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Wouldn't the risk here be that someone buys the flats and the freehold from the administrator of the bankrupt freehold company?
Sounds like it. Presumably an administrator would be appointed who would then sell off the assets of the freehold company in the most 'appropriate' way - this might be bulk lot of freehold and leases at auction but I couldn't see that realising anything near the actual value of the place if the leases were sold on the open market.
But that takes time and is a massive administration headache.
RTM requires 50% of the leaseholders to sign up, not the 2/3rds, I do'nt know if that helps. But I'm not sure if RTM applies to a Freeholder going under.
What I will say is that even if those flats are owned by the original Freeholder, they'll be well aware of the dangers here, so it's worth asking the person behind the Freehold to see if they're willing to join.
Good shout on the lawyer. This is a complex situation.