Registration To RP or not to RP 18 September 2019 Althea Houghton - - PowerPoint PPT Presentation

Registration

To RP or not to RP 18 September 2019

Althea Houghton Assistant Director Registration and New Entrants

Outline

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▪ Regulation ▪ Registration Preparedness

▪ Preliminary ▪ Detailed

▪ Questions

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
• bjectives
• 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

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The Standards - Applicable to all providers

Economic ▪ Governance and Financial Viability ▪ Value for Money ▪ Rent Both the Governance and financial viability standard and the value for money standard are amplified by Codes

• f Practice

Consumer ▪ Tenant Involvement and Empowerment ▪ Home ▪ Tenancy ▪ Neighbourhood and Community

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Regulation of smaller providers

Review of financial statements Analyse Statistical Data Return Review notifications about disposals and constitutional changes

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• Regulating the Standards updated April 2018 – sets out approach
• All standards applicable
• BUT proportionate approach to the c1200 smaller providers

Applying for Registration

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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,

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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

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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

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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

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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

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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

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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

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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

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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

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Althea.houghton@rsh.gov.uk

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