Afra Raymond’s submission to be made a party to the Colman Commission

16th March 2011

Afra Raymond’s submission seeking to be made a party to the Commission of Enquiry into the failure of

CL Financial Limited
Colonial Life Insurance Company (Trinidad) Limited
Clico Investment Bank Limited
Caribbean Money Market Brokers Limited and
The Hindu Credit Union Credit Union Co-operative Society Limited

My name is Afra Martin Raymond and I am a Chartered Surveyor, being a Fellow of the Royal Institution of Chartered Surveyors.  I am Managing Director of Raymond & Pierre Limited – Chartered Valuation Surveyors, Real Estate Agents and Property Consultants.  I am also the President of the Joint Consultative Council for the Construction Industry (JCC), an umbrella organisation which represents the interests of Engineers, Surveyors, Architects, Town Planners and Contractors in this Republic.

This submission is being made in my personal capacity and does not represent the position of either Raymond & Pierre Limited or the JCC.

My work on this vital issue has all been based on the public record and can be seen at

I am willing to give oral evidence before the Commission.

I have been conducting a campaign in the public interest on this important matter.  My work is unfunded and I have no assistance.  Indeed, I have no legal adviser at this Enquiry.

Having followed the issue so closely and attended the opening session on Friday 11th March, I am of the view that the parties thus far identified in this Enquiry are all seeking to advance their own interest.

I am here seeking to be made a party to this Enquiry, in seeking the interest of the silent majority, the taxpaying public, who have had to pay for this huge financial fiasco.

I am making this submission under rule 2. of the Commission’s Rules of Procedure, as a person whose “…participation in the Enquiry may be helpful to the Commission in fulfilling its mandate…

I await your reply.

Afra M. Raymond B.Sc. FRICS


Housing Policy Imperatives – Part 4

Having set out a framework for a more effective and equitable national housing policy, it is time to deepen the discussion.  In this week’s column, I will further analyse the existing housing policy so as to highlight those errors which we must avoid if we are to do better.

My proposed framework would quantify housing subsidy and allocate that in accordance with identified housing need, with the quality of the new homes also being monitored to ensure constant improvement.

To go further into the issues requires that we examine these aspects –

  • National Planning – It will be very difficult to achieve improved levels of housing quality if we proceed to build large numbers of new homes without reference to a national land-use plan.  1984 was the last time our Parliament approved a national land-use plan.  Over 25 years have elapsed and the position of the last government was that the national land use plan was being prepared for discussion in the next 2 years or so.  We have very limited developable land in this country – only about 9 to 10% of the total – so it is critical to plan and co-ordinate our future for best results with our limited resources.  Transportation, education, shopping, health-care, industry, housing and recreation are the main aspects which need to be fit onto those developable lands.  This ongoing housing programme has already had grievious cases of the alienation of agricultural lands for housing.  Alienation of agricultural lands is when we pave over farmland for non-agricultural development.  That land is permanently lost in terms of our food supply, but we need to preserve our agricultural lands.  That is vital in terms of maintaining our food security.
  • Intensity of development – An associated aspect that we need to reconsider is whether we can spare the land to continue HDC developments of  homes with gardens.  The HDC must publish its figures on the numbers of new homes built; the amount of land consumed; the numbers of houses versus the numbers of multiple-family homes and of course, the numbers of these various types of homes which have actually been occupied.  At this point the HDC has only built 15,394 new homes, compared to their annual target output of 8,000 new homes, which, if attained, would have been 60,000 new homes.  The HDC has only built a quarter of the intended number of new homes, which means that we still have time to adjust and improve the programme.
  • Pricing – The more I consider the dilemma in which this housing policy has been caught, the more it seems that the fundamentals were poorly-considered.  Just consider the issue of the pricing of the units – How did the pricing model evolve?  I have already, in part 2 of this series, critiqued the HDC’s cost-based model for its erroneous outputs in terms of assessing the quantities of housing subsidy being allocated.  One can go further to ask how these price points emerged.  Was any reference made to the incomes of the people on the waiting-list or were the HDC prices driven by the demands of the physical development agenda?  It seems to me that the latter was what took place, if indeed any conscious process of setting prices ever did occur.  If we are aiming for people-centred development, that entire misguided approach to pricing needs to be revised.  We need to give serious consideration to building more modest multiple-family homes for rental.
  • Quality – Another matter which has been in the news from both the last administration and now the new one, is the issue of the poor quality of some of the new homes.  We have been given various ‘horror stories’ about poor construction and the need for further works and so on.  But there is more to this story.  The fact is that the norm in the construction industry is that a contractor only has a valid claim to be paid in the case of ‘works properly executed’, so how did the HDC end up paying for all these defective buildings?  I am not seeking to exonerate the contractors from any wrongdoing, but the simple fact is that someone in HDC ought to have had the responsibility to inspect and approve the works before payment was authorized.  Either the HDC has a process for doing that or not.  If yes, what went wrong?  Who signed-off on those poorly-built homes?  If there is no such process, then the HDC system is one which exposes the Treasury and the neediest families in the land to real abuse.  These are serious questions which need to be answered, and soon.  If there are indeed civil servants and consultant advisers who have been approving defective work, they need to be dealt with.  If that were so, it seems to me that such actions would amount to grave professional misconduct, at the very least.  Such people should be banned from any State work for a period, as a minimum.  The real horror story is the official silence on the fact that someone from the HDC had to approve these very same defective works.  Lying by omission – see  That continuing dishonesty is the real horror story.  To remind readers that this is no new issue, please see –

