Why we are engaging with Castle Rock Edinvar Housing Association Ltd (CRE)
We are engaging with CRE about its service quality, development plans and because it is a systemically important landlord.
Registered as Castle Rock Edinvar Housing Association Ltd, CRE is trading as Places for People Scotland. CRE is part of the Places for People Group.
We refer to a small number of RSLs as systemically important because of their stock size, turnover or level of debt or because of their significance within their area of operation. We need to maintain a comprehensive understanding of how their business models operate, and how they manage the risks they face and the impact these may have. So we seek some additional assurance each year through our engagement plans. Given CRE’s size, turnover and level of debt we consider it to be systemically important.
CRE is one of the largest developers of new affordable housing in Scotland. It has plans to grow through a considerable programme of new homes for social rent and mid-market rent and will receive significant public subsidy to help achieve this.
To assess the risk to social landlords we have reviewed and compared the 2023/24 service quality performance of all social landlords to identify the weakest performing landlords. We will therefore engage with CRE about tenant satisfaction and repairs.
What CRE must do
CRE must:
- send us copies of its Board and audit committee minutes as they become available;
- send us by 30 April 2025:
- its approved business plan;
- its updated risk register, including details of its approach to development risk management and mitigation;
- the report(s) to the Board/appropriate committee about the plan and approach to risk management and mitigation; and
- evidence of how it demonstrates affordability for its tenants.
- send us an update on its development programme by 31 October 2025. This will include its latest report to the governing body/appropriate committee about development and details of the scale and tenure mix, timescales for delivery and any material delays or changes to the programme;
- tell us if there are any material adverse changes to its development plans which might affect its financial position or reputation, in line with our notifiable events guidance; and
- send us the information we require about the actions it is taking to improve its performance on tenant satisfaction and repairs.
What we will do
We will:
- review the minutes of the Board and audit committee meetings and liaise as necessary;
- observe CRE’s Board;
- review its business plan and supporting information;
- meet with CRE’s senior staff to discuss its business plan, supporting information and any risks to the organisation;
- review the development update and engage as necessary;
- review the information that CRE provides about its work to improve its service quality performance and engage as necessary; and
- update our published engagement plan in the light of any material change to our planned engagement with CRE.
Regulatory Returns
CRE must provide us with the following annual regulatory returns and alert us to notifiable events as appropriate:
- Annual Assurance Statement;
- audited financial statements and external auditor’s management letter;
- loan portfolio return;
- five year financial projections; and
- Annual Return on the Charter.
It should also notify us of any material changes to its Annual Assurance Statement, and any tenant and resident safety matter which has been reported to or is being investigated by the Health and Safety Executive or reports from regulatory or statutory authorities or insurance providers, relating to safety concerns.