Regulatory Framework Review – The story so far
A blog by Alan Stokes, Policy Lead SFHA
The Scottish Housing Regulator (SHR) may have formally kicked off its review of its Regulatory Framework in February 2018 with the publication of a Discussion Paper, but it had been liaising with the SFHA and key stakeholders well in advance of that. This provided welcome opportunities to help shape the content of the paper on behalf of our members prior to its publication.
Following the Discussion paper, SFHA requested volunteers for a Sounding Board of members which met for the first time in February, and also met in March with organisations that the SHR classes as “systemic”. This, along with the feedback we received electronically from members, enabled SFHA to respond to the Discussion Paper reflecting the collective view of our members. Our response to the Discussion Paper is available here: SFHA Response to SHR Discussion Paper (April 2018)
We were particularly pleased that the SHR has taken on board a number of the points we highlighted in our response. In particular, whilst the SHR will take forward its proposal to make internal audit a compulsory requirement – which is supported by the sector – it will no longer be proposing that Audit Committees become a compulsory requirement. Instead there will be flexibility for RSLs to put in place arrangements suitable to their own individual circumstances, in order to ensure the Governing Body leads their internal audit function. The SHR has also been very keen to explore methods – such as establishing new forums or attending existing groups - to constructively engage with the sector on an ongoing basis. We had highlighted this as a helpful way of enhancing mutual understanding, and are liaising with the SHR about how this can be taken forward.
Over the summer, the SHR asked SFHA - in conjunction with GWSF – if we could help them to pull together a small working group of members to talk through the practicalities of some aspects of the SHR’s proposals – in particular Assurance Statements and how the SHR will communicate its level of engagement with landlords. This group met in June and July, and Michael Cameron, Chief Executive of SHR summarised the discussions in two useful blogs available here:
The meetings have been constructive and extremely helpful. The group will meet again at the beginning of August, where the SHR intend to outline some of the content we might expect to see in the formal consultation – due to begin in October. The SFHA Regulation Sounding Board will also meet at the end of August, in advance of the formal consultation and the SHR will be attending.
There are many strands to the Regulatory Framework review, including amending Charter Indicators. It is proposed that the number of Charter indicators be reduced from 74 to 48 – and SHR met with SFHA and a small group of members to discuss the possible changes. SFHA was also able to share the proposals with its Housing Management, Property Maintenance, and Development Forums in order to provide meaningful feedback from those tasked with collecting data for and filling in the Annual Return on the Charter.
Whilst there is still work to do in regards to the overall review of the Regulatory Framework, SFHA is optimistic that this is all progressing in a positive direction. SFHA is now liaising with SHR about how best to engage with the sector during the formal consultation period (to begin in October for three months) and will look to co-ordinate consultation events so that as many of our members as possible have a chance to input to the SHR directly.
SFHA, the SHR and the sector all share the same goal - as we focus on continuing to achieve consistent and comprehensive excellence in social housing for the people of Scotland.
If you would like to input into the SFHA’s response to any aspect of the review, or have any questions about any of the points raised in this blog – please get in touch.
Alan Stokes
July 2018