A second matter that must be noticed is the question of residence. Before the Reform Act of 1832 the qualification for counties was based upon ownership; that for boroughs varied very much; but in those places where the franchise was broad it was based mainly upon residence. This distinction has, to some extent, persisted. In general it may be said that for English and Scotch counties, and in Ireland for both boroughs and counties, residence is not required, except so far as the occupation of a dwelling-house or lodging may involve residence and this is not necessarily the case.[211:2] In English boroughs a voter must have resided for six calendar months previous to the 15th of July in the borough, or within seven miles thereof;[212:1] and in Scotland he must have resided there for a whole year. The requirement of residence does not, however, imply quite so much as might appear, because, according to English law, the possession of a chamber in which a man occasionally sleeps, and to which he can return at any time, is enough to constitute residence; and, hence, he may have a residence in more than one place.[212:2] In the counties, therefore, residence is unnecessary, and even in the boroughs the requirement of residence does not limit a man to voting in a single constituency. The importance of this will shortly be pointed out. [Sidenote: Payment of Rates.] The third matter to be noticed is the question of rating. We have already observed that at one time the personal payment of rates by the voter was much discussed, and was regarded as an important guarantee of character.[212:3] In England poor rates are assessed upon the occupiers, not the owners, of the property, and it is still provided that all voters whose qualification depends upon the occupation of land (except lodgers, who are not from the legal point of view occupiers) must have been rated and must have paid their rates.[212:4] But this means only that the rates must have been paid on their behalf; and the practice of compounding by the landlord for small tenements is so universal that practically the landlord pays the rates in almost all cases where the occupiers would be likely to fail to do so. In England, therefore, the requirement that the rates must have been paid has little or no effect on the electorate. In Scotland, on the other hand, this is not the case. There the rates are divided between the owner and the occupier, and the practice of compounding does not exist. The result is that many occupiers are omitted from the parliamentary register every year on account of their failure to pay rates. For the whole of Scotland the number reaches fifty thousand.[213:1] [Sidenote: Actual Extent of the Suffrage.]