13 November 2010

Casino Singapore 1: Who's the idiot? Citizens/Gahmen lost Big Time

Who turned this little red dot into Casino Singapore?

1. Who is the idiot? On 4 Nov 2010, after giving a speech at the inaugural forum, "A Free Press for a Global Society" at the Columbia University, Minister for Law, Mr K Shangumam, said the following during the Q and A session:

"The point is this, if you actually sit down and look at what is it that is needed for a healthy, robust debate in public life. You want to talk about issues, you want to talk about what the government is doing right or wrong. How people can offer a different perspective, what are the different viewpoints there are, ALL OF THAT IS FAIR GAME. The point about the classic common law defamation theory is that when you descend into a personal attack against someone and it’s not comment. YOU CAN CALL SOMEONE AN IDIOT, HE CAN'T SUE YOU FOR THAT. YOU CAN MAKE A WHOLE LOT OF COMMENTS ABOUT A PERSON, YOU CAN CALL HIM INCOMPETENT, HE CAN'T SUE YOU FOR THAT, but if you make a personal factual allegation, “he stole”, or “he is corrupt” then the real issue is, should the press be given any greater privilege to make those allegations compared with an individual? [Capitalization emphasis is by The Pariah.]

After you read this blog posting about corporate disclosures, I wonder who will you call "an idiot" ... could it be me? It's OK - I won't sue. I can't sue anyway - so my Law Minister tells me.

2. Who increased net profit by 666% in FY2009/10? Yes - 666% increase in NET profit! I'm not kidding (and let me assure you that I am not even into biblical revelations of any genre). Before reading on, you may want to slip on your sunshades (and whatever else that can be slipped on) and lug along your binoculars because the figures are bedazzling eye-poppers in this financial striptease:

Awwwww ..... Shock and Awe:
Who makes this kind of profits in this little red dot?

(a) "profit before taxation for 3Q 2009 improved significantly by 126%"
Allgreen, 2 Nov 2009

(b) "profit after tax and minority interests (PATMI) increased by 76.7% ... in Q4 2009"
City Developments Ltd, 25 Feb 2010, who also described it a week later as: "... the year was also a record one of sorts, as it achieved its highest-ever full-year revenue ... and the second-highest-ever net profit".

(c) "144% surge in net profit ... for the financial year ended 31 December 2009"
Heeton Holdings, 24 Feb 2010

(d) "net profit after tax and minority interests ... for nine months ended 30 Sep 2009, up 259%" and "net profit after tax and minority interest ...for the full year ended Dec 31 2009, up 262%"
Ho Bee Group, 12 Nov 2009 and 12 Feb 2010, respectively

(e) "417.9% y-o-y surge in net profit for 2Q"
SC Global, 23 Aug 2010

(f) "net profit for 2Q2010 ended Dec 31, 2009 surged 220% y-o-y" and "posted a 173% y-o-y jump in net profit ... for FY2010"
Sim Lian Group, 15 Feb 2010 and 30 Aug 2010, respectively

(g) "net profit attributable for the six months ended Nov 30, 2009 (HY2010), rose 129.2%"
Tee International, 8 Jan 2010

(h) "188% rise in net attributable profit ... for the financial year ended 31 December 2009 with revenue crossing $1 billion for the first time"
UOL, 23 Feb 2010

(i) "for the half year ended Dec 31, 2009 ... group’s operating profit ... an increase of 123%",
"in the nine months ended 31 March 2009 ... operating profit ... an increase of 81%" and
"net profit for the full year ended June 30 (FY2010) rose to $160.75 million from $20.98 million a year ago"
Wing Tai Group, 5 Feb 2010, 13 May 2010 and 23 Aug 2010, respectively

The above examples are based on my random extractions of 9 public listed Singapore companies from The Edge, a business weekly. They span a spectrum of new and entrenched en bloc buyers over past year, high-end and mass market players, small and big developers, some more diversified than others in business focus.

Do read The Edge articles in full and you may immediately recognize the en bloc redevelopments cited therein:

Soooooooo .....
Mirror, mirror on the wall
Who is the fairest of them all?

Answer: Whoever made 666% increase in net profit for the full year. Tsk, tsk ... if you were reading carefully, you would have found the answer above. [Hint: Please re-read item (i).]

3. Casino Singapore. With property prices racheting up at such rates to yield net profit of triple-digit percentage gains for developers, ... when Owners sell at so-called "en bloc premium" to earn so-called "en bloc windfall" at $xxx psf only to see Developer-buyers soft-launch the redevelopment at three times (!!!) $xxx psf a few months after collecting en bloc sale proceeds, ... when the super Majority Consenters realise that the pre-en bloc promise of Utopia has landed them in Ethiopia post-en bloc, ... when the law has MAJOR structural flaws, viz, (i) locks-in Reserve Price for up to 12+12=24 months in a likely upward-moving volatile market, (ii) opens side gate when public tender fails to allow NON-expert Sale Committee volunteers to sign private treaty with expert Developer-buyer in the back-room and tell Owners only AFTER the deal has been signed, sealed and delivered and (iii) prohibits the super Majority from filing any objection to Strata Titles Boards/the courts, ... when the super Majority therefore have no choice but to keep mum and lump the "en bloc shortfall" as they are already cooked, ... when such "en bloc shortfall" will continue to haunt the super Majority Consenters 15-20 years later into their twilight years because of too-early monetization of their only crown jewel, ... and when my pet camel mutated into a 3.5-hump monster within a mere 1.5 decade (from 1995-2010), another question arises:

Do we just have two casinos? Or have we willy-nilly morphed into "The Biggest Casino in the World" at 710.3 sq km (Singapore's area size as of 2009 - Department of Statistics)?

It was reported in the Straits Times (12 Nov 2010) that for 3Q2010:

- Resorts World Sentosa: S$732mn revenue; S$346.5mn pre-tax profit; 47% profit margin
- Marina Bay Sands: S$631mn revenue; S$315mn pre-tax profit; 49.7% profit margin

Yawn ... the figures in casinos are just not as sexy and seductive compared to developers!

4. Contextualized against a time-scale. 666% increase in net profit, or 417.9% surge, or up 262%, or 188% rise ... are they obscene or what? Especially when you CONTEXTUALIZE these developers' net profits of such epic proportions to the timescale below. Now, now ... please bear in mind this question as we put things into context: "What were the two factors that likely contributed towards such obscene profits by the developers?" ... and let's see if your answer matches mine.


- Many of these developer companies pre-existed LTSA inception of Oct 1999 but they achieved such record highs only in FY2009-10 - SO WHAT CHANGED?

