Why we are engaging with Hanover (Scotland) Housing Association Ltd (Hanover)
We are engaging with Hanover about tenant and resident safety, 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.
In 2022 Hanover identified failures to comply with its tenant and resident safety duties. Hanover put in place an action plan to address the areas of non-compliance and has now confirmed it is fully compliant with its tenant and resident safety duties. Hanover is taking forward a programme of work to further improve its management of its duties. We will engage with Hanover as it completes its improvement plan.
Hanover is developing plans to dispose of a number of tenanted homes requiring substantial investment to meet energy efficiency standards. We are engaging with Hanover to seek assurance tenants’ interests are fully protected.
What Hanover must do
Hanover must:
- provide copies of its Board and audit committee minutes as they become available;
- send us by 30 April 2023:
- 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;
- inform us when it has completed its tenant and resident safety improvement plan; and
- provide us with the information we require on its proposals to dispose of tenanted homes and progress with consulting and rehousing tenants affected by the proposals.
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 the business plan and any risks to the organisation;
- engage as necessary regarding the tenant and resident safety improvement plan;
- review the information and updates on proposals to dispose of tenanted homes, the consultation and rehousing of tenants affected by the disposal programme 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.