Consequences and
Flaws of the Certificate
of Completion and
Compliance – Comparative
Analysis with Proposed
Solutions 1
By Datuk Professor Sundra Rajoo
The aim of this report is to undertake an
objective analysis of the implementation of
the Certificate of Completion and Compliance
(CCC) in 2007 which was aimed at replacing
the Certificate of Fitness for Occupation (CFO)
previously issued by the local authorities under
the Street, Drainage and Building Act 1974
(SDBA).
Under the former system, the CFO was issued by
the Local Authority (LA) under the Uniform By-Laws
of the Street, Drainage and Building Act 1974 (Act
133). The rationale behind the change was that
the former system was overly cumbersome, time-
consuming and subject to abuse.
It was not unusual for inordinate delays
to occur due to many factors including: non-
compliance by the developer for the submission
of Form E and its enclosures to the LA, additional
conditions imposed by the LA at the time of an
application for the CFO, the involvement of many
technical agencies and the lack of technical
officers to process the CFO.
Purchasers of proper ties encountered
numerous problems whenever vacant possession
was delivered to them by developers and the
1
purchasers could not occupy or renovate their
properties because the CFO was not issued.
Back in 2007 when the CCC was implemented,
self-certification, self-regulation, cutting down
red-tape and corruption were intended to be the
plausible solutions for the problems posed by
the certification process prevailing at that time.
Bearing these in mind, the new system was
proposed and eventually implemented.
Due to unending complaints particularly
from developers that the local authorities were
not adhering to the directives that had been
issued, the Government was concerned that
such apprehensions would presumably translate
into a loss of votes at the ballot box. Hence,
the Government approached the problem
with the implementation of the CCC. This was
intended to rejuvenate the public’s confidence
and to give assurance to the public that the
newly implemented procedure would be more
streamlined and structured.
However, 10 years into its implementation,
the CCC has proven to be more of a bane
than a boon. The reasons for this are many.
For starters, the Principal Submitting Person
(PSP) holds numerous responsibilities and
‘The Certificate of Completion and Compliance (CCC) In the Building Industry — Bugbear or Bunkum?’ by Ir. Harbans
Singh and Sundra Rajoo [2008] 1 MLJ cix.
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