Why we are engaging with Link Group Ltd (Link)
We are engaging with Link about its financial management, development plans, the transfer of engagements from Weslo Housing Management (Weslo) and because it is a systemically important landlord.
Link has three registered subsidiaries, Horizon Housing Association Ltd (Horizon), Larkfield Housing Association Ltd (Larkfield) and West Highland Housing Association Ltd (West Highland).
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 Link’s size, turnover and level of debt we consider it to be systemically important.
With the support of its tenants, Weslo transferred its assets to Link on 1 June 2021. Weslo was removed from the Register of Social Landlords on 22 February 2022. Link continues to progress delivery of the commitments it made to transferring tenants and service users.
Link 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. Link is also in the process of arranging private placement finance in order to support its development programme. The number of affordable homes provided by Link will increase by around one third over the next five years.
What Link must do
Link must:
- provide copies of its Board and audit committee minutes as they become available;
- provide quarterly updates on progress with the integration of Weslo into Link and with the delivery of the commitments Link has made to Weslo’s tenants and service users;
- send us by 30 April 2022:
- 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.
- 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;
- engage as necessary on the integration of Weslo into Link and on the delivery of the commitments Link has made to Weslo’s tenants and service users;
- review the business plan and financial projections;
- review the cash flow projections and liaise as necessary:
- meet with Link’s senior staff to discuss the business plan, the financial information and any risks to the organisation;
- review the development update and engage as necessary; and
- update our published engagement plan in light of any material change to our planned engagement with Link.
Regulatory returns
Link 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.