The 6-year rent reset - can you actually get to market rent?

[stormy]

Mods — would it be possible to move the posts from the thread linked below over to this one, so the rent reset discussion is all in one place?

RTB Rent Register

Thanks @Gerard0 That seems to copperfasten the Rent Register as the primary source of 'market' rent. On the willing tenant part, the tenant can claim, actually I was unwilling and knew I was being ripped off, but I couldn't find any place else to rent so I had to take it.

www.askaboutmoney.com

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Tenancies entered into after 1 March are now subject to one of the most heavily regulated rental regimes in Europe. In return, accommodation providers have been promised a reset to market rent every 6 years. This thread discusses how those resets will actually work — because based on the cases reviewed so far, getting to genuine market rent may not be possible.

We discussed one case here where despite a very strong evidence package, the Tribunal just applied an index level of same area average rent growth to the old rent to and ended up with rent clearly below market rent.


TR1219-004102 — Andriuska v Xerico Limited (Mullingar, Co. Westmeath, non-RPZ)
https://rtb.ie/disputes/dispute-out...on-and-tribunal-orders/?_search=TR1219-004102

Background
Tenancy commenced January 2012 at €575/month. The rent had never been increased in 8 years. The accommodation provider served a rent review notice in October 2019 raising rent to €1,100/month effective January 2020. The first review in nearly a decade.

The evidence in front of the Tribunal

• Two written letters from local estate agents (Property Partners McDonnell and CML Auctioneers) estimating rent for 3 bed Abbeylands semi-d's at €900–€1,100 and €900–€1,000 respectively
• Eight DAFT advertisements for comparable Mullingar properties at €900–€1,200
• Two same-estate letting agreements at €800 and €850
• The accommodation provider's three comparators at €850, €1,100 and €1,250

The Tribunal landed at €800/month - at the absolute bottom of the entire range of evidence put before it, and below every estate agent valuation.

Three points worth flagging:

1. The professional auctioneers' valuations were disregarded. Two independent estate agent letters specifically valuing Abbeylands 3-bed semis at €900–€1,100 were dismissed as "general opinions only, not based on detailed consideration of the specific dwelling." It's not clear what stronger market evidence the Tribunal would accept than two independent professional valuations specifically referring to that estate.
2. A condition discount was applied without the Tribunal ever seeing the dwelling. The accommodation provider didn't attend the hearing, so the only "evidence" of condition was the tenant's own description and some photos. The Tribunal applied a discount below the same-estate letting range (€800–€850) on the grounds the property needed "renovation," was "difficult to heat," and had "8 years of wear and tear." No inspection. No independent assessment. No costing. No methodology for how much the discount should be worth. The accommodation provider didn't get an opportunity to dispute the condition claims because the Tribunal accepted the tenant's account at face value.
3. Comparators in other comparable areas were excluded. The accommodation provider's three comparators were in Ballynacarrigy, Athlone and Kinnegad — all in Westmeath/north Leinster, all 3-bed houses, ranging €850–€1,250. The Tribunal effectively required same-estate evidence and disregarded everything else. The tenant's eight DAFT comparators in other Mullingar estates (€900–€1,200) were also given minimal weight. The only evidence that mattered was the two same-estate lettings produced by the tenant himself.

Maintenance Issues
It's worth acknowledging the tenant raised genuine maintenance issues (mould, broken sockets and extractor fans, a leaking radiator, missing smoke and CO alarms). The accommodation provider should have addressed them. But most of these fall under minimum standards under the Housing (Standards for Rented Houses) Regulations (obligations that have to be met regardless of the rent level). The correct remedy is enforcement of those obligations under s.12(1)(b), not a discount applied to market rent. Using unfixed minimum-standard issues to suppress the rent effectively double-counts: the accommodation provider already has to do the work to comply with the law, and then the same issues become a reason to set rent below comparator evidence. The Tribunal here folded the maintenance complaints into an unquantified condition discount, with no inspection and no costing of the repairs allegedly needed. That's a methodological problem, separate from whether the complaints themselves were valid.

The structural problem
Section 24 of the Act defines market rent as the rent a willing tenant would pay and a willing landlord accept "having regard to the letting values of dwellings of a similar size, type and character to the dwelling and situated in a comparable area." The statute uses "comparable area" not same estate. But Tribunals are applying it to mean same estate or same complex (see Mardan case). Where same-estate evidence exists, they then discount it further for condition.

