Registration To RP or not to RP 18 September 2019 Althea Houghton Assistant Director Registration and New Entrants
Outline ▪ Regulation ▪ Registration Preparedness ▪ Preliminary ▪ Detailed ▪ Questions 2 Regulator of Social Housing September 19
Regulation Aim: To regulate a sector that is viable, efficient, well-governed and able to deliver homes to meet a range of needs • Regulation designed to deliver our Economic and Consumer statutory objectives • Set high level, outcome focussed standards • Proportionate and duty to assess impact on the ‘regulated’ ▪ We operate on a co-regulatory basis - Boards are responsible for ensuring compliance with the standards 3 Regulator of Social Housing September 19
The Standards - Applicable to all providers Economic Consume r ▪ Governance and Financial Viability ▪ Tenant Involvement and Empowerment ▪ Value for Money ▪ Home ▪ Rent ▪ Tenancy ▪ Neighbourhood and Community Both the Governance and financial viability standard and the value for money standard are amplified by Codes of Practice 4 Regulator of Social Housing September 19
Regulation of smaller providers • Regulating the Standards updated April 2018 – sets out approach • All standards applicable • BUT proportionate approach to the c1200 smaller providers Review notifications Review of financial Analyse Statistical Data about disposals and statements Return constitutional changes 5 Regulator of Social Housing September 19
Applying for Registration 6 Regulator of Social Housing September 19
Registration stats ▪ c1450 registered providers ▪ All but 46 are non-profit ▪ c1150 <1000 units ▪ Typical new entrants: • Subsids of LAs/ existing RP groups for particular purpose • For profits taking s106 and investment back funds • Applicants accessing grant funding • Established charities providing supported housing ▪ About 100 applications a year, all ‘small’ applicants, 3/4 refusals or withdrawals, 7 Regulator of Social Housing September 19
Registration requirements ▪ Registration is optional – although access to grant is a factor ▪ Eligibility requirements in legislation ▪ English body ▪ A provider or intending provider of social housing ▪ And we set criteria applicants must: ▪ Meet the governance and financial viability standard at the point of registration ▪ Have management arrangements in place to enable them to meet the other standards ▪ Constitutional criteria for non-profit bodies ▪ We must register eligible applicants that meet the criteria 8 Regulator of Social Housing September 19
Registration process ▪ Two stages : ▪ Firstly (“preliminary stage”) assess eligibility for registration ie that they are or intend to be a landlord of social housing ▪ Secondly (“Detailed Stage”) assess whether they meet the registration criteria ▪ Application forms for both stages, including guidance about expectations available on the website ▪ Becoming a Registered Provider – publication on the website ▪ We may review other public information – registers, planning, websites ▪ Assurance based regulator – build up evidence to support statements 9 Regulator of Social Housing September 19
Approach to registration – Some Reflections • Big undertaking to become part of a regulated sector • Post registration regulatory contact will be minimal but standards must be met • Standards the same but how you achieve them will be appropriate and proportionate to your objectives, business plan, risks / uncertainty in what you plan to do • Timing – proposals must be progressed for there to be the ability to assess effectiveness of governance arrangements and deliverability of financial plans • We will clarify, recognise regulatory terminology 10 Regulator of Social Housing September 19
Preliminary Stage – Be Prepared • Provide evidence to support answers • Care in terminology and definitions – we are bound by the legal framework • Evidence of corporate status • ‘Sufficient’ level of intent – common issue with community based applicants • Degree of certainty • Think about timing, risk of changes to plans / provision • Timeline to delivery – apply at the right time – things go more smooth if lots of good evidence provided • Social housing • Below market rental levels – methodology and future rent setting • Approach to allocation – RPs not LAs 11 Regulator of Social Housing September 19
Detailed Stage – Be prepared (1) When you’re ready! • Essentially demonstrating you are managed well and viable Board – we take our lead from the board and the assurance it has • Code of governance and constitutional framework • Roles and responsibilities established • Skills and experience, assessed fit for changing role • Access to expertise • Actively engaged, quality, informed decision making • Collective responsibility 12 Regulator of Social Housing September 19
Detailed Stage (2) Organisation / operation • Realistic delivery milestones • Business planning, how you manage risk and control for the outcome you want – the frameworks • Access to resources and financing • Financial Control • Financial Planning – assumptions, risks and mitigations change over time from development to delivery • Reasonable scenario testing – under a range of different economic environments • Treasury Management – expert help / input • Operational approach – managing the day to day 13 Regulator of Social Housing September 19
Detailed Stage (3) Key parts of evidence to build an assurance base: • Appropriate and relevant policy frameworks important but it’s how it is working practically and evidence about that which gives us better assurance • Progress on development plans, funding • Board active involvement, informed decision making, self assessments, challenge, collective responsibility • Robust financials, basis for assumptions, stress testing, covenants, plan for when things may not go to plan • Identify, recognise and plan for management of risk 14 Regulator of Social Housing September 19
Sources of information Regulatory Framework • Standards • Codes of Practice Regulating the Standards Register as a Provider of Social Housing – Registration Guidance and Forms Becoming a Registered Provider Consumer Regulation Review Sector Risk Profiles Fees Statement 15 Regulator of Social Housing September 19
Althea.houghton@rsh.gov.uk 16 Regulator of Social Housing September 19
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