- Published articles span a near-year of 2009/10 to give a more representative perspective

- Second bout of en bloc frenzy started in earnest in 2006 and peaked in 2Q2007

- Typical two-three year lag time for construction/redevelopment

- Accounting conventions for developers with inherent lag time in income/profit recognition

- Private Residential Property Index first surpassed the last peak only in 2Q2010

- 2008/09 Great Recession triggered by Wall Street meltdown

- 2009/10 Resilence Package of S$20.5bn for FY 1 Apr 2009-31 Mar 2010 with advance roll-out from 22 Jan 2009 and step-down Job Credit Scheme until 30 Jun 2010 where the Gahmen dipped into past reserves for the first time in history for S$4.9bn to fund the Job Credit Scheme and Special Risk-Sharing Initiative

- Corollary to 2009 Resilence Package were (a) corporate income tax rate cut from 18% to 17% for YA2010, (b) tax exemption on foreign-sourced income earned before 21 Jan 2009 and remitted between 22 Jan 2009-21 Jan 2010 and (c) special accommodations for developers, viz:

(i) deferred property tax starting from the later of 22 Jan 2009 or Provisional/Written Permission date,

(ii) one-year extension of Project Completion Period for private residential projects,

(iii) another two-year extension for developers' disposal of residential units, aggregating to a four-year leeway, etc,

all of such special accommodations for developers (together with other mind-boggling and backbending accommodations by MND/URA/BCA in DELAYING THE POLICY IMPACT of withdrawn Deferred Payment/Interest Absorption Schemes (DPS/IAS), withdrawal of Gross Floor Area bonuses, etc) and the "voluntary caveat" loopholes of Singapore Land Authority (SLA) likely contributed to the 3 Nov 2010 STARK EXPOSÉ when URA were caught with their pants down because the figures for expected supply of housing units even within the near future were seriously out-of-whack.

Instead of reaping policy results upon announcement, these super business-friendly civil servants allow developers to piggy-back on building plans long approved by BCA for, say, 100 fancy duplexes even when they revamp the entire project into, say, 700 shoe-box units, but retaining the old GFA bonus for planters/bay windows with consequent startling incongruence. Likewise, developers can significantly delay sales/phased releases under URA extensions and yet hang on to the DPS/IAS competitive advantage under old BCA building plan approval. Flippers and property agents join developers in merrily exploiting SLA's "laxity" by not filing caveats, delaying/timing the filing or even aggregating/misfiling in order to paint a distorted picture about last-done prices, speculative profitability, flipping dominance, etc. Well, the "joke" has backfired on the Gahmen as these super business-friendly civil servants have crossed sides either to sit on the boards of corporate developers or to be on their payroll whilst the rest of us are still scratching our heads as to how deeply and how widely the GIGO-based systems (Garbage In, Garbage Out) of URA/SLA/BCA have skewed statistics and indices. Your guess is as good as mine!

No doubt, there are other multi-factorial justifications for profit hikes of 666%, 417.9%, 262%, 188%, etc (eg, accounting treatment of fair value gains by different companies, contributions from non-en bloc redevelopment, hot money inflows, pre-dominance of Mickey Mouse (shoebox) units sold at astronomical psf price, etc).

That was why I have been advocating since late 2009 that MinLaw should invoke the amended Statistics Act and extract from MAS the data on developer project financing to affirm/debunk allegations and facilitate MinLaw's on-target policy/legislative refinement of LTSA. Alas, it remains a classic Rumsfeldian case of Unknown Unknowns except that the unknowing (whoever that idiot is) doesn't want to know.

5. En bloc gang robbery-cum-rape and looting of public coffers. As for the question posed in Point 4:

"What were the two factors that likely contributed towards such obscene profits by the developers?"

My answer: Developers made obscene profit at the expense of (i) CITIZENS (especially from their en bloc purchases) and (ii) GAHMEN (milking the 2009 Resilience Package).
And what's your answer?

I can't help but wonder how the en bloc gang robbery-cum-rape could have escaped radar detection by our world-class PAP Gahmen who even opened wide the treasury doors, ostensibly WITHOUT conditions, WITHOUT tracking and WITHOUT provision for any clawbacks or nimble re-adjustment. And Finance Minister Tharman wasn't even under the same pressures as Paulson or Geithner at the time! Well, well ... the 75% (or lower?) syndrome inflicts even our very best, eh?

Bottomline: In the sparring practice round in Feb 2010, REDAS (Real Estate Developers Association of Singapore) were slightly outfoxed by the Gahmen when REDAS' pressure tactics to get the Gahmen to disclose Reserve Price for Government Land Sales backfired. But for this major championship fight, it appears that the PAP Gahmen lost Big Time - they have been summarily outclassed by the corporate developers who achieved such sparkling results within the above contextualized time-scale! Developers, being inherently astute, likely merrily milked the maximum out from 2009 Resilience Package even whilst they "cry-father-cry-mother" (literally translated from the visceral "kow bei, kow boo" Hokkien-dialectic expression for "plaintive whining and whinging") about the Great Recession!

Sigh ... that's what happens when the fine line is crossed ... when Gahmen not only got incestuous with Big Biz but also when increasing one-upmanship and internal competition further calcified the already entrenched silo mentality within each ministry, statutory board and government agency. DOUBLE JEOPARDY, DOUBLE WHAMMY!
6. Preview summary of Parts 2 and 3. In "Casino Singapore 2: Who's the idiot?? No to gang robbery-cum-rape", I will set out:
– How and why the en bloc gang robbery-cum-rape was allowed to happen.
– How to counter the gang robber-cum-rapist.


In a way, it's calling their bluff when the Gahmen used national needs for urban rejuvenation and higher land-use intensity to justify passing a law that is calibrated towards such gang robbery-cum-rape. It will give an insight as to why private condos were targetted instead of HDB public housing when land area used for private condos is miniscule relative to that used for HDB public housing and the lessons that Singapore could draw from South Korea, Taiwan and Hongkong in en bloc redevelopment.

In "Casino Singapore 3: Who's the idiot??? Smoking gun with spent bullets", I will attempt to gather the incriminating evidence of such gang robbery-cum-rape although the gang rapist is still virulent and not quite "spent" and is on the prowl again! It will remind us of the hollow parliamentary promise made by MinLaw in 1999 during en bloc law inception that the primary objective of this law was to create "many more housing units in PRIME 999-year leasehold or freehold AREAS FOR SINGAPOREANS".

