Chapter 2: Comparative Concepts, Terms and Systems

Meaning of HomeownershipThis chapter provides some useful frameworks for us to analyse the survey datacollected in the two societies.

It cannot or should not be assumed that homeownership means the same thing or has similar attributes in different societies. There
are a number of factors underpinning cross-national differences.

The variations

encompass the means of acquisition and financing, rights of disposal on the market,
differences in right of ownership over the land as opposed to the dwelling, the natureof the dwelling stock as well as quality and space standards. The obvious similarities
relate to the strong attachment to the idea of home ownership in Japan and Britain,and in both societies residential ownership is strongly associated with individual
houses rather than flats. In Japan, however, while single-family homes are still thedominant type of owner-occupied housing, ownership of condominiums has been
increasingly rapidly in urban areas in particular. Government policy has also been
instrumental in the development of the tenure with a strong subsidy bias in most of
the post-war period.

There are however important differences: Homeowners in

Britain are frequent movers, the stock is relatively old and employers have only everplayed a very marginal role within the housing system. In contrast, rebuilding in site
is common in Japan for up-grading and mobility rates are low once households have
moved into home ownership, especially that of a single-family home (For detailed
discussion, see Hirayama et al. 2003).
Moreover, housing in Japan is often considered as ‘family assets’, which ‘belong not
to the individual but to the family and thus are passed on from one generation toanother’ (see for example, Hirose et al. 1998). Such a symbolic (and practical)
meaning of the home typically derives from the customary tradition of the patriarchal
succession system (see for example Izuhara 2002). This idea may originate from thetime when property was important for the structuring of family relationships,controlling productive property (which provided the family with the means of－ 4 －obtaining an income) controlled family members who were in the position to inherit(Allan, 1982). This legacy of ‘family continuity’ or keeping the family line going isindeed still deeply rooted in the mind of some people. Another factor related to thispoint is the attachment to their own land and dwelling – once people achieved theownership of a single-family home their mobility tended to be low and trading up wasoften achieved by rebuilding a home one the same site in Japan. In Britain, bycontrast, housing has been considered more as a ‘commodity’ and treated as part of
tradable assets. The commodification of housing has been accentuated through thepost-war development of the owner-occupied sector.

British people, especiallyamong the middle class, are more frequent movers, and beyond a very small minority,
there is little attachment to a particular piece of land.
Land and Dwelling
One of the marked characteristics of homeownership between Britain and Japan isthat a plot of land and dwelling are often considered separately, and thus valued andregistered separately in Japan, while the value of ‘housing’ includes both a plot ofland and building on top in Britain. ‘Housing’ is often used as a generic term todescribe a dwelling with or without a plot of land in the academic literature. In Japan,
however, there is a clear differentiation between land and housing (the building on topof the land) especially when we discuss the values of properties. In this context, plotsof land hold their value higher and longer than houses due to the short life span ofJapanese houses.

National climate, materials used and the economically-driven

practice of ‘scrap and build’ supported by the construction industry are some of themain reasons given for rapid cycle of housing reconstruction and accelerated decline
in stock value. In this report, the term, ‘housing assets’ implies, as in western homeownership systems, combined assets of land and dwelling, unless specifically stated,in order to make arguments comparable and accessible.
Asset Accumulation and the State
How the state perceives and treats individuals’ asset accumulation manifests
fundamental differences in the two societies in terms of financing long-term care
(Izuhara, 2005). Policies in both societies encourage older people to ‘age in place’,－ 5 －which enables older people to retain their assets invested in housing. In England, due
to changes in demography, social and financial pressures, the housing assets ofindividuals have increasingly been seen by policy makers as a source of income in oldage. Under the current system, people with capital or savings of more than £18,500
will be expected to meet the full cost of their long-term care fees. Japan has taken acontrasting strategy to fund increasing care needs in an ageing society. Under thenew social insurance scheme, eligibility to receive public services is decided
according to criteria on the extent of physical and mental disability. Other conditionsof individuals such as their income and their assets are irrelevant in the assessment
process.
The Role of Firms and Employers in Housing Asset Accumulation
The role of the companies is explicitly counted in Japan, and company housing as apart of occupational welfare had a unique role in the development of the post-war
housing system. During the periods of economic growth, some (typically mediumand large) firms constructed housing such as apartment blocks and dormitories toaccommodate their employees, with highly subsidized rents.

