The social housing regulator is changing the regulatory framework to better protect social housing assets and tenants amid a more complex operating environment for providers. The new framework will focus on ensuring providers don't take undue risks with assets or viability, have appropriate board skills, conduct active stress testing of risks, and maintain proper records. Providers will need to demonstrate compliance with the new Governance and Financial Viability Standard. The regulator is finalizing the framework with publication expected in early 2020 and the new rules taking effect in April 2020.
2024: The FAR, Federal Acquisition Regulations - Part 28
NHF Risk Conference 15 Jan 2015 - Jonathan Walters' presentation
1. The social housing regulator
Successful places
with homes and jobs
A NATIONAL
AGENCY
WORKING
LOCALLY
NHF Risk Conference
– Changes to the
Regulatory Framework
2. The social housing regulator
Life is getting more
complex for providers
Gone: 30 year money from
banks
Gone: 50% plus grant rates
Going: Welfare underwriting
rents in full
At risk: local government
funding – Supporting People
Complex choices for Boards
Opportunities and risks
A more cyclical model?
3. The social housing regulator
But some cyclical factors are
hiding the impact
4. The social housing regulator
Sales are increasingly funding
the subsidy gap
Sales
620
971 898
638 516
734
1,405
1,736
1,536
1,470
940
606
583
538
508
0%
2%
4%
6%
8%
10%
12%
14%
16%
18%
0
500
1,000
1,500
2,000
2,500
3,000
3,500
2014 2015 2016 2017 2018
Housingsalesas%oftotalturnover
£(million)
1st tranche shared ownership Properties developed for sale Fixed asset sales Revenue a % of all turnover
5. The social housing regulator
What did “Cosmo” tell us?
Creeping risk profile made
business unsustainable
Weak governance
Poor controls
Complex finance
Commercial exposures to
non-social housing
You should learn the
lessons
6. The social housing regulator
It’s not just Cosmo
Dubious rationale and process
for mergers
Development problems
Poor grasp of risk flows and
risk in he round
Treasury / security mishaps
Boards with inadequate skills
and grip
Tardiness / economy with the
truth
7. The social housing regulator
Providers can’t always
answer the ‘simple’ questions
What is this organisation
for?
Why are we doing this?
What happens if it goes
wrong?
How do we know that [gas
servicing] is OK?
If I was putting my own
money at risk, would I do
this? What return would I
want?
8. The social housing regulator
Regulatory Framework
In the light of the changes in the sector we have been
looking at how the regulator needs to evolve
Consulting on changes to the Framework
Protection of social housing assets is priority
– Protect taxpayer investment
– Protect tenants
– Maintain investor confidence: continued growth in supply
9. The social housing regulator
Framework Changes
Fine tuning on-going but expected requirements:
Don’t put assets or viability at undue risk
Skills and capabilities of board to match activities
Active stress testing
Maintain records of assets and liabilities
Boards to certify compliance to Governance and Financial
Viability Standard
10. The social housing regulator
What are we going to expect
on stress testing?
You need to understand risk flows and risk in
aggregate
It needs to be comprehensive and forensic – so
asset/liability register likely to be pre-requisite
Deal with “what ifs” (e.g. can we really walk away from
that non-recourse JV / subsidiary?)
You need to know what kills you
Outputs should inform business plan and risk-appetite
You should consider (and where necessary embed)
stabilisers / controls
11. The social housing regulator
What should RPs be doing
Robust stress testing
Establishing appropriate controls
Challenge yourselves on skills and capabilities
Focus on risk flows
Question
– What could bring my business down?
– Under what circumstances?
12. The social housing regulator
What next
Currently finalising framework
Publish decision early January
Full framework to be published March 2015
New framework comes into effect April 2015