There are also observations and reflections of “too little, too late, too diffident” approach in formulating and effecting laws, regulations and policies without sufficient checks-and-balances within a holistic framework (eg, tax man consulting tax-payers on a proposed clarification and then withdrawing such proposal). Then you evaluate and decide for yourself whether the former Minister for Law, Prof S Jayakumar, had any basis for his ministerial allegations and fear-mongering attempts, especially when the facts in this 3-part Casino Singapore blog posting affirmed how en bloc law effectively unlocked land value for Developer-buyers, NOT extant Owners who instead face the Hobson’s Choice of being Squatters, Refugees, Downgraders and Downsizers:

Casino Singapore 2: Who's the idiot?? No to gang robbery-and-rape

In "Casino Singapore 1: Who's the idiot? Citizens/Gahmen lost Big Time", I set out how developers chalked up jaw-dropping increases in net profit of 666%, 417.9%, 262%, 188%, etc, for FY 2009/10, viz, two-three years after 2006-2007 en bloc frenzy (i) in the aftermath of 2008-09 Great Recession whilst (ii) in the midst of pay-outs under 2009-10 Resilience Package of S$20.5bn, causing us to plunder S$4.9bn from our past reserves for the first time in history:

1. How and why the en bloc gang robbery-cum-rape was allowed to happen?
As to the first part of the question on HOW the gang robbery-cum-rape was allowed to happen - Answer: By MinLaw getting the RIGHT ANSWER TO THE WRONG QUESTION. Errrrr ... Correction: It's not even the "right" answer, but a "more or less right answer".

MinLaw invoked draconian Majoritianism over private property rights ostensibly to meet the very valid national objectives of (i) urban renewal and (ii) higher land-use intensity. I say "ostensibly" because when 82% of us live in Housing and Development Board (HDB) public housing flats, the proportion of land used for HDB estates is many times that used for non-landed private properties. In addition, as HDB housing programme started in 1960 with most HDB estates being built in the 1980s, there are already issues of estate ageing, functional obsolescence of building materials, low land-use intensity, etc.

So WHY pass such a draconian law to invoke Majoritianism over PRIVATE PROPERTY RIGHTS when the proportion of land used for such non-landed private developments is small, relatively speaking?

Just like any crime story, it gets titillating when you trace back to "motive", eh?

We need to digress a little so as to put things into proper perspective. Now ask yourself this whilst bearing in mind the above context:

Q1: Do we have a massive HDB programme under SERS (Selective Enbloc Redevelopment Scheme)? [Under SERS, Gahmen even go so far as to assure displaced owners of a ready-to-move-in replacement unit around the same neighbourhood vicinity with continuing subsidies but subject to various conditions and relatively modest top-up payment.]

A1: No! SERS is truly selective and is a "privilege" for the select few. Why? Wouldn't it make more sense to embark on a massive SERS because it would IMMEDIATELY and SIGNIFICANTLY improve land-use intensity, bearing in mind that (i) most of our old HDB blocks range from 10-15 storeys with some walk-ups of 4 storeys and some at the then-skyscraper height of 25 storeys and (ii) most of the deluge of PRs and newly minted Singaporeans are NOT of Jim Rogers and Zhong Sheng Jian genre? Why not replicate Tanjong Pagar's 50-storey Pinnacle-at-Duxton all over Singapore, eh?

But instead of massively increasing land-use intensity under SERS, HDB persist in tinkering with urban rejuvenation even as first-time-buyers and no-choice-but-downgraders raise hue and cry as they compete with the deluge of foreign immigrants (including PRs and newly minted citizens) with each exploiting and re-inventing all possible loopholes within HDB's policy framework! Surely, it could NOT be due to HDB's oblivion about what Ministry of Home Affairs (MHA) and Ministry of Manpower (MOM) were each doing in approving all kinds of applications with such zeal and zest when HDB is under the purview of Ministry of National Development (MND)! HDB eventually woke up by asking the RIGHT QUESTION as to "why there were so many HDB flats available for rental" (instead of the previous WRONG QUESTION of "how to control and regulate the rental of HDB flats") ... and a whole host of HDB rule changes were announced on 30 Aug 2010!

Hence, there must be serious advantages for Gahmen to consciously choose the alternative of applying the following slew of HDB upgrading programmes, instead of SERS demolition-cum-replacement (DESPITE the fact that the building materials used in old HDB flats are likely hitting functional obsolescence because of inherently lower quality compared with that used in private apartments/condos that the Gahmen die-die want to facilitate en bloc demolition):

(a) MUP (Main Upgrading Programme),

(b) HIP (Home Improvement Programme) where they upgrade the interior of your HDB flat - this is being piloted in - guess where - Tampines (part of Minister Mah Bow Tan's Tampines GRC) and Yishun (probably part of Prime Minister Lee Hsien Loong's Ang Mo Kio GRC) ... I wonder if in the next General Election the PAP will offer to upgrade your frumpy old mattress to a bouncy new water-bed mattress to induce couples into making more babies,

(c) LUP (Lift Upgrading Programme) - on top of the brazen impropriety of allocating priority for lift upgrading based on the level of votes for a specific political party during a General Election when such upgrading work is funded by national reserves, nobody is querying if it is cost-justifiable to provide lifts in, say, four-storey HDB walk-up flats that serve only 6 more families ... yeh, I'm NOT kidding (now why won't Minister Mah Bow Tan be returned to electoral victory in his constituency when the owner of an old 4-storey HDB flat in Mr Mah's electoral ward gets a near-private lift shared with only one other neighbour on his floor?),

(d) NRP (Neighbourhood Renewal Programme) which will replace the IUP (Interim Upgrading Programme) component of IUP Plus.

To return to the main point about en bloc gang robbery-cum-rape - For the prime/ popular locations where Singaporeans bought private condos - drawing down on their CPF retirement nest-egg saving and hocking themselves to the eyeballs with both husband-and-wife working their 4-globule posteriors off to repay bank loans for the next 20-30 years - the Gahmen passed an en bloc law calibrated to unlock land value - but NOT for extant owners who are the citizens/voters!!!

As to the second part of the question on WHY the gang robbery-cum-rape was allowed to happen -

Q2: What's the "motive" for this en bloc law under the UNHOLY POLITY involving market forces, developers as Big Biz, and almost the entire Gahmen machinery when it impacts only a relatively small proportion of land used for non-landed private property???

A2: This is a two-part answer.

First, because the needs of rich and/or smart Foreign Talent for swanky condos in prime/popular residential districts PREVAIL over the sense of home, of rootedness and of community of Singaporeans. 

Second, because of developers' Big Biz interests, where demolition and redevelopment of prime/popular residential districts are more likely to be astronomically profitable with limited downside risks due to enhanced marketability of such choice locations - as borne out by:

... FY2009-10 OBSCENE INCREASE IN DEVELOPERS' NET PROFIT in triple-digit percentage range for the FIRST TIME in their CORPORATE HISTORY,

... just two-three years AFTER 2006-07 EN BLOC FRENZY,

... with the typical two-three year lag time for demolition/construction culminating in 2009-10 COMPLETION OF REDEVELOPMENT and THE INDUSTRY'S ACCOUNTING CONVENTION OF PROGRESSIVE INCOME/PROFIT RECOGNITION,

... despite 2008-09 GREAT RECESSION,

... which triggered 2009-10 RESILIENCE PACKAGE HAND-OUT.

Is the above argument well-reasoned and reasonably substantiated? It is NOT for me to say. It is for you to evaluate and decide.

By invoking majoritianism under the guise of collectivism, MinLaw hypes upon the "will of a super-majority" of 80% (90% if the estate age is less than 10 years from the date of issuance of the Temporary Occupation Permit). Hence, MinLaw tries to valiantly balance the en bloc law between Majority Consenters (pro-sale) and Minority Dissenters (anti-sale) which is merely a Side Show and NOT the Real Battle.

MinLaw's orchestration of this Side Show has inevitably resulted in the Land Titles (Strata) Act ("LTSA") being SKEWED towards pro-sale.

Pro-sale, by extension, is therefore pro-developers. [Yawn ... what else is new? Progressive Corporatism as a form of expedient governance - as we all know the unspoken open secret.]

As en bloc transaction is a sale, the two contracting parties are sellers (Owners) and buyer (Developer).

Pro-developer naturally translates to Anti-owners. [Way to go, eh? A law that works against the interests of condo owners who are largely individuals, mostly Singaporeans. It is pathetic to read the 6 Nov 2010 Straits Times report that quoted our earnest Deputy Prime Minister Teo Chee Hean: "Sincerity, honesty, what you can actually do for people" as the hallmark traits of the ruling government. It breaks my little heart to realise that the good minister doesn't even realise what the PAP did TO the people whilst working FOR the people.

The following two blog entries explained how the law is calibrated to be Pro-sale (and therefore Anti-owners - regardless of whether you are a Majority Consenter or a Minority Dissenter - the only difference is that the Majority Consenter dug his/her own hole whereas the Minority Dissenter would be buried alive in the hole dug by others):

(a) http://singaporeenbloc.blogspot.com/2010/06/fifa-world-cup-2010-when-people-with-no.html

(b) http://singaporeenbloc.blogspot.com/2008/08/greek-mythology-themis-and-source.html

2. How to counter the gang robber-cum-rapist.
Again, my suggestions are two-fold:

FIRST: Mandate an additional settlement option of one-for-one (1-4-1) exchange

- PREFERABLY, BY LAW with well thought-out legislative safeguards for Owners to counter-balance the skills/knowledge of Developer-buyers and other en bloc industry experts WITHOUT killing commercial viability for the Developer-buyers

- ALTERNATIVELY, BY CONTRACT with the assistance of SPECIALIST en bloc lawyer cognizant with all the potential legal, financial, CPF, land conveyancing, construction and business risks - which is a tall order even for most non-specialist lawyers (what more for volunteer Sale Committee members who do not have industry skills and are likely clueless)

SECOND: Adopt 3 Action Points at 3 Critical Milestones in any en bloc attempt

If the Gahmen is sincere about working FOR the people, then they should learn from South Korea and Taiwan and mandate one more settlement option for en bloc sale, viz, a one-for-one (1-4-1) exchange based on SAME size, SAME floor level and SAME geographic orientation of main living room window for qualifying owners with contractual commitments of design layout, furnishings and fittings and finishing materials (in much the same way that the Paterson Lodge (now since redeveloped into Paterson Linc) en bloc sale was structured EXCEPT the Paterson Lodge risks were capped because they had 100% consent for exchange which is well nigh impossible to obtain in most estates).

- South Korea's Hapdong Redevelopment Scheme mandates such 1-4-1 exchange:

- Taiwan also is going the same route of 1-4-1 exchange, as per the Straits Times article of 2 Aug 2010:
- Hongkong has more sensibly calibrated en bloc laws that bar any en bloc attempts unless each of the buildings on the lot in a non-industrial zone is at least 50 years old. Also, the Hongkong Lands Tribunal is empowered to take into consideration the age and state of repair of the estate in any en bloc attempt. In comparison, the role of Singapore's counterpart Strata Titles Boards (STB) is much more severely limited.

In sharp contrast, Singapore's en bloc law sanctions demolition as soon as the spanking new condo is issued with the Temporary Occupation Permit (ie, when Developers are authorized to hand over the condo keys to Owners) IF 90% of the Owners so agree to such sale/demolition.

Not only that, AFTER exacting such a HIGH SOCIAL AND ENVIRONMENTAL COST (NOT to mention likely POLITICAL COST too) from such en bloc demolition of swathes of prime/popular residential estates in the 2006-07 frenzy, what UPSIDE came out of it?

Swanky (or "wannabe swanky") apartments where you walk right into the kitchen and/or dining room upon entry (why not into your shoe closet as it would no doubt increase space efficiency, eh?). Residential blocks that have a bigger footprint and less natural lighting in kitchens backed by private lift shafts, and less natural ventilation as gardens on the street level are replaced by gardens on mid/top levels in a singular drive to maximize the permissible Gross Floor Area and squish out every sq cm imaginable as Net Saleable Area.

What else came out of it? Ahhhh ... wholesale cladding of entire blocks to hide all-round bay windows with consequent increase in heat transmission values, and lost opportunities to create wide expanse of horizontal space in readiness for renewable energy possibilities as they become increasingly commercially viable in the near future, etc.

Ohhh ... how could we miss those sleek glass curtain wall facades in our equatorial climate where double-glazing would earn the Developer brownie points under BCA Greenmark Scheme (in case you miss the irony of "brown" and "green" shades). And chalk-up even more obscene profits for Developers because saleable area is computed from the glass edge of curtain wall as opposed to mid-point of the thickness of concrete wall on which a window frame sits. Not to mention the faster pace of buildability afforded by glass panels which hasten project completion to Developers' sheer delight. Who cares if you have to blast on the air-con upon returning home to dispel trapped heat, keep all curtains drawn tight to keep a modicum of bedroom modesty as your prying neighbours watch TV (and your XXX-rated performance) from their living rooms two Honda car-lengths away, wash curtains much more frequently (and spin them dry in dryers whilst the blazing sun is shining outside in blistering tropical heat) than repainting the building facade every 10 years and worry about continuing availability of cheap foreign labour who would risk an arm and a leg to clean your windows whilst swaying in the wind from a suspended gondola/body harness?

Blimey, such urban planning mis-steps will take another generation to unravel and perpetuate in the vicious cycle of UNsustainable Redevelopment! All these were achieved with the blessings of Urban Redevelopment Authority (URA) and Building and Construction Authority (BCA) as they craft development guidelines, approve building plans and audaciously delay impact of policy changes in operational execution!

Besides 1-4-1 exchange, there are Three Actionable Suggestions at Three Critical Junctures of the en bloc process made by PAP MP Ellen Lee during the parliamentary debate on the LTSA amendments on 18 May 2010:

(a) At the beginning of en bloc process:
Mandate professional establishment by a qualified property appraiser of Apportionment Method with basis of recommendation documented in writing and tabled at an EOGM PRIOR to drafting of Collective Sale Agreement. Such professional recommendation/ justification should be attached to the Collective Sale Agreement and highlighted in the skeletal summary.

(b) In the middle of en bloc process:
Mandate disclosure of sensitised Residual Land Value methodology applied in the investment business proposals used by the marketing agent in attempts to sell the estate to potential Developer-buyers. Such business proposals (and each round of updates) should also be tabled at an EOGM and distributed to each owner with signed acknowledgements of receipt attached as Appendices to the Collective Sale Agreement.

(c) Towards the end of en bloc process:
Mandate a simple Re-Affirmation by Majority Consenters prior to execution of Sale and Purchase Agreement by the Sale Committee representatives. The Re-affirmation Level must hit the same tipping point of 80% (or 90%) but need NOT be identical to the level of Collective Sale Agreement signatories. Re-affirmation is returned to the en bloc lawyer via registered post (or fax followed by registered post). Non-return of Re-affirmation is a DEEMDED affirmation. Such process could be operationalized within 14 business days and would NOT jeopardize the rights of the Developer-buyer nor compromise the legal sanctity of contract enshrined in the Collective Sale Agreement, bearing in mind the inordinately long gestation and lock-in period inherent in LTSA.

In his ministerial reply during the abovementioned 18 May 2010 parliamentary sitting, the Law Minister, Mr K Shanmugam, commented that some of the MPs' suggestions are "not without merit" and that they "may well be very useful for specific developments, and owners may wish to adopt them". Whilst no one can lay claim that everything provided in the law applies 100% to all cases, surely that is NOT a sound basis for MinLaw to do nothing and continue to perpetuate the legislative artfulness, eh? Hmmmm ... with such artful legislation in place, do we have an arty-farty MinLaw on our hands?

In fact, with the 2010 LTSA amendments, STB and the judicial courts will likely be reduced to the status of Rocket Dockets insofar as it concerns future en bloc disputes. Under Rocket Dockets, "justice hurried is justice buried". It is the flip-side of "justice delayed is justice denied".

Alleging future Rocket Dockets is NOT a figment of my Doom-Boom-and-Gloom imagination as we are sitting ducks in perpetual threat of en bloc doom, watching the crane boom swinging and smashing the wrecker's ball into what was once our homes and scurrying around in gloom to find replacement units at 2xPrice or ½Size.

In fact, my "Rocket Dockets" hypothecation is even SUBSTANTIATED by none other than the Law Minister, Mr K Shanmugam, when he asserted in his speech at the forum “A Free Press for a Global Society” held on 4 Nov 2010 at the Columbia University: "There are thus LESS INSTITUTIONAL CHECKS AND BALANCES ON EXECUTIVE ACTION IN SINGAPORE compared with the US – AND THAT IS DELIBERATELY SO." [Capitalization emphasis is by The Pariah.] Please refer to the green highlighted text in page 3, paragraph III(23)(2) in the following link:

Is this what we want for our "country" ... errrr "land"?

Sigh ... as a citizen, I find it very disconcerting to observe how public institutional checks-and-balances have been increasingly eroded, undermined, compromised - all in the name of expediency, trust, faith. And I am NOT even using USA as a benchmark!

I am just assessing it within the Singapore context as I reflect, eg, .... on how many times has the judicial right of review been invoked in our 45 years of our nationhood, ... on the level of respect ministers show even to their own party cadre members in the quality and relevance of their ministerial replies, ... on how often do MPs seek clarification or rebut/challenge ministerial replies, ... on the degree of transparency where the Civil Service, the Intelligentsia, the Mass Media and the Government Parliamentary Committees are able to put out the facts to educate (and assure) the public on the due process of checks-and-balances in the quest to "serve the people", ... on how accountability is called for when the S$20.5bn Resilience Package continued to be handed-out even as scintillating quarterly financial results were being released half-way into the Resilience Package, ... on how transparency is manifested in disclosing the effective cost of such Resilience Package to public coffers after imputing and adjusting for 1% cut in corporate tax rate, various extensions, waivers, deferrals, etc.

As a people, I reckon Singaporeans need to decide in the next General Election whether:

(i) We want the INSURANCE of having public institutional checks-and-balances; OR

(ii) We are willing to bear the systemic risk of giving a BLANK CHEQUE to the ruling party (whoever that may be, now or in the future) POST-DATED FOR UP TO 5 YEARS as an EXPEDIENT TRADE-OFF?

In "Casino Singapore 3: Who's the idiot??? Smoking gun with spent bullets", I will present the incriminating evidence of such en bloc gang robbery-cum-rape. The story continues to unfold ... invoking the by-now-forgotten parliamentary promise made at the inception of en bloc law that the primary objective of this law was to create "many more housing units in PRIME 999-year leasehold or freehold AREAS FOR SINGAPOREANS", ... the ministerial allegations and fear-mongering attempts in 1999 and repeated in 2007 in the face of facts that repeatedly affirmed how en bloc law effectively unlocked land value for Developer-buyers who get 2x Price AND 2x Size whilst extant Owners face the Hobson's Choice of 2X Price OR ½ Size:

Casino Singapore 3: Who's the idiot??? Smoking gun with spent bullets

I continue my bleating ...

In "Casino Singapore 1: Who's the idiot? Citizens/Gahmen lost Big Time", you would have heard my bleats on the exponential increases in developers' net profits of 666%, 417.9%, 262%, 188%, etc, for FY 2009/10:

In "Casino Singapore 2: Who's the idiot?? No to gang robbery-cum-rape", you would have gotten an insight as to why MinLaw targetted private condos instead of HDB public housing as part of national agenda of urban rejuvenation and higher land-use intensity despite miniscule proportion of land used for condos relative to HDB and how/why MinLaw consequently abetted enbloc gang robbery-cum-rape. You would have read of the alternative solutions of one-for-one (1-4-1) exchange to follow the lead of South Korea and Taiwan. Also, you would have learned of Hongkong's more sensibly calibrated en bloc law that prohibit senseless demolition of non-industrial buildings of less than 50 years old. Plus the three actionable suggestions cited during the 18 May 2010 parliamentary debate that you could adopt in your own estate's en bloc attempts:

In this concluding "Casino Singapore 3: Who's the idiot???", you would get to see the "SMOKING GUN with SPENT BULLETS" ... the incriminating evidence of such en bloc gang robbery-cum-rape. You would be reminded of MINLAW'S PROMISE made solemnly in Parliament in 1999 about the PRIMARY OBJECTIVE of the en bloc law being "FOR SINGAPOREANS", which has proven to be CHILLINGLY HOLLOW many times over in the multiple bouts of en bloc frenzies to date as we citizens morph into SQUATTERS, REFUGEES, DOWNGRADERS AND DOWNSIZERS in the aftermath in deference, of course, to the housing needs of the rich and/or smart Foreign Talent (whether as owners, investors or tenants).

