign for the industry that things are, at last, gathering pace.

Almost the entire residential conveyancing process in England and Wales, particularly pre-exchange of contracts, is punctuated by the risk of delays and problems, but both legal and practical efforts are in motion to streamline the process - with technology at the centre of modernisation.

E-conveyancing and HM Land Registry HM Land Registry is making steady progress with its plans to digitalise the land registration process to make conveyancing an entirely electronic process - and it has just celebrated a major success. The Land Registry Digital Street research project announced, in April, that it has successfully completed the UK’s first digitised end-to-end residential property transaction. It used a blockchain prototype in the purchase of a semidetached property in Kent, showing how emerging technology can reduce uncertainty and delays in the process. The research project is also exploring the use of smart contracts to speed up property transactions, so we will be watching developments there with interest.

Another key development is the new digital Local Land Charges Register launched by Land Registry 10

last summer. This allows access to an online service to search for local land charges relating to land or property, reducing (and eventually eliminating) the need for manual searches. But it’s slow progress: there are only five local authority areas that have so far made the data switch to Land Registry, and it could take years for all 326 local authorities in the UK to be covered because of the amount of data that needs to be migrated.

Then there’s the digital mortgage: we are now in the second year of ‘sign your mortgage deed’ where buyers can sign their mortgage deed with the biggest of the high street lenders, so long as the borrower’s identity is first verified online via GOV.UK Verify.

What’s in the pipeline?

The Law Commission has made significant and wide-ranging proposals in its 13th Programme of Law Reform, including improving the conveyancing process. One of its on-going projects is reviewing the Land Registration Act 2002. The Commission suggests that a legal framework could be created to account for new technologies to make the conveyancing process more efficient – including re-examining the legal framework for electronic conveyancing.

Again, this is slow progress: this project is scheduled for completion this Summer and the Commission’s recommendations for reform are keenly awaited by the sector.

FIRST COMMENT

But this isn’t putting the brakes on continued work

by Land Registry to digitise the process. It’s 18 months since it published its Business Strategy 20172022. A particular focus is on automating the most straightforward updates and aspects of complex processes where possible, though it acknowledges that automation needs improved and digitised internal processes and systems. It will also “refresh and re-platform our core information technology (IT) and casework systems and infrastructure”.

And what part is the Government playing at the moment? Unsurprisingly, it has been somewhat distracted by Brexit, but this spring it expressed its commitment to improve the residential conveyancing process to reflect a modern digital age. In its report, Improving the home buying and selling process in England, government set out plans including to reduce the time between exchange and completion, speed up local authority searches and introduce reservation agreements to reduce the incidence of failed transactions.

While some parts of the process have already been successfully transformed by technology, the report notes the limited progress in other parts of the home buying process, “particularly in the official search and legal conveyance stages”. The report states: “Further technological developments, for example a digital land register, biometric ID verification and integrated case management systems based on real-time data could help make the conveyancing process simpler, faster and more transparent.”

So how does government intend to achieve its aims? A key move will be setting up a ‘technology working group’ to prioritise work on digital signatures, improving and streamlining ID verification, promoting the wider adoption of e-conveyancing, and “work with innovators to explore routes to market for technological solutions”.

Who the technology working group will include and how it will work in practice remains to be seen. You can read the full report here.

E-signatures given the thumbs up As for e-signatures, there has been a fairly inconspicuous but significant development for property buyers, sellers and developers.

The Law Commission has given initial confirmation that electronic signatures are as valid as traditional handwritten signatures in the execution of documents, if a signature is required by statute. This includes contracts for the sale of land. However, to be valid, there must be an intention to give legal authorisation by the e-signature, whether that’s a tick or a typed name.

This has put to bed a certain amount of legal uncertainty surrounding the electronic execution of documents and will undoubtedly save time in some transactions.

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Do note that e-signatures cannot yet be used in all legal documents because the go-ahead has not yet been given for the electronic execution of registered dispositions under the Land Registration Act 2002. That said, section 91 of the Land Registration Act 2002 allows certain electronic documents to be regarded as a legal deed without a ‘wet’ signature, so long as the identity of the person providing the digital signature is established and verified (e.g. the ‘sign your mortgage deed’ service mentioned above).

Lawyers on the ground Are conveyancing solicitors laying their own groundwork in preparation for e-conveyancing?

According to the results of a thematic review recently published by the Solicitors’ Regulation Authority, 63% of conveyancing firms it spoke to say they are taking proactive steps to prepare. This included having a dedicated IT team preparing for e-conveyancing, reviewing and purchasing new conveyancing software, updating case management and IT systems and taking part in Land Registry pilot schemes.

Other firms say they are awaiting further details to be released before taking any implementation measures - or simply don’t have the time or want to spend their cash on it yet.

The fact is, any technological developments which are tried, tested and secure and will make the currently fragmented and protracted conveyancing process speedier and more efficient will be good news for clients and your profit margins. All parties and stakeholders need to consider preparing now.

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FIRST COMMENT

Reverter of school sites - still an issue?

