Why we are engaging with Hillcrest
We are engaging with Hillcrest because it is a systemically important landlord and about the transfer of engagements from Hunters Hall Housing Co-operative Ltd (Hunters Hall).
COVID-19 has significantly impacted the services provided by social landlords in 2020 and will continue to influence how services are provided in 2021. We will continue to monitor, assess and report upon how each landlord is responding and we will keep our regulatory engagement under review so that we can continue to respond to the challenges of COVID-19.
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 Hillcrest’s size, turnover and level of debt we consider it to be systemically important.
The transfer of engagements from Hunters Hall took place on 1 April 2021 after Hunters Hall’s tenants supported the proposal in an independent ballot. Hillcrest will now support Hunters Hall as it progresses its application for removal from the Register of Social Landlords (the Register).
Hillcrest is one of the largest developers of new affordable housing in Scotland and receives significant public subsidy to help achieve this. Hillcrest plans to develop new homes for social rent and mid-market rent.
What Hillcrest must do
Hillcrest must:
- send us by 30 April:
- its approved business plan and updated risk register;
- 30 year financial projections consisting of statement of comprehensive income, statement of financial position and statement of cash flow complete with assumptions and explanatory narrative;
- a comparison of projected financial loan covenants against current covenant requirements;
- financial sensitivity analysis which considers the key risks, the mitigation strategies for these risks and a comparison of the resulting covenant calculations with the actual current covenant requirements;
- the report to the Board in respect of the approved 30 year projections, sensitivity analysis and covenant compliance; and
- evidence of how it demonstrates affordability for its tenants.
- provide copies of its Board and audit committee minutes as they become available;
- provide updates on progress with the delivery of the commitments made to Hunters Hall’s tenants;
- provide updates on progress with the application from Hunters Hall to be removed from the Register; and
- ensure that the impact of the pandemic on its development plans is reflected in its business plan 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 business plan and financial projections;
- meet with Hillcrest’s senior staff to discuss the impact of the pandemic on its existing business model and business plan and any risks to the organisation particularly in relation to its services to tenants;
- liaise with Hillcrest as it progresses the delivery of the commitments made to Hunters Hall’s tenants;
- liaise as necessary about the application for the removal of Hunters Hall from the Register; and
- update our published engagement plan in light of any material change to our planned engagement with Hillcrest.
Regulatory returns
Hillcrest 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.