The result is a methodology where:

• Same-estate achieved rents set the ceiling
• Wider-area comparators are excluded as not similar enough (including those in the same LEA)
• Professional valuations are excluded as not specific enough
• A condition discount drives the figure below even the same-estate range
• The accommodation provider's evidence is given minimal weight (especially if they don't attend it seems)

End Result: Index Based Rent, Not Market Rate
The €800 outcome. It's a 39% increase on €575 — 4.2% per year compounded, broadly equivalent to what the RPZ cap would have allowed had Mullingar been designated (at the time). So the substantive effect of the s.19 open-market test is essentially the same as a cap calculation: cumulative inflation-adjusted upward movement from the existing rent, not a genuine fresh market test. For a tenancy that hadn't seen a review in 8 years and where local market evidence suggested €900–€1,100, the accommodation provider achieved a rent that's neither at market nor close to it.

Is this fair? As ever, things stack against the accommodation provider

• The Tribunal weighted the tenant's same-estate evidence (his daughter at €800, his sister at €850) very heavily (both family members of tenant)
• The condition discount was applied on uncontested tenant evidence. The accommodation provider had no opportunity to dispute it.
• Two independent professional valuations (furnished to the tribunal) were dismissed as "general opinions"
• Wider-area comparators were excluded despite the statute referring to "comparable area" rather than "same estate."

The case illustrates how the s.19 methodology, even with comprehensive market evidence in front of the Tribunal, produces an outcome closer to a regulatory cap than to a genuine market figure. The wear-and-tear discount and the same-estate-only rule combine to systematically suppress the achievable rent below independent professional valuations.

The new rent register is not going to have the level of details required in these tribunal case examples. Can one now assume that even if they do manage to find a rent at the market rent in the register, it's just going to be discounted for a random and unquantified "condition" adjustment?

 

[Greenbook]

The professional auctioneers' valuations were disregarded.

This is a key point here.

Where the Rent Register, as it generally does, shows lower rents, the landlord will use EAs valuations plus Daft to justify the higher rent.

The Tribunal will ignore these, for two reasons:

1. Based on previous decisions, that's what it does anyway.

2. The legislation has copperfastened the Rent Register as the primary source of 'market' comparables. Anything else provided is optional and supplementary ie. doesn't carry much wait.

High rents are bad, both for tenants and the economy generally, so I'm not actually advocating for them.

What I am really complaining about is the underhandedness of all this. First we were told RPZs were going (that went on for years), then they weren't, then we could reset to market in certain circumstances, then this was tied to the Rent Register, then that was up and running and we see that it is rigged. The PRS is a crazy business to be in. And we're tied up in all sorts of filings, deadlines, uncertainty about when to file to even achieve this.

It is obvious now that the government and the RTB will do their upmost to ensure that there is no reset to market either when the tenant leaves or at year 6. Tenant's will be encouraged to dispute the rent, this is top on the Report Your Landlord Form. This can be done at any stage via the Form, so if the place is a bit shabby after a couple of years, then tenant can obtain a discount at the stage.

Tenancies entered into after 1 March are now subject to one of the most heavily regulated rental regimes in Europe.

I'd imagine it is the world and not just Europe.

 

[stormy]

I'd imagine it is the world and not just Europe

I agree

This can be done at any stage via the Form, so if the place is a bit shabby after a couple of years, then tenant can obtain a discount at the stage.

Indeed, this looks to be the way it will go. There will never actually be a reset as this discount is just going to be applied irrespective of the evidence presented.

 

[DannyBoyD]

The analysis of previous documented cases is useful & even interesting.

The stomping around in your wellies repeating circular arguments very much less so.

 

[Bronte]

1. Based on previous decisions, that's what it does anyway.

- all cases were based on prior legislation
- we don't know how the new legislation is going to be interpreted
- the RTB is not the Oracle, a court case will be the final decision, I very much doubt they will argue the 'new act' with market rents means the RTB price register, because that's not what the Act says. If it did I'd agree with you.
- yesterday I analysed an RTB tribunal that was open to a) rental valuations of rents b) DAFT ads

 

[Bronte]

Stormy thanks for your analysis, before I read it I'll do my own analysis as I find it helpful in understanding what is happening in the Tribunals

