Additional HMO Licensing

HMO Licensing

Good Morning, our local Council has introduced additional HMO Licensing covering Section 257 HMO's. Licensing came in on 1st of February 2020 but they gave 12 weeks grace to License which is now up. I have several flats that may or may not be Licensable. I have been asking for 14 weeks for confirmation of the situation and not received a satisfactory reply on some. My view is that as I have had an open discussion with them and tried to License where required then if they do finally decide I need a License then there should be no civil penalty. Howevere, I'm not sure where i would stand with a rent repayment order?
Example:-
One block of 3 flats, all let on ASTs.- we own 2 of the 3, and 1 of ours is already Licensed under additional Licensing as it is a 3 bed HMO. The other 2 are not Licensed. NBC are saying the freeholder should License, but I(as Freeholder)have no way of making the other leaseholder provide documents or even pay a share of the fee or comply with conditions. The Council can only enforce against the Freeholder so I am responsible for someone I have no control over. Not really enough space to raise all the issues!