I close this week by renewing my call for Minister Moonilal to take leadership on this burning national issue.  A conference on revising Housing Policy should include participation from the leading civil society organizations such as the JCC, the National Land Tenants’ and Rate-payers’ Association, the Sou-Sou Land group, Habitat for Humanity and the Salvation Army.

Basic facts need to be compiled and distributed to seed the discussion.  The framework and philosophy need to be clearly articulated, if we are to get it right this time around.

The continuing presence of over 10,000 empty homes is intolerable – it is solid proof of a seriously failed policy.  Our silence has to be broken on this issue.  We cannot continue this way.

Related reading:

Housing policy imperatives – Part 2

Last week’s column set out my principal queries as to our nation’s housing policy – see and Procedures/Strategic_Corporate Plans/Housing Plan.pdf – and the intervening events have only put those into better focus.

Key points –
Cheaper Govt Houses’ in the Sunday Guardian of 27th June featured an interview with Dr. Roodal Moonilal, Minister of Housing and the Environment.  The Minister touched on some of the key issues and confirmed that

…Some people simply cannot afford the market value of the homes. As a result, Government is looking to provide a further subsidy to assist with the purchasing of homes. I intend to take a proposal to Cabinet to consider the price reduction of the housing units…

– see .

There was no mention of rented housing in that article, so it seems that the new Minister has adopted the existing policy of preferring to sell the new homes built by the Housing Development Corporation (HDC).  In addition, he is proposing to increase the housing subsidy.  An important  correction is that HDC houses are not sold at ‘market value‘ as the Minister implied.  Market value is the amount the new home could sell for on the open market and the HDC offers the new homes to applicants at a lower price.

What is Housing Subsidy?

This is an important aspect of the housing policy discussion and these are the basic points –