Landlords mistakes

- did not show up at tribunal
- let tenant purchase furniture
- no rent increase since 2012 to 2020
- ABSOLUTELY OUTRAGOUS to issue a rent increase notice
- supplied 3 rents, none of which were the same estate
- adding up the 3 and dividing by 3 is less than the proposed rent increase
- did not supply ads, nor photographs nor details (I suppose layouts, furniture, standard of finish)

Tenant mistakes
- none, I feel sorry for him that he's had to put up with so many issues

Tenant positives
- had purchased furniture
- said landlord had not done any refurbishment, furniture old and dated
- had fixed a heater
- had painted
- said landlord refused to refurb or buy furniture as rent was so low (this is outrageous, and yes as a landlord I complete get it, but if you're going to up the rent you'd better not be doing this)
- tenant had emails of problems from 2019
- OMG the issues are humongous
- tenant has photos (OMG it gets worse and worse)
- I've got this far and even I'd be on the tenant's side
- no landlord inspections
- massive heating bill
- was able to produce his daughters rent from a nearby property of 800 from January 2019
- her house was exactly the same size
- evidence of yet another sister's house, fully refurbed at 850 from Sept 2019
- emails from not one, but two auctioneers of the rental estimates
- 10 ads (this tenant is brilliant - I'm learning loads from him !! )
- argued his rent should not be increased (( agree)
- this is really really fair of the tenant, and shows his bone fides, he said he'd be prepared to pay 900 if the repairs were done, like bloodly hell what is not fantastic about that

RTB

- frankly I'm amazed the RTB agreed to increase the rent at all
- rightly said market rent had to have regard to it's current condition
- rightly said after 8 years occupation a place would have had considerable wear and tear
- rightly used the 2 houses rent in the same estate as proof of market rent
- rightly used the two supplied ads as further support

Conclusions

- you must be prepared to properly demonstrate comparable rents
- photos are important (so it's easy to compare)
- location important
- must be like with like
- interestingly, while they relied on the two auctioneers emails of rents, the tribunal were very clear that those emails were 'general' and not 'specific' to the property. This is important, because to me, that means you should get an expert to view the property and write a rental value based on seeing it
- leases of other properties are perfect for evidence

Frankly I'm amazed the Tribunal was not harder on the landlord given the state of the property, but I'll presume this is because it was a new owner and not entirely their fault as to what had happened prior to this

I'm surprised the agent sent the notice, knowing the repairs needed, and didn't ensure the repairs were complete before increasing the rent.

 

[Greenbook]

- all cases were based on prior legislation

Current legislation is even more restrictive. The previous legislation mandated Daft ads, now it is the Rent Register ie.

rent information contained in the published register in relation to dwellings of a similar size (determined by reference to floor area), number of bedrooms, type, character, and (where applicable) BER, to the dwelling and situated in a comparable area to that in which it is situation.

- we don't know how the new legislation is going to be interpreted

I think we can take a good guess at that. The RTB is not going to be in favour of high rents.

- the RTB is not the Oracle, a court case will be the final decision, I very much doubt they will argue the 'new act' with market rents means the RTB price register, because that's not what the Act says. If it did I'd agree with you.

A Tribunal decision like this can be difficult to appeal as an appeal to the High Court is only on a point of law ie. some issue of legal interpretation. Also, what small landlord can afford to appeal to the High Court where you have to have a Senior Counsel. If you lose, you'll pay your own legal fees and the RTB's legal fees including their Senior Counsel as well.

- yesterday I analysed an RTB tribunal that was open to a) rental valuations of rents b) DAFT ads

Pre the new rules - see section 24 above.

WORK IN PROGRESS, NO COMMENT UNTIL FINISHED PLEASE

My understanding is that this case is about the landlord trying to impose the annual 4%/2% increase? If so, the decision is very worrying as the landlord got knocked back on that. The rent was low due to the RPZs, the landlord tried to increase it by the annual rent cap and even that was knocked back.

The does not bode well for increases to 'market'

 

[Greenbook]

Ultimately, I think the real answer to this is what they didn't do rather than what the government did.

If they had intended that we could increase rents to genuine market, then the determiners of that would be what a tenant would pay backed up by Daft ads and/or an EAs opinion. That's market in any other business area.

Instead what we have is what a willing tenant would pay having regard to the Rent Register which is rigged to show low rents.

Just like there was never an intention to end the RPZs, there is no intention to allow market rents either.

 

[Bronte]

error (multiquote will be the death of me)

 

[Bronte]

Tenancies entered into after 1 March are now subject to one of the most heavily regulated rental regimes in Europe.