By Stuart Tooke Senior Commercial Underwriter Purchasers and vendors of sites used or previously used as schools should do their homework on sale or purchase. Or they could be in for a nasty surprise.

Landowners were encouraged during the 19th Century to give land over for the benefit of the public. One such act, The School Sites Act 1841 (1841 Act). enabled land to be dedicated for educational purposes – often being used as the site for a school. However, there was a catch. The grant was subject to a right of reverter. Meaning that should that land cease to be used for the purposes of a school (or use which fell within the provisions of the 1841 Act) then the Grantor (his heirs or assigns) became automatically entitled to recover the land by Statutory Reverter without the need for any transfer of the same. This raised the obvious question as to whether the seller of such a site actually had the right to dispose of the site because of the right of reverter. An attempt was made to resolve the matter by the introduction of The Reverter of Sites Act 1987 (1987 Act). This act did away with the right of reverter by introducing a trust arrangement. The land could be sold free from the right of reverter (subject to overreaching) if the use of the site as a school had ceased at the time of the sale. However, if the use has not ceased at the time of sale, the purchaser of such a site could find themselves in the unfortunate position of having to account for any future sale proceeds as a Trustee under the provisions of the 1987 Act.

The Case: In the case of Fraser & Fraser v Canterbury Diocesan Board of Finance (2005) a site for a school was conveyed in 1866 for purposes that fell within the 1841 Act . In June 1995 the school was sold to a purchaser (ISP) for use as a special needs school which did not fall within the provisions of the 1841 Act. The property ceased to be used as a Church of England School in July 1995 whereupon it was used as a special needs school until it was closed in 2000. The site was subsequently sold in 2005 for a sum considerably in excess of its 1995 purchase price. But when had the reverter arisen? Pre the 1995 purchase or post? The House of Lords decided that reverter occurred not when the decision to close the school was taken (pre the 1995 sale) but on the actual closure in July 1995.

The freeholder at that time, IPS, was therefore liable to hold the 2005 sale proceeds on trust for the beneficiaries.

The Reverter of Sites Act (1987 Act) Being able to sell free from the right of reverter means that School Trustees have to hold the sale proceeds on trust for the beneficiaries of the right of reverter. This in practice could mean they are not

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free to do as they please with the sale monies, even though they may believe otherwise.

The Case: Rittson-Thomas v Oxfordshire County Council (2019): The County Council were the trustees of the school site which was conveyed under the provisions of the 1841 Act in 1914. They decided to relocate the school to a new site, closing the old school in February 2006 and selling the same in September 2007. The sale proceeds were used to off-set some of the costs of the new school which they appeared, on the face of it, entitled to do under S14 of the 1841 Act. However, the claimants alleged that the closure of the school prior to its sale gave right to a right of reverter under the S(2) of the 1841 Act and therefore such right was converted into a right to the proceeds of sale under S(1) of the 1987 Act. The County Council denied the reverter on the basis that it was always their intention to use the sale proceeds towards the construction of the new school. The Court of Appeal agreed with the claimants. They decided that a right of reverter did arise when the old school closed in February 2006.

In order to prevent a right of reverter from arising the site should have continued in use for a statutory purpose under S(2) of the 1841 Act until the time of sale.

These cases highlight the needs of both vendors and purchasers to be well aware of the legislation in this area and that some school sites could still be caught by the right of reverter or trustee provisions.

They must tread carefully.

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Seeing the wood for the trees for 35 years

Call: +44(0)207 160 8100 Email: info@firsttitle.co.uk Visit: www.firsttitle.co.uk First Title Insurance plc is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. First Title Insurance plc is registered in England under company number 01112603.

Registered office: ECA Court, 24-26 South Park, Sevenoaks, Kent, TN13 1DU.

Leading Title Insurance

FIRST COMMENT

Product Focus:

Lack of access - pre-planning Background

Ramifications of risk

The insured purchased an old car park in Manchester with the intention of developing it for new industrial warehousing and / or possible new food markets. Planning had not yet been granted for the development and cover was required on a pre-planning basis.

As the access was registered in the name of a third party, the challenge was assessing the likelihood of the legal owner of the access objecting to the development. This was especially challenging as planning had not been granted yet, so there was no way of knowing how the legal title owner would receive the development.

There was an issue that the site did not abut the general highway and the access leading up to it was registered in the name of a third party.

Even though the site benefits from a number of historic rights of way over the access, there was a concern these might fall away with the new development.

There is a general requirement that development sites have unrestricted use of the road leading up to it. When this is not possible First Title can look to provide a policy in the event of interruption from the legal title owner of the access.

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Solution As the legal title owner appeared to be dormant and other titles were using the access uninterrupted, First Title were able to provide a suitable lack of access policy. The policy runs in perpetuity and will cover the insured in the event of any future dispute over access with the legal title owner.

To find out more about our products and services email info@firsttitle.co.uk or call +44 (0)207 160 8100

www.firsttitle.co.uk

First Title Insurance plc is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. First Title Insurance plc is registered in England under company number 01112603.

Registered office: First Title Insurance plc, ECA Court, 24-26 South Park, Sevenoaks, Kent TN13 1DU.