  • Public funding – To create new homes, the HDC has to spend public money for land acquisition, professional fees and cost of construction – these are ‘first costs’ for new homes, but there are other significant costs of getting a needy family to move in.
  • Housing subsidy – For example, if the market value of a new HDC home is $900,000 and those homes are sold to applicants for $425,000, the housing subsidy in that case is $475,000.  Please note that I am not relating the sale price to the cost of production of the new home – that is a mistaken approach, because it ignores the opportunity cost of the investment decision to sell at that reduced price.  Effectively, this ignores the market to the detriment of the taxpayer.  Even in the case of rented housing, the same basis would apply, with the difference between the market rent and the actual rent being the weekly housing subsidy.
  • The allocation of Housing SubsidyFidelis Heights at Bates Trace in St. Augustine is a new HDC development of townhouses near to UWI – in my view, the homes there are middle-income units which should not have been built by the HDC.  In that case the housing subsidy per unit is in excess of $850,000.  In view of the desperate national housing shortage and the scarcity of resources, it was a grievious mis-allocation of both public capital and housing subsidy to have embarked on this scheme.  In the examples cited by the new Minister, the housing subsidy is far lower.  The people who purchased units at Fidelis Heights got them at between $780,000 to $900,000.  I am also aware that those homes were allocated without reference to housing need – i.e. some of them went to single people, without children.  To put it plainly, there is no case for allocating $850,000 in housing subsidy to a single person, when there are entire families in greater need, who are not catered for by the system.  There is a very poor quality of discussion on the issue of housing subsidy.  That is because of the system of cost-based pricing, as mentioned above, which error is compounded by the sparse references in the official statistics.  I have only been able to unearth a single official attempt to quantify housing subsidy in the ‘2010 Draft Estimates of Development Programme ‘Provision of Housing Subsidies at Greenfield sites’ is stated, at line H 003 to be $3,058,863.  I am not saying that there is a poor understanding of the role of housing subsidy.  That would be untrue, since the people who are manipulating the system all understand the real value of housing subsidy very well.
  • Rent control – ‘Rent subsidies for tertiary students’, also in Sunday’s Guardian – see – featured a discussion on the housing situation affecting 14,000 UWI students.

    [Minister of Science, Technology and Tertiary Education (MSTTE) Fazal] Karim said while the university has established mechanisms to register landlords “there exist no mechanisms to monitor prices, ensure quality accommodation, minimise security anxiety or seek the interests of the landlords and students.” In the near future, Karim said, the MSTTE and the Health Ministry will establish a committee that will make recommendations to establish mechanisms for the provision of subsidies “on rents to all students residing in the region and who are registered at tertiary institutions in the area.”

It seems from his statements that the MSTTE is proposing a rental subsidy to all tertiary students, whatever their means.  In a situation of scarce resources, that type of policy can have inequitable consequences, since some of these students are not needy at all.

The Minister of Legal Affairs, Prakash Ramadhar, attending as MP for the area, said –

…what adds to the problem is the lapsing by the Rent Assessment Board. “We nationally had to debate the issue if this country would go into a free market in terms of rent or rent restriction.”

Ramadhar said he would like to see free market forces determine rents.

Legal Affairs Minister Prakash Ramadhar, left, Fazal Karim, Science, Technology and Tertiary Education Minister, right, listen attentively to the landlords during yesterday’s discussion. Photo: Jennifer Watson. Courtesy Trinidad Guardian
Legal Affairs Minister Prakash Ramadhar, left, Fazal Karim, Science, Technology and Tertiary Education Minister, right, listen attentively to the landlords during yesterday’s discussion. Photo: Jennifer Watson

So here we have the paradox deepening, with the Minister responsible for the rent control system seeming to say that he is against those controls.

The outlook for the state’s intervention into the housing arena is confusing, to say the least.  Confusion is the ideal atmosphere to breed under-performance and corruption.

Our needy citizens deserve better.  This entire debate should be to create reasonable, redistributive and  sustainable housing policies for our nation.

The allocation of scarce housing subsidy must be reported and improved, so that the most needy receive the most subsidy.

Next week, we expand to include questions as to how many of the HDC houses are occupied by the legitimate tenants?  Are steps being taken to deal with those who have broken the terms of their tenancy?  Also, some discussion on the use of re-purchase schemes as another way to create extra units of housing.

SIDEBAR: The numbers’ game

Last week’s column asked Dr. Moonilal to specify how many new homes were empty at this time and it was very disappointing to read that “…approximately 10,000 homes, including defective units, are unoccupied…”.  The new administration has to strive to do better than the one they just replaced and it is just not acceptable that the HDC cannot (or will not?) report on an elementary matter like this.

Related reading: