Cooperative apartments: entrance - ruble, exit - two.

By becoming a member of the cooperative, you do not have to pay a high interest rate on the loan. The missing amount of money is provided to you not by the bank, but by other members of the organization. How profitable is this?

Alternatives to mortgage schemes were practiced in Russia back in the 19th century. At that time, a group of enthusiasts organized a so-called “cooperative” and, on their own, bought or built an apartment in a certain house for each of its members. This is where the concept of a “cooperative house” came from, that is, one that was built with collective money. As a rule, in the future the cooperative took over the functions of maintaining the house and created its own housing office. Over the past three decades, cooperative houses were at first very popular, then with the advent of mortgages, interest in this type of housing began to fade. And today, when mortgage loans do not look entirely profitable, some are beginning to look for alternative ways to pay in installments for the desired square meters.

Savings scheme

One of the most common alternatives to a mortgage loan today is a housing savings cooperative (HSC). This is a non-profit organization that collects shares from its members and gives each of them the opportunity to buy residential premises. Often these are apartments on the secondary market. The heyday of the emergence of housing savings cooperatives in Russia occurred in 2005, after the adoption of the federal law of December 30, 2004 No. 215-FZ “On Housing Savings Cooperatives”.

The ZhNK scheme is as follows. Anyone who wants to get square meters joins the ranks of the cooperative - all you need is a passport, makes a minimum down payment and undertakes to make fixed monthly share contributions agreed upon in advance for each housing cooperative. The cooperative spends these funds on the purchase or construction of residential premises. Money is also spent on insurance, maintenance, repairs of residential premises, payment of utilities, servicing and repayment of attracted loans and borrowings, payment of taxes, fees and other obligatory payments.

When the total amount of invested funds is about 50% of the cost of housing and the required accumulation period (minimum 2 years) is completed, the cooperative member receives funds from the general fund to purchase housing for himself. He returns the remaining money within 10-15 years. As soon as he has fully paid off the cooperative, the housing becomes his property. The apartment remains the property of the cooperative until the borrower pays the full cost of the housing.

The popularity of residential mortgages is at least two orders of magnitude lower than that of the mortgage market. In conditions of high inflation, the amount of contributions required to obtain housing grows by 20-30% per year, and the risks associated with the functioning of such cooperatives themselves are high. These are, in fact, analogues of small enterprises, which are more difficult for the state to control than large banks interested in establishing long-term reliable contacts with financial authorities.

What is a housing cooperative?

Housing or housing-construction cooperatives were known in Soviet times, then such associations were about as popular as mortgages are now.

According to Article 110 of the Housing Code of the Russian Federation, a housing cooperative (or housing complex) is a voluntary association of citizens who use their own money to build an apartment building and then manage it.

Technically, it looks like this: there is some developer who is ready to build a house, but there is not enough or no money for it. Such a developer is hired by several citizens who give him money to build them a house.

From the outside it looks like an Equity Participation Agreement, but this is not entirely true; there are differences in these two schemes:

  1. legislative regulation: housing cooperative agreements are regulated by the housing and civil codes, and DDU additionally by Federal Law No. 214;
  2. registration in Rosreestr: housing cooperative agreements are registered only after the entire amount for the apartment has been paid and construction has been completed, and residential building agreements must be registered immediately after signing;
  3. cost of housing: the housing cooperative may include a clause on revising the cost of housing at the time of completion of construction, but this is prohibited in the housing cooperative;
  4. payments - under a housing cooperative agreement, payments can be made after the delivery of the object, but under the DDU, everything must be paid before the object is handed over;
  5. legal protection: for housing cooperatives the Law on the Protection of Consumer Rights does not apply, but for DDU it does.

That is, from the legal side it turns out that the housing cooperative construction agreement has more disadvantages than advantages. And preschool education is not the safest option, and housing cooperatives are even more so.

Advantages and disadvantages

Despite everything, there are a number of advantages of ZhNK over mortgages. First of all, these are low interest rates on borrowed funds. The rate on a ruble loan in a cooperative is 5-7% per annum versus 12-19% in commercial banks. Also, additional costs when obtaining a loan will cost you much less. For example, a down payment in a bank is 15-20% of the cost of an apartment, but in housing and communal services you need to deposit no more than 15-20 thousand rubles. In addition, when joining a cooperative, you do not need to collect stacks of documents for a loan and confirm your income - according to the law, ZhNK has no right to demand this. There is another nice bonus. Members of the housing cooperative have the opportunity to count their existing housing or, for example, a housing certificate as a contribution to the cooperative.

One of the disadvantages of ZhNK is the limited loan period. For example, to get an installment plan for 10 years, you need to maintain an accumulation period of 6.5 years, for 15 years - 10 years, etc. This restriction prevents members from receiving new housing immediately by paying only part of its cost. In commercial banks, the loan repayment period can reach up to 30 years. In addition, until the full payment of financial assistance received from the housing cooperative, a member of the cooperative is not the owner of the housing.

Cooperative apartments: entrance - ruble, exit - two.

The forgotten, but very popular in Soviet times, scheme for purchasing housing through a cooperative began to be discussed again in the early 2000s. Then, through the housing cooperative (housing and construction cooperative), those who did not immediately have the full amount bought apartments. In conditions when prices were constantly rising, this method of acquiring real estate seemed reasonable, especially since it was possible not to resort to expensive bank loans, but by joining a cooperative, then, for many years, paying off the interest-free balance. However, the machinations of cooperative leaders and the subsequent series of high-profile court cases, as well as the tightening of legislation, did their job, discouraging Russians from joining housing cooperatives. However, this purchase scheme did not sink into oblivion, but declared itself with renewed vigor in 2010, after the adoption of amendments to Federal Law No. 214. Today we will tell you what a housing construction cooperative is, how it works and on what conditions, what are the rights and responsibilities of both parties and whether this scheme should be trusted.

Born in USSR

A housing construction cooperative is a voluntary association of people for the purpose of construction, reconstruction and management of an apartment building. In fact, housing cooperatives are a product of the Soviet era. The first cooperatives, according to Maria Litinetskaya, the general director, appeared in the 20s of the last century. However, already in 1937 they were eliminated as a manifestation of private property. Only 20 years later, by decision of the CPSU Central Committee, the cooperative was revived. It should be noted that at that time the housing cooperative built housing at the expense of shareholders, but at the same time received impressive loans from the state for up to 20 years and other benefits. Despite the fact that cooperative apartments were quite cheap, the share of housing cooperatives in the total volume of housing construction in the USSR did not exceed 7-8%, since in order to join the cooperative, it was necessary to stand in a long-term queue. Gradually, the attractiveness of housing cooperatives completely disappeared, primarily due to numerous scams associated with cooperatives.

Perhaps this real estate purchase scheme would have remained a relic of the past if it were not for the amendments to Federal Law No. 214 adopted in 2010. As a result, the number of developers who did not want or could not sell housing under the new letter of the law again began to resort to selling housing under participation agreements in housing cooperatives, says Sofya Lebedeva, general director. This is due to the fact that, on the one hand, housing cooperatives allow developers to bypass the law on shared participation and sell apartments before receiving a building permit, and on the other hand, they do not face any fines for delaying the construction of a facility. Now, according to data, the volume of transactions carried out under the housing cooperative scheme is about 20% in Moscow and 8% in the region.

Housing cooperative begins with the charter

Before joining a cooperative, you need to know that the legal regulation of the activities of housing cooperatives is ensured by Art. 116 of the Civil Code of the Russian Federation “Consumer cooperative”, as well as the fifth section of the Housing Code of the Russian Federation – “Housing and housing-construction cooperatives”. However, as Sofia Lebedeva notes, this legislative act contains only the most general rules regulating participation in cooperatives. Therefore, the charter of the housing cooperative and the concluded agreement are important.

How is a housing cooperative born? The decision to organize a housing cooperative is made by a meeting of founders, and virtually any person can be the founders. Thus, the Housing Code only says that “persons who wish to organize” such a cooperative have the right to participate in the meeting of founders. The decision to create a cooperative must be formalized in a protocol, and the housing cooperative itself must undergo state registration and receive a legal entity.

After this, the charter of the cooperative must be formed, which states the name of the housing cooperative, location, describes the activities of the cooperative, the procedure for joining and leaving it. The charter must contain information on the procedure for making and paying share contributions, and stipulate the responsibility of the parties in case of violation of obligations.

The reins of management of the housing cooperative belong to the meeting of members of the cooperative. They also elect the board of the cooperative, which monitors the current activities of the housing cooperative, and the audit commission, which regularly checks the financial and economic activities of the cooperative. The commission provides the report of its inspection to the general meeting of members of the cooperative in the annual report.

Easy login

Joining a housing construction cooperative is quite simple. To do this, you need to write an application for admission, which will be considered by the general meeting of members of the cooperative within a month. After receiving an affirmative decision from the moment of signing the charter and paying the entrance fee, you become a member of the housing cooperative. However, a member of the cooperative can receive a certificate of ownership of the apartment only after the share amount has been paid in full.

A member of a housing cooperative may leave the cooperative by writing a corresponding statement. If, at the time of leaving the housing cooperative, he has not fully paid his share contribution, then the amount previously paid must be returned to him. However, the terms and conditions for the return of money must be specified in the charter of the cooperative.

High risks

Like any scheme for purchasing real estate on the new buildings market, housing cooperatives have their pros and cons. Among the advantages, two can be noted. Firstly, unlike the DDU (share participation agreement), you can enter a housing cooperative at the age of 16 years. It is clear that no bank will give a mortgage loan to a 16-year-old borrower to pay the down payment on a prepaid loan. Secondly, the cost of the share can be repaid by the cooperative member over many years, without paying high interest, as is the case with a mortgage.

However, this is where the advantages of housing cooperatives end and serious disadvantages begin. As Maria Litinetskaya notes, when purchasing an apartment using this scheme, there is a much greater risk of being left without housing or with an apartment of poor quality. For example, the expert says, the nuance is that the decision to move in a shareholder is made at a general meeting of members of the housing cooperative. In practice, this means that even if the buyer has paid the share in full, he may not receive the long-awaited apartment if the settlement for some reason was not approved by the general meeting.

In addition, unlike the DDU, the housing cooperative is not obliged to eliminate the identified shortcomings and construction defects. When purchasing through a cooperative, you can obtain a certificate of ownership only after the share amount has been paid in full. This leads to the fact that a house can be rented out, an apartment can be obtained, the buyer can live in it for several years, and at the same time he does not have the right to receive a certificate of ownership.

Another danger is that a shareholder has the right to be excluded from a housing cooperative without explanation, and this does not contradict current legislation. If a member of the cooperative did not pay the share contribution and was expelled from the housing cooperative, then his apartment may be taken away.

The shareholder also has monetary encumbrances. Firstly, everyone who is part of the housing cooperative is required to pay membership fees - entrance and monthly. Secondly, if the cooperative did not have enough funds to complete the construction of the facility, then all members of the housing cooperative are responsible for the debts of the cooperative. Thus, if the construction estimate increases, shareholders will simply have to contribute additional funds. The fact is that the agreement on participation in the housing cooperative does not always fix the final cost of the apartment. But even if it is named in the contract, the cooperative can unilaterally change it.

Your money was crying

But sometimes cooperative members face even greater problems. Thus, there are quite frequent cases in the market when cooperatives were created to carry out fraudulent schemes. In addition, the purchase of housing under construction under this scheme does not protect the buyer from double sales, since in this case the transaction is formalized through the purchase of a share with the payment of a share contribution and is confirmed only by an act issued by the housing cooperative.

In addition, when purchasing a new building, there is always a high risk of bankruptcy of the developer or non-compliance with the construction schedule, and, consequently, delays in the delivery of the project. When buying an apartment through a housing cooperative and in the event of the developer’s bankruptcy, it will be very difficult to get your money back or to achieve the resumption of construction of the house, states Maria Litinetskaya.

As we said earlier, the mutual responsibilities of the parties must be spelled out in the charter. The problem is that, in accordance with clause 113 of the Housing Code of the Russian Federation, the charter must necessarily indicate the responsibility of shareholders for late payment of contributions, but the cooperative’s obligation to its members may not be specified. Therefore, if in accordance with paragraph 2 of Art. 113 of the Housing Code of the Russian Federation, the cooperative’s charter included its responsibility to shareholders, that is, the opportunity to return money through the court. At the same time, the failed new resident will not receive any interest for the use of your funds, as in the case of a DDU. If there is no such clause in the charter, then even in court it will be almost impossible to return the contributed share.

The actions of housing cooperatives, of course, are regulated by law, and when selling housing under construction under this scheme, the developer acts within the framework of the law. However, Sofya Lebedeva warns that when purchasing an apartment through a cooperative, the buyer is legally protected much worse than someone who buys housing under a DDU concluded in accordance with Federal Law No. 214 and even in some aspects worse than under a preliminary or investment contract.

Risks and alternatives

Collective liability for possible losses does not allow for claims to be made directly against the organizers of housing cooperatives; inflation and financial risks themselves are not controlled by the shareholder. Such a system works at a low level of inflation, low growth rates of housing prices and in conditions of a stable system of investment risk control, built, for example, in Germany. But even there, the risks of accelerating inflation in the coming years will likely reduce the attractiveness of such structures.

There are other alternatives to mortgages, for example, a credit consumer cooperative of citizens or a consumer loan. Experts recommend paying attention to risk-free ways to obtain housing loans. For example, accumulating funds in a bank account, investing these funds according to your knowledge and skills in various financial instruments or in real business.

Sravni.ru advice: If you do not have the opportunity to join a cooperative, then get a mortgage. Find lowest down payment deals with this mortgage calculator.

How to choose a housing cooperative?

There are many housing construction cooperatives, but as a developer, you also need to choose the right one.

Four factors to pay attention to:

  1. general legal information - date and place of registration, Unified State Register of Legal Entities, records in the Central Bank. This data can be obtained from the Federal Tax Service, it is not publicly available;
  2. internal documents - charter, rights and obligations of shareholders, maybe even a standard agreement. These are documents of the cooperative; they are not publicly available, but upon your request they are required to provide them;
  3. reputation on the Internet - reviews, website, perhaps there are company pages on social networks. It is better to look for reviews on thematic forums or in social network groups, since they can be custom-made on the website;
  4. cooperation with banks - will it be possible to get a mortgage? If yes, then in which banks, under what conditions.

It’s a good idea to choose a housing cooperative based on a personal recommendation. For example, one of your loved ones has already rented an apartment there, there were no problems, so you can take note.

List of required documents

When buying an apartment in a housing cooperative, you must know the list of the most necessary documents that are needed to conduct a sale transaction . Here are some of them:

  1. A certificate from a specific cooperative, which indicates that the owner of the property has paid all contributions.
  2. Extract from the house register (a copy, not the original).
  3. Documents identifying the owner of the apartment (passport, driver’s license, etc.).
  4. Certificate certifying the state registration of the right.
  5. Cadastral and technical passports.

Purchasing an apartment under a housing cooperative agreement

In the real estate market, in particular residential real estate, developers have been inventing and implementing various sales schemes for several years in a row. For example, a preliminary purchase and sale agreement, an agreement of entry and initial contribution to a cooperative, an agreement of intent, and so on.

But it is worth noting that not all methods of developers to obtain a potential buyer are harmless and legal.

As for the housing cooperative agreement, it should be said that it is not regulated by government agencies according to the laws of the Russian Federation . This means that there is a high risk of double or even triple home sales.

This procedure may also require certain financial expenses.

In the case of a person who wants to purchase a new apartment in a new building, membership in a cooperative may be an attractive option.

Indeed, in this case, the developer has to comply with the laws, but also take into account the opinion of the members of the housing cooperative.

But at the same time , the legal entity bears responsibility, including the financial aspect - monthly fees, participation in a meeting of residents of the house, choice of local government, etc.

HELP : This form can be an obstacle for people who want to take out a mortgage. Not all banks provide mortgage loans for housing cooperatives.

But if the developer is on good terms with the bank and has a positive reputation , then this action is quite possible.

I would also like to note the undeniable disadvantages associated with membership in the housing cooperative . Namely:

  1. A person can take risks, since the main goal of forming an organization is to build a house for some reason, which is impossible or will not be carried out in the near future.
  2. Increase in prices for the construction of apartment buildings.
  3. If, for one of the reasons, the deadline for the construction of real estate has passed due to the fault of the cooperative, then it cannot be held responsible to its own citizens.
  4. Developers or investors do not bear any guarantees to homeowners.
  5. Annual control over the financial and technical work of the housing cooperative is carried out only by an electoral audit commission, which is elected by company members. There is no official government body in the case of cooperatives.

The risks that are given in the example above directly affect human rights, especially if the cooperative is in some way connected with investment or construction firms that are involved in the construction of a particular house. In this case, the negative risks increase several times.

Now, let's talk about the relationship between mortgages and housing cooperatives.

Comparison with other similar types of acquisition

Participation agreement

An equity participation agreement (EPA) implies an agreement between the developer and the shareholder, which means the investment of financial resources in equal shares for the construction of a residential apartment building and the transfer of a specific apartment by the developer to the owner after completion of construction.

The advantages of DDU include protection of the owner from double sales, transparent documentation and the right to terminate the contract with subsequent compensation for damage caused. Shared construction is usually cheaper than buying ready-made housing.

Mortgage

It is known that mortgage lending is a burdensome way of obtaining housing for an ordinary person.

Today, a mortgage provides a good opportunity to purchase your own real estate, but in its essence it is an enslaving way . In fact, it turns out that the apartment is purchased at double or even triple the price, depending on the period for which the loan was issued. There are also certain difficulties with the initial payment, which for an ordinary person is not so small.

The main difference between a residential complex and a mortgage is that after accumulating the down payment, the shareholder receives the missing amount as a loan, and not as an interest-free loan, and pays it off within a certain period.

Until the debt is fully repaid, the owner has only a share, which he can bequeath, sell or donate. However, in a cooperative, housing is owned by the community until the last moment, which means the situation may not develop in favor of the unlucky member.

According to the mortgage agreement, a person initially receives ownership of the property , but if his financial situation suddenly changes for the worse, the bank may initiate legal proceedings and attempt to repossess the apartment.

Timing and cost

Based on the data that you can read on the Internet or ask lawyers, you can say for sure that buying an apartment in a housing cooperative is the most dangerous option . No, of course, it has its advantages, but cooperatives are the most favorite place for profit among unscrupulous developers. Absolutely any person who agrees to become a member of a cooperative is taking a very big risk.

As for the cost of housing in the case of a housing cooperative, this is very difficult to understand: according to the laws, if the cost of an apartment is specified in the contract, then the developer has every right to unilaterally change it as he pleases. The legislation of the Russian Federation, in this case, is on the side of the developer.

The timing of the commissioning of an apartment building and its subsequent registration may also be unknown. The developer, again, can postpone and extend the construction date as much as his heart desires. People who have purchased certain housing in the building can only wait.

The risks of buying an apartment in a housing cooperative are presented in this video:

When changing housing, the question always arises: “ What authorities can help in the event of a purchase and sale transaction ?” Here is some list:

  1. House management.
  2. Inspectorate of the Federal Tax Service.
  3. Unified Information Settlement Center (UISC).
  4. Bureau of Technical Inventory (BTI).
  5. Guardianship and trusteeship authorities.
  6. Public housing commission under the municipal district.
  7. Internal affairs bodies.
  8. Office of the Federal Registration Service.

To summarize, I would like to repeat that searching for and subsequent purchase of housing in connection with cooperatives is not the best prospect .

There have been many cases in history when people placed too much faith in a company and seemingly friendly developers. Then they lost their property, earned money, long-awaited apartment and were left with nothing.

Therefore, before you start looking for the desired home, you should ask for advice from a qualified lawyer and notary.

Why is this so?

The question arises: why are people so easily fooled? Why don't they see obvious things?

There are two aspects here:

1. Outwardly, everything is within the framework of the law: the concept of “housing cooperative” is regulated by law, in particular Chapter 11 of the Housing Code.

2. Psychological moment. People are accustomed to scammers asking for something, but here, on the contrary, they offer it. Moreover, not just anything, but an APARTMENT in installments without overpayment! Well, how can you refuse?

What it is

Cooperative apartments were common in the USSR, and they were built in the 90s. From the moment a member of the cooperative paid a share for the apartment, it became his property.

Funds for the construction of an apartment building (hereinafter referred to as MKD) were allocated by the state in the form of a loan, which citizens repaid within 15 years after completion of construction. Soviet cooperatives operated on the basis of enterprises; the members of such citizen associations were employees of the enterprise.

Shares for such housing were paid a long time ago, and today cooperative apartments are no different from other, non-cooperative apartments.

Transactions with such apartments take place according to the laws of the secondary market.

How to register ownership

Owners of cooperative apartments just need to get a certificate that the share has been paid and on this basis register the right in the Unified State Register of Real Estate.

No additional documents are needed - the apartments were registered by the BTI, and from the BTI data the information was included in the Unified State Register of Real Estate.

Further transfer of rights is carried out under ordinary contracts of sale, gift, exchange, etc.

Read how to correctly draw up an apartment purchase and sale agreement here >>

How to inherit

An inheritance for a cooperative apartment is opened in the same way as for any other. Within six months after the death of the testator, you must contact a notary.

If the heir has not actually accepted the inheritance, then it is necessary to go to court. If the inheritance in the form of an apartment was actually accepted, the heir will be able to register ownership without court.

How they tried to lure me into a credit cooperative

One day I received a call with an offer of a very profitable cooperation - to offer my clients apartments in installments without overpayments, and also receive a percentage for it! What should I do? People ask to come to the meeting and look very carefully at the incredible offer.

We activate the mode of a naive Chukchi boy, exchange an expensive suit for a sweater from a second-hand store and forward to a bright future and a percentage of each transaction.

At the meeting they quickly explained to me that the scheme is called joining a housing cooperative, a person pays “very insignificant” (a little more than 300,000 rubles) entrance fees, then pays either 35% or 50% of the cost of the purchased property, waits his turn within six months , gets an apartment and pays the balance in equal payments over 10 years without any interest.

Then, abruptly from the legal and economic part of the question, we move on to the topic of self-aggrandizement... Bright brochures, stories about more than a thousand happy members who have joined the cooperative, who have already received their apartments, about how inspections of the prosecutor's office, the Central Bank, the FSB, the GRU, and the Russian Post are successfully carried out and sanitary and epidemiological stations.

And they quietly tell me the most valuable information that for each client I refer I will receive a commission of up to 1000 EUROS... (they probably expected that now the calculator in my head would go crazy from these incredible numbers).

In simple words, they tried to talk my teeth into it, so that behind all this tinsel of brochures and regalia the essence of the issue would not be visible. So that in pursuit of profit, I (like, in principle, any person) should lose my head and quickly sign everything that is handed to me. Naive children of Chukotka...

To begin with, I decided to turn on the “slowdown” and ask leading questions, as if in order to fully understand...

In appearance, indeed, everything looks good: a person signs an agreement to join a housing cooperative (HC), deposits money, and subsequently receives an apartment, for which he pays in installments without interest!

But! The apartment is bought in the name of the residential complex, that is, in the purchase and sale agreement and, as a result, in the extract from the Unified State Register of Real Estate, the owner is listed as the residential complex, and not the person who gave his money. Of course, a person does not appear at the level of documents registered with the Federal Registration Service, i.e. in fact, he IS NOT THE OWNER OF THE REAL ESTATE. All his relations with the residential complex are regulated only by an internal agreement with the residential complex.

Here I ask the first awkward question:

“Comrades, please tell me what prevents the chairman of the residential complex, who has the right to sign without a power of attorney, from simply taking and at one moment selling all the apartments that are on the balance sheet of the residential complex? In fact, he did not invest a penny from his own pocket into these apartments - it was all the money of the shareholders. Plus, the money available is in an account to which he also has almost sole access. After all, he can also withdraw this money through shell companies. And with all the money: both from the account and from the sale of apartments - go to some prosperous country that never extradites criminals? Yes, it will be an absolute scam, but there will be no one to ask! The person is gone, the apartments have new owners!”

And then I heard an argument that almost made me go into hysterics with laughter: “What are you talking about! This is an honest person who would never dare to do such a thing! Moreover, according to the charter, he must ask all shareholders (you don’t even have to stutter about the approval of a major transaction.”

As you yourself understand, any attempts to point out that a legal entity has the right to dispose of its property (and as we found out above, the apartment belongs to the legal entity, and not to the citizen), ran into an impenetrable wall of complete illiteracy.

Then I asked the following question: “Comrades, suppose I fit into this, the apartment costs 5 million, 2.5 -

mine, 2.5 is yours, so I take 2.5 million from you and give back 2.5 million in 10 years. A reasonable question arises: have you heard anything about inflation? Or does it not apply to your superstructure?”

As you yourself understand, populist slogans about an army of lawyers and accountants who have calculated everything began to pour in again. Naturally, I did not receive a legally valid answer.

In principle, this was the end of the meeting, except that, naturally, I was accused of incompetence and excessive suspicion, I was also told that they felt sorry for my clients, whom I was depriving of the unrealistic opportunity to buy an apartment without unnecessary overpayments, and I was dooming them to mortgage slavery.

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