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Property factor complaints and the written statement of services

When a homeowner complains, the expensive part is rarely the first message. It is the file behind it: a written statement of services that was never issued after settlement, a complaints procedure that was not sent when asked for, a holding note that never went out when the timescale in the statement could not be met, or correspondence that cannot be found later.

None of those steps is difficult. Together they keep a factoring office on the chase, instead of with owners. If the complaint is not resolved, the next step is the Housing and Property Chamber, and a thin file is what that application looks like when it arrives.

Lorework is an AI coworker for that work. It works through the web systems you already use, on its own computer. The wider coworker model for property factors is set out on the property factors page. The update loop on a common repair is on the communal repairs page. This page is about the written statement of services, the complaints procedure, and the file a firm needs to keep. It is written for factors in Scotland, because the Act, the Code and the tribunal path are Scottish.

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The written statement is the document the tribunal will compare you with

Section 1 of the Code of Conduct requires a property factor to provide each homeowner with a comprehensible written statement of services (WSS), setting out the terms and service delivery standards of the arrangement in a simple, structured way. If a homeowner later applies to the First-tier Tribunal, the tribunal will expect the factor to be able to demonstrate how its actions compare with that statement.

The Code also sets timescales for issuing it. The factor must take all reasonable steps to ensure that a copy is provided within four weeks of the factor agreeing in writing to provide services, or within four weeks of the date of purchase (the date of settlement) where the factor maintains the common parts — or, if the factor was not told of the purchase in advance, within four weeks of receiving notification. A revised statement must go out at the earliest opportunity, and within three months, where a substantial change is required. At other times, the latest statement must be available on request.

The statement itself has to cover, among other things, any delegated authority (for example financial thresholds for instructing works), the core services, and target times for taking action on routine and emergency repairs. It also has to set out how homeowners can make enquiries, the timescales for responding in writing and by telephone, and the complaints handling procedure. Section 7 adds that a copy of that complaints procedure must be provided to homeowners on request.

The admin around that document is easy to underestimate: issuing it after a settlement, sending a revised version when the service changes, providing it or the complaints procedure when an owner asks, and then actually following the response times the statement promised.

The complaints procedure has steps, timescales and a written record

Section 7 of the Code requires a factor to have a written complaints handling procedure, applied consistently and reasonably. The procedure must include the series of steps a complaint must pass through and the maximum timescales for each step. Good practice, the Code says, is a two-stage process; that is guidance, not a substitute for the timescales the firm has actually published. The process must, at some point, require the homeowner to make the complaint in writing. It must also tell the homeowner how to apply to the First-tier Tribunal if the complaint remains unresolved when the process has concluded, explain how the firm will manage complaints about contractors or other third parties it uses, and, where the firm offers alternative dispute resolution, give information about that.

When the in-house procedure has been exhausted without resolving the complaint, the final decision should be confirmed in writing. A factor must not charge homeowners for handling complaints unless that is explicitly provided for in the property titles. All correspondence relating to a homeowner's complaint must be retained, electronically or on paper, for at least three years from the date the first complaint was received.

Section 2 of the Code, on communication and consultation, sits beside that procedure. A factor should respond to enquiries and complaints within the timescales in the written statement, and should keep the homeowner informed if it cannot respond within the agreed time. The factor must take all reasonable steps to ensure its registration number appears on documents sent to a homeowner.

mygov.scot's guidance for factors is plain: the firm must have a written complaints procedure and give it to homeowners. Homeowners can complain if the factor fails to meet the Code, does not follow the written statement of services, or does not comply with their title deeds.

The bottleneck is the log, not the legal judgement. A complaint has to be recorded, acknowledged within the time the statement promised, moved through the published steps, answered in writing at the end, and kept for three years. A holding note when the firm cannot meet the agreed time is part of the same job.

If the procedure is exhausted, the next step is the Chamber

mygov.scot tells homeowners to follow the factor's complaints process in writing, and to keep copies. If they are not satisfied, they can apply to the First-tier Tribunal for Scotland (Housing and Property Chamber). The application is free. The tribunal will only accept it once the factor's complaints process has been completed, and the homeowner must include copies of the complaints, any responses, and a copy of the written statement of services if they have one. For issues on or after 16 August 2021, the form is C2.

mygov.scot's factor-facing page adds that the firm will be able to respond, and that if the tribunal agrees with the homeowner it may issue a Property Factor Enforcement Order, telling the factor what it must do to fix the issue.

That is a different application from a letting-agent Code of Practice case, even though both are heard in the same Chamber. The operational lesson is the same: a missing statement, an unanswered complaint, or a file that does not show the published timescales is what a thin file looks like when the form arrives.

Register details have to be kept current, including on the documents that go out

mygov.scot's guidance for property factors is specific about what "registered" requires after the first application. The firm must update its details if they change, provide an annual update of the properties it manages, and include its registration number on all documents it issues to homeowners. Registration must be renewed every three years. It is against the law to operate as a factor without being registered.

Section 13 of the Property Factors (Scotland) Act 2011 requires a registered factor to take all reasonable steps to ensure that the property factor registered number is included in any document sent to a homeowner. For communications sent or placed on or after 1 April 2026, that duty also covers any other communication in relation to the factor's activities, including electronic communications.

Those are not software features. They are the framework the complaints file has to fit: a current registration, a number on the documents that go out, and a written statement the firm can actually produce if it is asked for one.

What an AI coworker does on complaints and the written statement

Your team works with Lorework in chat. You can require approval before it writes or submits anything. Follow-ups, checks and owner updates can run as scheduled, recurring tasks.

Typical starting bottlenecks in a Scottish factoring firm are:

Issuing the written statement of services after a settlement, or a revised statement when the service changes, and providing the statement or the complaints procedure when an owner asks.
Logging a complaint, acknowledging it within the timescales in the written statement, and sending a holding note if the firm cannot meet the agreed time.
Moving the complaint through the published steps, confirming the final decision in writing, and keeping the correspondence for at least three years.
Checking that the property factor registered number appears on documents issued to homeowners, and that register details and the annual property list are not left to drift.
Recurring checks, such as a weekly sweep of open complaints with no recent owner update, or statements still due after settlement.

Lorework does not register the firm, draft the written statement of services, decide a complaint, or handle a tribunal application. Those stay with the firm. It takes on the admin around that work.

How you teach it the way your firm works

You do not have to write a technical specification. Your team teaches Lorework your procedures and templates, in chat, the way you would brief a new starter — a written-statement issue, a complaint acknowledgement, a holding note, a final decision letter. You can ask it in chat, or set recurring work on a schedule.

It works in the web systems you already use, on its own computer. There is no need to rip out the systems you already run. The property factor registered number still has to appear on documents issued to homeowners, in the way the firm already does it.

How a firm starts

Start with one routine job, such as issuing the written statement after a settlement or the acknowledgement loop on a new complaint, not a wholesale change of tools. Add the procedures and templates Lorework should follow. A 30-minute demo is enough to walk through that job and see how Lorework would take it on.

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Questions

What can an AI coworker do with factor complaints and the written statement of services?

It takes on repetitive admin such as issuing or chasing a written statement, acknowledging a complaint within the timescales in your statement, sending a holding note if those times cannot be met, and keeping the correspondence the Code requires the firm to retain. Your team teaches it those processes by chat. It does not replace the factor's duties under the 2011 Act or the Code of Conduct.

Can it draft the written statement, decide a complaint, or deal with a tribunal application?

No. Lorework does not draft the firm's written statement of services, decide whether a complaint is upheld, or handle an application to the Housing and Property Chamber. Those stay with the firm. It takes on the admin around that work.

What timescales apply to a complaint?

The Code requires the firm's written procedure to set out the steps a complaint must pass through and the maximum timescales for each step. Section 2 also expects the firm to respond within the timescales in the written statement, and to keep the homeowner informed if it cannot. Those timescales come from the firm's own statement and procedure, not from a generic service-level figure.

What should be in the file if a homeowner applies to the Housing and Property Chamber?

The tribunal will only accept an application once the factor's complaints process has been completed. The homeowner must include copies of the complaints, any responses, and a copy of the written statement of services if they have one. For issues on or after 16 August 2021, the form is C2. The application is free. A complete factor file is what makes that process manageable.

Do register details have to be kept up to date as well?

Yes. Registered factors must update their details if they change, provide an annual update of the properties they manage, include their registration number on documents issued to homeowners, and renew registration every three years. From 1 April 2026, the registered-number duty also covers other communications about the factor's activities, including electronic communications.

How does a firm start?

Start with one routine job, such as issuing the written statement after a settlement or the acknowledgement loop on a new complaint, not a change of systems. A 30-minute demo is enough to walk through that job and see how Lorework would take it on.