1. Before and After. These are but a few examples of: "Before" and "After" en bloc sales with the same choral verse of:
For Owners: "Twice the price OR Half the size"
For Developers: "Twice the price AND Twice the size".
So is it any surprise how Developers ramped up triple-digit percentage increases in net profit for FY2009-10 (eg, 666%, 417.9%, 262%, 188%, etc) especially when it coincided with 2009/10 Resilience Package BONUS hand-out from Gahmen???


District 9, Central Core Region (Hilton Towers en bloc; The Lumos redevelopment)

Before: Average en bloc purchase price: S$1088 psf
After: Average redevelopment sales price: S$3298 psf as of 12 Nov 2010
Developer sale price is 203% HIGHER than purchase price

Before: Aggregate area demolished: 72,800 sq ft
After: Aggregate area available for sale: 128,914 sq ft
Developer's new stock level is 77% HIGHER than demolished stock level

Before: Aggregate en bloc purchase price: S$79.2mn
After: Aggregate sales proceeds to date: S$115mn
[As of 12 Nov 2010: Caveats lodged for 17 units (19 sold; 44 launched, 9 to be launched)]
Developer needs to sell ONLY 19% of new stock (ie, area available for sale) to recoup entire en bloc price. [NOTE: As en bloc purchase price (land cost) is the most chunky component of total project cost to a Developer-buyer, once land cost is recouped, it significantly lightens the Developer's holding cost (financing/interest expense) as a business risk. Hence, one could make an educated guess that project breakeven point is likely a low hurdle unless gold is used lavishly as a construction material, or interest rate hikes are steep spikes, eh? In other words, it would be the Developers' equivalent of "pau chiak" in durian sellers' vernacular (Hokkien for "sure-win guarantee").]

District 15, Outside Central Region (Flamingo Valley en bloc/redevelopment)

Before: Average en bloc purchase price: S$640 psf
After: Average redevelopment sales price: S$1298 psf as of 12 Nov 2010
Developer sale price is 103% HIGHER than purchase price

Before: Aggregate area demolished: 323,300 sq ft (estimated)
After: Aggregate area available for sale: 494,518 sq ft
Developer's new stock level is 53% HIGHER than demolished stock level

Before: Aggregate en bloc purchase price: S$194mn
After: Aggregate sales proceeds to date: S$90.7mn
[As of 12 Nov 2010: Caveats lodged for 58 units (74 sold; 120 launched; 273 to be launched)]
Developer needs to sell ONLY 30% of new stock (ie, area available for sale) to recoup entire en bloc price. [NOTE: Same as Case 1 above]

(II) For DETAILS of above Case 1 and Case 2 -
Please click on the following link:

Would you agree that the above evidence of one-for-four (1-4-4) winnings by Developers post-en bloc would effectively DEBUNK the assertions by the previous Minister for Law, Prof S Jayakumar, who was likely misguided in his belief that any legislative provision for one-for-one (1-4-1) exchange would result in lower en bloc sale price?

This is NOT a matter of hindsight being a precise science. The Straits Times poll published as far back as 16 Jun 2007 already made this pitch of "Double the price OR Half the size" for Owners post-en bloc. The poll results are now increasingly substantiated and factually affirmed two-three years after the 2006-07 en bloc frenzy as redevelopment projects get completed and developers' incomes/profits are progressively recognized under the accounting conventions applicable to this industry. My hypothecation of 1-4-4 for Developers have panned-out (viz, "Double the price AND Double the size" for Developers post-en bloc). Allow me the dubious honour of gloating "I told you so" as you re-read this old Aug 2008 blog posting: http://singaporeenbloc.blogspot.com/2008/08/en-bloc-why-it-is-not-right-for.html

Going forward, the 2006-07 en bloc pattern may NOT hold true anymore BECAUSE the Developers' game rules have since changed AFTER their 2009-10 triple-digit percentage increases in net profits, ... where the over-satiated Developer-buyers have developed an appetite to time the market by landbanking and "manage" even land supply beyond the hapless reach of Government Land Sales in CCR, RCR and popular pockets of OCR (viz, Core Central Region, Rest of Central Region and Outside Central Region). Such may be the new-found capacity and power of Developers these days!

When Developer-buyers choose to landbank from en bloc purchases, that's when they are "betting" with a pre-loaded dice ... viz, en blocs immediately spike demand for their yet unsold/unlaunched units and shrink supply because of inherent lag time in redevelopment (double bonus for Developers). On the one hand, global/regional factors could overturn the gambling tables on these Developers, even with their pre-loaded dice! On the other hand, there are predatory lions, tigers and leopards out on the loose who have already been fattened from 2006-07 en bloc feeding binge and 2009-10 Resilience Package bumper hand-outs. These Developers now have a treasure hoard of winnings in hand to further outwit, outclass and outlast any future Gahmen initiatives IF Gahmen can only come out with more-of-the-same or behind-the-curve measures (instead of something fresh and innovative, eg, en bloc quota, 1-4-1 exchange, etc).

Surely, law/policy makers should NOT buy it hook, line and sinker when Developers recant their historical mantra of past market crashes to hoodwink them into believing that en bloc gang robbery-cum-rape must continue to be allowed under artful LTSA legislative framework. http://singaporeenbloc.blogspot.com/2008/08/en-bloc-why-it-is-not-right-for.html

Yet all these super-smart civil servants in MinLaw (most of whom were likely funded by the public for their dual-degree education) failed to be PROACTIVE and continue to fail in being TIMELY and REACTIVE.

2. My word is NOT my bond. To add salt to wound - In calibrating the law to unlock land value for corporate Developer-buyers (NOT extant Owners) whilst being paid by
taxpayers, MinLaw manifest SELECTIVE AMNESIA in DIShonouring their parliamentary promise made in 1999 during en bloc law inception that the PRIMARY OBJECTIVE of this law was to create "many more housing units in PRIME 999-year leasehold or freehold AREAS FOR SINGAPOREANS".

3. PhDs amongst our crème de la crème? You don't need a PhD (yeh, definitely NOT the "Press here Dummy" types amongst the ranks of our crème de la crème), because any idiot can see for himself/herself ...

- Compare the strata title area demolished from the en bloc estate with the net saleable area harvested from the redevelopment:
The "inventory" for the developer typically doubled or more! [During the 18 May 2010 parliamentary debate, the Minister for Law, Mr K Shanmugam, used a misleading indicator of higher land-use intensity by comparing the number of units pre- and post-en bloc. That was naughty and even mischievious because with the current fad of Mickey Mouse (shoebox) units, it would make the senseless comparison even more meaningless!]

- Compare the average en bloc price received by previous estate owners with the average sales price paid by new estate owners:
The price likely doubled or more!