I think the new UK legislation is pretty heavy, on the continent we have heavy regulation, but tenants have obligations. My lease is very tight and detailed.

We discussed one case here where despite a very strong evidence package, the Tribunal just applied an index level of same area average rent growth to the old rent to and ended up with rent clearly below market rent.

The case you have on this thread doesn't mention the index at all.

The rent had never been increased in 8 years

It is very important to point out when discussing this case, that the tenancy commenced in 2012, BUT there was a new owner/landlord in 2018.

The evidence in front of the Tribunal

• Two written letters from local estate agents (Property Partners McDonnell and CML Auctioneers) estimating rent for 3 bed Abbeylands semi-d's at €900–€1,100 and €900–€1,000 respectively
• Eight DAFT advertisements for comparable Mullingar properties at €900–€1,200
• Two same-estate letting agreements at €800 and €850
• The accommodation provider's three comparators at €850, €1,100 and €1,250

The two same estate were the lowest rents, were the exact same comparators as regards location and size. They were therefore far and above the correct ones to work out market rent from.

 

[Bronte]

The professional auctioneers' valuations were disregarded. Two independent estate agent letters specifically valuing Abbeylands 3-bed semis at €900–€1,100 were dismissed as "general opinions only, not based on detailed consideration of the specific dwelling." It's not clear what stronger market evidence the Tribunal would accept than two independent professional valuations specifically referring to that estate.

They were not disregarded, they were looked at, and the Tribunal said they a) not specific enough and b) the tribunal preferred the leases provided of 2 properties in the exact same estate

A condition discount was applied without the Tribunal ever seeing the dwelling. The accommodation provider didn't attend the hearing, so the only "evidence" of condition was the tenant's own description and some photos. The Tribunal applied a discount below the same-estate letting range (€800–€850) on the grounds the property needed "renovation," was "difficult to heat," and had "8 years of wear and tear." No inspection. No independent assessment. No costing. No methodology for how much the discount should be worth. The accommodation provider didn't get an opportunity to dispute the condition claims because the Tribunal accepted the tenant's account at face value.

- the landlord not attending is a fault of the landlord
- 'some photos'. What more evidence could a tenant provide, that's perfect evidence or do you disagree
- the landlord did not refute the tenant's sworn evidence, the tenant provided photos, heating bills, proof of purchase of furnitrue, evidence of painting, a long list of problems, which had been sent to the landlords agent, 8 years of wear and tear is real, it was 8 years
- no independent assessment, that's up to the landlord, in fact the tenant stated there had been no landlord inspections, whose fault is that
- they were correct to 'discount' the rent given the state it was in
- of course the tribunal had to accept the tenants account, it was clear as day the place was in a bad state, had had zero repairs, the tenant was living with electrical faults for goodness sake,
- what do you mean the landlords didn't get an opportunity to dispute the conditions claimed, he didn't show up, like serioulsy?

Comparators in other comparable areas were excluded. The accommodation provider's three comparators were in Ballynacarrigy, Athlone and Kinnegad — all in Westmeath/north Leinster, all 3-bed houses, ranging €850–€1,250. The Tribunal effectively required same-estate evidence and disregarded everything else. The tenant's eight DAFT comparators in other Mullingar estates (€900–€1,200) were also given minimal weight. The only evidence that mattered was the two same-estate lettings produced by the tenant himself.

A landlord would look to rents in the exact same estate to know market rent, I know the rents on my street. This is not rocket science. Rents in Athlone are not the same as rents in Kinnegad?

 

[Greenbook]

@Bronte based on what you've said in previous posts, and my apologies if I have misinterpreted or misremembered something

1. You have gone straight to market rent based on a EA valuation
2. You are also charging back all the costs to your tenant on an itemised basis
3. You did not file the rent setting form
4. You have not used the Rent Register at all for your rent.

This I think was done because the property was vacant for 2 years, but the consensus here from very knowledgeable posters was that the rent setting form and compliance with the Rent Register is required in your circumstances too.

I honestly hope you don't, but I think you may have an issue which how you dealt with the rent setting. Legal advice might be beneficial.

That is the big picture. Picking bits and pieces out of this Tribunal decision isn't.

 

[Bronte]

It's worth acknowledging the tenant raised genuine maintenance issues (mould, broken sockets and extractor fans, a leaking radiator, missing smoke and CO alarms). The accommodation provider should have addressed them. But most of these fall under minimum standards

Seriously? The place sounds horrendous.

