Why we are engaging with Cunninghame Housing Association Ltd (Cunninghame)
We are engaging with Cunninghame about its financial management, development plans and because it is a systemically important landlord.
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 Cunninghame’s level of debt we consider it to be systemically important.
Cunninghame has told us a need to obtain new private finance during 2022/23 to support its development plans.
Cunninghame 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 will receive significant public subsidy to help achieve this. The number of affordable homes provided by Cunninghame will increase by around one third over the next five years.
What Cunninghame must do
Cunninghame must:
- provide copies of its Board and audit committee minutes as they become available;
- send us by 30 April 2022:
- an update on the borrowing requirement for 2022/23;
- its latest projected monthly cash flows for the 12 months to 31 March 2023;
- send us by 30 June 2022:
- its approved business plan and report to the governing body about the plan;
- its updated risk register;
- send us an update on its development programme by 31 October 2022. This will include details of the scale and tenure mix, timescales for delivery and any material delays or changes to the programme; and
- 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.
What we will do
We will:
- review the minutes of the Board and audit committee meetings and liaise as necessary;
- review the cash flow projections and liaise as necessary;
- meet with Cunninghame’s senior staff to discuss the business plan and any risks to the organisation;
- review the development update and liaise as necessary; and
- update our published engagement plan in light of any material change to our planned engagement with Cunninghame.
Regulatory returns
Cunninghame 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.