Sure, there may be Development Charge (DC) to be paid by the Developer-buyer but relative to total redevelopment cost, DC is an inconsequential component in the whole scheme of things to the Developer-buyer.

Yes, there is substantive Construction Cost but these typically range from 25%-40%, depending on (i) whether the redevelopment is in the mass-market or super-deluxe range and (ii) the extent of yo-yo gyrations in supply-and-demand aberrations (eg, sand ban by Indonesia, controlled granite chip export, intense labour competition arising from concentrated
construction activities post-en bloc frenzy, or some other regional or global factors). These yo-yo gyrations are likely exacerbated by Gahmen's spasmodic rah-rah PRO-cyclical policies and regulations (instead of striving for a measured tempo under the COUNTER-cyclical approach) because – being human – the powers-that-be are naturally driven by the Key Performance Indicator (KPI) of GDP Growth which is 27% of their total pay (another 20% is based on Job Performance Related KPIs which adds up to 47% under Variable Wage Component for these high-fliers).

Of course, there is Financing Cost where the developers pay interest/fees for bank loans that add up to quite a bit even in a low interest rate environment because of the sizeable quantum involved in paying off all en bloc Owners upon legal completion. But IF the other option of 1-4-1 exchange is taken up by enough en bloc Owners, it would significantly reduce the financing cost burden for Developer-buyers - An Inconvenient Truth that is conveniently unheeded.

4. Rocket Dockets. It does NOT take rocket science to figure out that - under the 2010 amendments of the Land Titles (Strata) Act ("LTSA") - MinLaw will probably succeed in turning the Strata Titles Boards and the courts into Rocket Dockets. This was probably in direct response to developers' complaints to MinLaw of their business risks when protracted en bloc battles could potentially drag on for another 1-2 years from the date when these developers commit to the Sale and Purchase Agreement.

Sauce for the gander is clearly NOT sauce for the goose because the law provides for up to 12+12=24 months to commit Majority Consenters to a Reserve Price in the Collective Sale Agreement! So going forward, justice will likely be hurried. Never mind that justice is buried. Go, Go, Go ... Cheaper, Better, Faster. [Sheesh, how many idiots are running around out there???]

5. Trust, but verify - Windfall or Wind (aka Fart)? As Ronald Reagan famously said to Mikhail Gorbachev: "Trust, but verify". I do NOT make frivolous assertions about MinLaw getting the RIGHT ANSWER to the WRONG QUESTION (viz, how to balance the en bloc law between Majority Consenters and Minority Dissenters). As part of a healthy cross-check, the authorities just need to ask themselves: Why else would en bloc sales continue to be so alluring for Developer-buyers even AFTER the 2010 LTSA amendments? Especially when sites from Government Land Sales are readily available with certainty/speed and therefore reduced business risks for developers, especially with the relaxation in Mar 2010 where developers could "tikam-tikam" (repeated attempts at "hit-and-see") in order to trigger sale of sites on the Reserve List:

Q1: So what's in it for Developer-buyers when it comes to en bloc purchases?

A1: "En bloc windfall", dummy!
[Now, you see why increases in net profit of 666%, 417.9%, 262%, 188%, etc, for FY 2009/10 are a breeze for developers, especially with the bonus of a 2009 Resilience Package handed to these developers on a silver platter by the Gahmen.]

Q2: If Developer-buyer gets "windfall", what do en bloc Owners as sellers get?

A2: Four-letter word: "Wind" (aka "Fart")!
[Now, who's the idiot??? Or should it be plural?]

As en bloc owners suck in the fart from other people, "our land"* will continue on the relentless march towards "Progress" under the billowing banner of Progressive Corporatism flying high in the air, ... replete with our euphemistic Integrated Resorts and the Biggest Casino in the World (viz, the whole island of property speculators
and en bloc flippers), ... all that blinding Orchard Road razzmatazz as building lights flash furiously in curious mis-sync, ... so much buzz and fuzz ** and, ... yes, even funk (if you know where to look)!

* I can't bear to call it "our country" these days. In any case, we have been told categorically by Law Minister K Shanmugam in Oct 2009 that we are "not a country" ... but the good minister didn't (and likely couldn't) explain why on earth are we obliged to pay taxes and why for heaven's sake are we compelling our young men to do National Service ... but these are essential trappings of our "country" masquerade, eh?

** Don't even start me on hot money, money laundering and asset bubbles when gigantic communist China could dance even more nimbly.
Please read this Bloomberg article of 13 Nov 2010: "China to curb foreign investment in property":

In comparison to Giant China, our Teeny Singapore's MinLaw continue to do an unsteady baby cha-cha (two tiny steps forward, one big step back) for LTSA amendments despite anecdotal evidence of flippers driving most en bloc attempts as Sale Committee members. MinLaw were far behind-the-curve in finally closing the gaps in Residential Property Act in respect of foreign buyers of landed property. But MinLaw is NOT alone in this shenanigan.

The whole government machinery (eg, Ministry of National Development, Urban Redevelopment Authority, Building and Construction Authority, Singapore Land Authority, Housing Development Board, Monetary Authority of Singapore, Ministry of Finance, etc) was "too little, too late" in formulating policies and regulations.

It was probably the first time in recorded history that the taxman would consult taxpayers on a tax law! And AFTER such Public Consultation in Jun-Jul 2009, MOF BACKTRACKED on their proposed tax clarification (viz, the profit from the sale of only one property on/after 1 Jan 2010 will not be taxed if the individual owner has not disposed of any other property within 4 years prior to such sale):

With the Private Property Price Index (PPPI) mutating into a 3.5-hump camel with the highest pointy half-hump growing almost vertically in 2007-10 (!!!), I wonder if MOF is even feeling haunted these days for that idiotic back-tracking in 2009:
Not only that but it would appear that the various authorities didn't even dare to give immediate effect to the changes they announced. For elaboration, please click on the following blog-link and scroll down to the clipart pics of gymnasts doing back-flip and leg split:

Indeed, the regulators' trepidation was palpable as they danced around to ensure that they didn't step on the dainty toes of Big Biz ... in case such authorities unwittingly created policy risks for Big Biz that would adversely impact on Big Biz' projected ROIs and in turn likely create rippled waves to dent GDP bonuses of our entire government machinery. Singapore is probably one of the few places in the world where policy makers mitigate and remove policy risks for Big Biz. It is as if the Regulators are afraid to regulate the regulated! Have you seen a cat who is afraid of mice? Think Securities Exchange Commission and ol' Bernie who made off with US$50bn ... and the rest is history, as they say. Never mind, if the cat is black or white. Never mind too, if the mice are black or white.