The correct remedy is enforcement of those obligations under s.12(1)(b), not a discount applied to market rent. Using unfixed minimum-standard issues to suppress the rent effectively double-counts: the accommodation provider already has to do the work to comply with the law, and then the same issues become a reason to set rent below comparator evidence. The Tribunal here folded the maintenance complaints into an unquantified condition discount, with no inspection and no costing of the repairs allegedly needed. That's a methodological problem, separate from whether the complaints themselves were valid.

There was not actually a discount, it was a very fair market rent given the condition of the property The correct remedy would be no rent increase until the landlord fulfilled his obligations, he should have done this first and then gone to market rent. In fact I'll go further, he should have been fined for the egragious amount of issues, especially the sockets

- the professional valuation would have been accepted if it was specific enough
- using the same estate valuation is actually very fair for judging market rent, what's harder is a city, or the electoral areas, this will be sorted out in time.
- you didn't mention the landlord could have upped the rent during the years prior as he was not in an RPZ so there is zero point comparing RPZ limits to it
- again and again you refer to uncontested tenants evidence, whose fault is that ? You have not addressed the fact the landlord decided not to attend, nor send his agent. I don't believe they could defend anything and that is the reason they didn't show up.

Can you link to a better case, this one was judged very fairly as far as I'm concerned.

 

[Bronte]

@Bronte based on what you've said in previous posts, and my apologies if I have misinterpreted or misremembered something

1. You have gone straight to market rent based on a EA valuation
2. You are also charging back all the costs to your tenant on an itemised basis
3. You did not file the rent setting form
4. You have not used the Rent Register at all for your rent.

This I think was done because the property was vacant for 2 years, but the consensus here from very knowledgeable posters was that the rent setting form and compliance with the Rent Register is required in your circumstances too.

I honestly hope you don't, but I think you may have an issue which how you dealt with the rent setting. Legal advice might be beneficial.

That is the big picture. Picking bits and pieces out of this Tribunal decision isn't.

- I'm at market rent as that's what my expert said the market would take
- I'm in the two year vacant rule
- I don't care what the rent registry of the RTB says
- I know what the words market rent mean
- the fact I've rented at market rent demonstrates I'm at market rent
- my rent is now the highest on that street, I've shared it with 2 other landlords
- no I'm not charging back itemised anything? They pay their utilities and bins. I'll pay for repairs. The agent has a whole team to do everything, ie they have a carpenter, plumber, electrician etc. They also organise the fire tests. All those will be billed back to me. I'll repaint in between lettings. If they stay long term than I'll do it when the agent expects me to. My new business model is hands off, hand it over to agent and I don't want to know about it. (everything above x amount is run by me, I've already authorised the fire inspections etc). They also do annual inspections.
- Agent deals with RTB registration and rent setting, they have a dedicated person for this
- I'm pretty confident in my own knowledge that the Rent Register is a guide, but the legislation does not specifically state the register is to be the decider on market rent. It will take a while for this to settle though.

Can you tell me how my rent can be incorrect? My property is not in an estate, it's got a top refurb, there is not a comparable rental on the street. In fact right now I can point to multiple other tenancies that are achieving close to my rent, but that are not as high, they are each unique, different sizes and my finish is the best as it was a massive renovation. Already on Daft I can see that the rents are very high now. Soon they will be the figures for the RTB rent index, which is not yet out for Q2 in 2026. My rental is not yet up on the RTB registar.

 

[DannyBoyD]

tenant has photos

Where are you seeing the photos?

 

[Bronte]

Where are you seeing the photos?

1. Agent asked the tenant to send him the photos - outlined in blue
2. Agent told tenant the maintenance team would contact him
3. In yellow photographs supplied in the file of some of the issue (I presume the worst ones)

As a landlord I'm trying to figure out what it is the RTB wants, but I would have thought photos were essential. The tenant was very well prepared and had put up with a lot.

 

[Greenbook]

Can you tell me how my rent can be incorrect?

See all the earlier posts on the difficulties and traps with rent setting on this thread and other threads.

 

[DannyBoyD]

@Bronte - ah, ok - I thought there were actual photos attached to the report & I couldn't see them.

 

[stormy]

Bronte, thanks for the detailed engagement! I do appreciate the engagement, and it's good to keep me honest!

