As you know, at the end of June we were gifted with new AML legislation here in the UK. One of its main features was an absolute clarification about the AML status of estate agents: “In these Regulations, ‘estate agent’ means a firm or a sole practitioner, who, or whose employees, carry out estate agency work, when the work is being carried out”, and “for the purposes of these Regulations, an estate agent is to be treated as entering into a business relationship with a purchaser (as well as with a seller), at the point when the purchaser’s offer is accepted by the seller.” Until June, there was some (perhaps disingenuous) confusion among estate agents about whether we could really, possibly, actually mean them – but now it’s clear that we do.
I do already have a small number of estate agency clients, and a couple of them had previously asked me to write a piggy edition for them. I had demurred, on the grounds that I wouldn’t sell enough to cover my costs. Ignoring the time I spend writing a piggy book – not that the time’s not worth anything, but it is my choice to do it – there are still actual costs involved. The books are self-published, and I have to pay a cover designer to (you’re ahead of me here) design the cover. For the piggies, that comes in at £99 a cover. When I sell a (staff, rather than NED) piggy through Amazon, Amazon charges the buyer £5.99, and I eventually get £2.03 of that. So to pay for the cover, I need to sell forty-nine copies of the book.
When the Regs were updated so crisply, I re-thought my position on the estate agency piggy. Surely, I reasoned, with all the publicity about the new Regs, and all those estate agents who thought they were excused suddenly realising they are not, and all the negative press about the UK property sector being abused by money launderers, and the medium risk rating for the sector in the National Risk Assessment, well, they’ll be biting my hand off to get some accessible and digestible information for their staff. And so I wrote like a demon and got the estate agency piggy out within a week of the Regs appearing. I alerted the various estate agency trade bodies, I tweeted, I emailed every estate agent I knew, I contacted the estate agency press. And the response has been: pffffff. In July I sold five copies. I guess we’re waiting for a high profile regulatory fine to focus the mind – for which all hopes are pinned on HMRC. Those piggies may be waiting quite some time to be rehoused.