So on Happy Humping Day, whilst stringing along my pet mutant 3.5 hump camel (BTW, 1.5 humps in the PPI graph above are either pure saline or silicone implanted with untimely, unfiled or misfiled caveats - so please do NOT squeeze too hard!), let's reflect upon what the Minister for National Development, Mr Mah Bow Tan, has been spewing and spouting over 2009 and 2010 whilst on his High Horse:

Reuters, 29 Jul 2009: "I wouldn't say there's excessive speculation at the moment, but there is some element of speculation involved." Ahem ... coughing a little!

Channel News Asia, 30 Jul 2009: "It’s a bit early to say whether there is a speculative bubble or property bubble building up. Obviously it is not in everybody’s interest for such a bubble to form because if it does, and when the bubble bursts, which it inevitably must, then a lot of people will get hurt." Hah??? ... Duh???

Agence France Press, 12 Aug 2009: "A little bit of speculation is inevitable in every market, but when it becomes excessive, then it is something that we should try to avoid." Aaaargh ... by now, gagging from the implant spill-out of pure saline and/or silicone - see, I told you NOT to squeeze too hard!

The Edge, 14 Sep 2009: "We are currently seeing signs of heightened speculative activity, though the level of speculation is not that extreme ... Given the current market conditions, the government has decided to adopt several measures to temper the exuberance in the market and preempt any speculative bubble from forming." Man ... is the guy really one-up over Alan Greenspan as he can burst bubbles as soon as they start to form?

Channel News Asia, 24 Nov 2009: "We want to curb erratic spikes in prices due to excessive speculation, inaccurate information or market manipulation." [Silence] ... Dumbstruck and speechless by now.

Hansard parliamentary record, 18 Oct 2010: "By taking these calibrated steps one at a time, we are able to let the air out of the bubble ... gradually, rather than to prick the bubble and then have it burst, because when the property bubble bursts, a lot of people will be hurt, not to mention the economy as a whole." Ooops ... duck that flying shoe as you pace-out the fart softly, softly!

6. After Humping Camels and Jumping from High Horses. As part of the "trust, but verify" doctrine, we should probably probe and prod if we have more of "right answers" to "wrong questions". Now, let's ask ourselves:

Is Minister Mah and Ministry of National Development also getting the right answer to the wrong question? Sheesh ... do we have an epidemic viral connection between Wrong Questions and Right Answers?

- In a little isle of 710.3 sq km with the world's highest population density of 7,022 persons/sq km (2009, Department of Statistics) where the ENTIRE WORLD POPULATION as of 2009 could be jam-packed into 1000 SINGAPORES, should we blindly adhere to the conventional wisdom shared by Minister Mah that "a little bit of speculation is inevitable in every market"?

- Under such circumstances, should we even allow a bubble to form at the outset and then let the air out? This is especially pertinent when lodgement of caveats is voluntary and URA/SLA do NOT even know when there is deliberate intent NOT to file, or to DELAY/TIME the filing or to MISFILE/AGGREGATE caveats because both URA and SLA systems have been exposed to be GIGO-based (Garbage In, Garbage Out) ... instead of ensuring data integrity by putting the statutory onus on lawyers to (i) verify caveat data accuracy, (ii) provide supporting extracts of key documentation and (iii) file within a 14-day deadline.

- When a country as big as China limit foreigners to only one property purchase with pre-qualifying employment and stay tenure criteria, what is teeny Singapore doing (IF anything - Duh?), bearing in mind our legendary land scarcity and record-breaking population density/sq km?

- Even if the air is let out over time (apparently, some idiots have mastered the art of PACING-OUT A SLOW FART as they dribble pee whilst shitting from the other end!!!), would it merely be slow death with prolonged pain (rather than quick death with sharp pain) for anybody who got the market timing wrong? There is an edifying parallel between asset bubbles and avalanches - NEVER under-estimate the intrinsic momentum once it starts to form.

- When the GIGO-based (Garbage-In, Garbage-out) systems of SLA, BCA and URA have shown data holes and compromised data integrity (eg, buyer indicators cannot be kept at a simplistic one level if the level of froth is to be reasonably sussed-out, occupancy data of HDB property is not complemented by equivalent private property data, different motivations will result in different types of flips and defining speculation by sub-sale data is naive, to say the least, raw data at en bloc source or multiple-unit purchase source cannot be open to fuzzy-wuzzy aggregation and/or averaging techniques to save business costs, etc), it will seriously undermine the credibility and reliability of these institutions at source. If these institutions continue to put their reputation at risk - all purportedly in the name of business-friendliness - does it speak of a deeper and more entrenched malaise across the Civil Service spectrum and, indeed, within the larger system? There is already a Rubik dimension to these manifestations.

- In contrast, the recent HDB measures could hardly qualify as "letting air out" but then, c'est la vie ... the HDB burst was one Big Resounding Fart because these measures did NOT impact Big Biz but they adversely hit upon heartland issues, eh?

- Are the market segments of HDB public housing, strata titled private condos and private landed properties much more fungible than the authorities would like to believe?

- One segment of the locals (especially the first-time-buyers and the no-choice-but-downgraders) lament about affordability of HDB flats sold with public subsidy. But isn't there a significant segment of HDBers who are wealthy enough to "invest" in one or more private properties, whether in or outside Singapore, ingeniously capitalizing upon a whole spectrum of ownership/occupation permutations within the policy framework beyond HDB's wildest imagination?

- Technically, even those who bought HDB flats from the resale market (eg, the foreigners) are also benefitting from the low-base effect because of the embedded public subsidy. In any case, what's "five years" as HDB's Minimum Occupancy Period to qualify for future purchases of private property relative to the whole scheme of things? Who moves house every five years? If a HDBer owner/occupant has the means to invest in one or more private condos (especially after a mere five years but even when it is longer), does it indicate undetected fudge at HDB application point? Or is there systemic exploitation of Gahmen's "housing type" yardstick as a smokescreen to milk more out of wealth redistribution schemes or other forms of benefits/subsidy entitlements arising from means-testing (typical "yau kwee" mentality of Singaporean "kiasuism" - Hokkien words for "petty gains" and "fear of losing out", respectively) - all this whilst generating (i) rental returns from HDB flats to boot and (ii) flipping multiple private properties, whether individually or as a shady consortium born from networking during "investment courses" that taught them how to invest in physical real estate with as little as $5k! And - in the midst of all this - IRAS is NOT even shy to boast that they have a LOW detection rate of tax evasion from property trading! Do we want to cultivate a nation of speculators and flippers, spinning castles in the air and going down the same sorry road as Iceland and Ireland, rather than being producers/providers of actual goods and services?

- Should CPF funds intended as retirement nest-egg savings be released for (i) purchase of second and subsequent properties for extant owners and (ii) purchase of one or more properties for extant HDB occupants? Even when such releases of CPF monies are sanctioned, shouldn't they be subject to (a) higher CPF account balance qualifying criteria and (b) even lower CPF Available Withdrawal Limit when ownership and/or occupancy status has changed upon marriage or other life events?