I'll address the substantive points

Auctioneer valuations
Fair correction on "disregarded" - the Tribunal looked at them and gave reasons for low weight ("general opinions only, not based on detailed consideration of the specific dwelling"). But the effect is the same: two independent professional valuations specifically referring to the estate produced ranges of €900–€1,100 and €900–€1,000, and the final figure landed at €800 - below the lowest figure either professional thought achievable.

Your point that valuations "would have been accepted if specific enough" deserves scrutiny. The auctioneers' letters were specific: 3-bed Abbeylands semi-detached, the estate, the property type, the bedroom count. The only further specificity possible is physical inspection of the exact dwelling. But the valuations were prepared before the rent review notice was served, when there was no formal dispute. The "specific to the dwelling" standard either requires pre-dispute access (which most landlords don't anticipate needing) or post-dispute access (which tenants won't grant). It's a standard that systematically disadvantages landlords relying on professional evidence. And it's implausible that two independent local auctioneers both produced ranges that were independently wrong by >€100.

Property being "horrendous."
That's a stretch. The tenant's complaints were: a few non-working sockets, mould on kitchen and bathroom ceilings, broken extractor fans, a clogged toilet sink, a leaking radiator, no smoke/CO alarms. Real maintenance issues that should have been fixed - but it's clearly not "almost uninhabitable." No mention of structural problems, no heating failure (the heating worked, it was expensive), no roof issues, no pests. The tenant lived there continuously for 8 years.

On same-estate comparators being "very fair."
I strongly disagree here. Section 24 refers to "comparable area" not "same estate". That wording is clear. Mullingar is a town of ~25,000 with multiple residential estates of broadly similar character. Reading "comparable area" as "same estate" reads the law much more narrowly than it is - that's not interpretation, it's rewriting by the Tribunal. The new Rent Register from 1 March 2026 uses the Local Electoral Area as the unit of comparable area, not the individual estate. So the Tribunal's approach is stricter than the law. And also stricter than the Rent Register facilitates.

The Tribunal also effectively treated the €850 fully-refurbished same-estate comparator as a cap on what any property in the estate could achieve, while excluding the wider evidence pointing higher: eight DAFT comparators in other Mullingar estates at €900–€1,200, two independent auctioneers at €900–€1,100, and the landlord's three comparators at €850, €1,100 and €1,250.

On Athlone and Kinnegad - they're not Mullingar, that's fair as a generality, but that's an argument for weighting those comparators, not for excluding them. Both are Westmeath towns producing comparators entirely consistent with the Mullingar evidence.


Why this matters for the new 6-year reset.
I'm not looking at this case to defend the landlord's failures - they are real and they cost him. The point is structural. Even if he had attended, supplied full inventories, fixed every maintenance issue, the methodology applied here (same-estate-only comparators, professional valuations set aside as "general", wider comparable-area ignored). The point is that the €850 refurbished unit is the cap (tenant's sister's house) despite the weight of all the other evidence. This is especially interesting as the tenant themselves even offered to pay €900 if it was refurbished.

That's the question for the 6-year reset under the new rules. Accommodation providers entering tenancies post 1 March have been promised a reset to market rent at year 6 in return for accepting some of the most regulated tenancies in Europe. But if the Tribunal methodology stays the same (narrow same-estate readings of "comparable area", professional valuations discounted, condition adjustments calibrated by guesswork) and the Rent Register becomes the primary comparator source (with all the staleness, lack of detail, and downward bias that implies), then the 6-year "reset" won't actually deliver market rent. It'll deliver some random rent register number, with a condition adjustment, dressed up as a market reset.

The reset is a promise that it looks like won't be achievable.

 

[Bronte]

Bronte, thanks for the detailed engagement! I do appreciate the engagement, and it's good to keep me honest!

Thank you Stormy, obviously I'm on the side of landlords and clearly I cannot stand the costly ineffectual RTB. But we have to do a fair analysis if we are understand how things are decided. That was a woeful example linked. If you or anyone else could put up a better one on 'market rents' that would be great. But we have three massive problems:

- the RTB can and does get the law wrong, so it is only legally decided if a case goes to the High Court
- the new legislation, we don't know how the RTB is going to 'interpret' the new legislation
- no legal commentator has stated what the new legislation actually concretely means, that's because it's a dog's dinner of legislation (see Alan Shatter's views for confirmation). So no legal commentator can work it out as it's too complex.