Others leased

accommodation from either the private sector or from relocated employees for thesame purpose. Of the conventional components of occupational welfare, housing
assistance has been, in terms of cost, by far the most important voluntary service
provided by companies. The direct provision of company housing has been graduallyshifted into assisting employees to purchase their own housing, mainly via homeloans or subsidized interest payments. Company housing had been used for many
workers as a bridge to home ownership. Like other welfare benefits, the distributionof company housing was not a universal benefit for workers, and women were often
excluded from the benefits. In Britain, on the other hand, there has not been such
distinctive company assisted schemes towards home ownership, and tied
accommodation can be available only to a specific group of employees.
Institutional and Legal Framework
The role of government in the housing finance systems has been very different. The
dominant lender in Japan has been the Government Housing Loan Corporation－ 6 －(GHLC). In Britain, there was limited direct financing by local authorities in the1960s and 1970s but private banks and building societies have dominated. The Rightto Buy for public tenants in Britain contributed an expansion of the home ownershipsector including different sections of society as homeowners.
In Japan, the lending policies of the GHLC are not explicitly discriminating
towards single people or women in general, however, certain eligibility criteria havebeen set to screen potential borrowers. Until 1993, an age restriction existed forsingle-person households wishing to access public loans; as recently as 1981, among
single households, public loans were only available to those over 40 years old. In
1988, the age bar was brought down to 35 years old before it was removed in 1993.
Third, until 1997, lower ceilings had been used for borrowing limits applicable tosingle persons. The restriction was relaxed in 1998 and now the same criteria forassessing a borrowing limit are applied to both single and family households. The
most significant change is anticipated due to the projected abolition of theGovernment Housing Loan Corporation by the end of fiscal year 2006. The revised
body, which succeed the Corporation, will withdraw from the primary loan market
and deal only with loan securities.
In Japan, legal ownership of a home and mortgage contribution are closelylinked since only those who contribute to mortgage repayment are legally allowed toput their names in the ownership deed. In contrast in Britain, ownership is notnecessarily attached to people’s mortgage status/contributions.
Age, Class and Ethnicity
In order to make the data comparable, the cross-national survey drew samples fromthe same three age bands in both Britain and Japan. Class and ethnicity are two key
indicators to analyse any social trends in Britain, and other surveys including theCensus have been increasingly sensitive to capture ethnic origins of the respondents
today. Not only broad categories such as white, black and Asians are used, but thosecategories are further delineated to identify the origins of the respondents. Due to theresource constraints, the survey used the following categories; white British; white
Irish; other white background; Asian background; and a black background. Table 2.1
shows the definitions of Social Class used in this survey. The survey further asked－ 7 －the women’s employment status being full-time, part-time or at home not seekingwork.
Table 2.1: Definition of social classAB
C1
C2
DE

Social Class
Upper Middle ClassMiddle ClassLower Middle Class
Skilled Working Class
Working Class
Those at the lowest
levels of subsistence

Occupation of Chief Income Earner
Higher managerial, administrative or professional
Intermediate managerial, administrative or professional
Supervisor or clerical and junior managerial, administrative orprofessional
Skilled manual workers
Semi and unskilled manual workers
State pensioners, etc, with no other earnings

Class and ethnicity debate tends to be missing in Japanese research reflecting thepopular discourse of ‘homogeneous’ Japan. There is however an increasing debate on
the end of the ‘middle-class’ society (see for example Chuo-Koron, 2001). Japanesesurveys tend not to ask the ethnic and race backgrounds of respondents partly because
the number and proportion of non-Japanese is very small in the total population. TheJapanese survey asked employment status of the women (and also the male head ofhouseholds if applicable). Four simple categories were used: 1) manager, regularworkers; 2) non-regular workers (part-time or temporary workers); 2) self-employed;and 3) without a job. For the purpose of comparison, the analysis will focus on
employment status (full, part-time or without work) rather than on the British
definitions of ‘class’.

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