Why we are engaging with Hanover (Scotland) Housing Association Ltd (Hanover)
We are engaging with Hanover about its development plans, a small transfer of homes 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 Hanover’s turnover we consider it to be systemically important.
Hanover is developing plans to transfer and dispose of a number of tenanted homes requiring substantial investment to meet housing quality standards. We are engaging with Hanover to seek assurance that tenants’ interests are protected.
Hanover has plans to grow through a small programme of new homes for social rent and will receive significant public subsidy to help achieve this.
What Hanover must do
Hanover must:
- send us copies of its Board and audit committee minutes as they become available;
- send us by 30 April 2024:
- its approved business plan, the report to the Board on the business plan and its updated risk register; and
- evidence of how it demonstrates affordability for its tenants.
- provide us with the information we require on its plans to transfer and dispose of tenanted homes, including progress with consulting and rehousing tenants affected by the proposals;
- send us an update on its development plans by 31 October 2024. 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; 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;
- observe Hanover’s Board;
- meet with Hanover’s senior staff to discuss its business plan and any risks to the organisation;
- review the information about Hanover’s plans to transfer and dispose of tenanted homes and engage as necessary;
- review the development update and engage as necessary; and
- update our published engagement plan in the light of any material change to our planned engagement with Hanover.
Regulatory returns
Hanover 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.