Why we are engaging with West of Scotland Housing Association Ltd (West of Scotland)
We are engaging with West of Scotland about its financial management, development plans, and because it is a systemically important landlord.
West of Scotland has two subsidiaries, Willowacre Trust and Westscot Living.
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 a combination of West of Scotland’s size, turnover and level of debt we consider it to be systemically important.
On 1 August 2022 Charing Cross Housing Association Ltd (Charing Cross) transferred its homes to West of Scotland. West of Scotland will now support Charing Cross as it progresses its removal from the SHR Register of Social Landlords.
West of Scotland 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. The number of affordable homes provided by West of Scotland will increase by around one fifth over the next five years. West of Scotland has told us it needs to obtain new private finance during 2023/24 to support this.
What West of Scotland must do
West of Scotland must:
- provide copies of its Board and audit committee minutes as they become available;
- engage as necessary on the integration of Charing Cross into West of Scotland and on the delivery of the commitments West of Scotland has made to Charing Cross’s tenants and service users;
- keep us informed about its progress in addressing the weaknesses in the management of tenant and resident safety duties for Charing Cross;
- update us as it develops its plans to obtain private finance;
- 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;
- 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; and
- provide the information we require to progress the de-registration of Charing Cross, this includes Charing Cross’s final audited financial statements and auditors report.
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 Charing Cross into West of Scotland and on the delivery of the commitments West of Scotland has made to Charing Cross’s tenants and service users;
- review West of Scotland’s progress in addressing the weaknesses in the management of tenant and resident health and safety duties for Charing Cross;
- review the business plan;
- review the updates on its proposals for obtaining new private finance and liaise as necessary;
- meet with West of Scotland’s senior staff to discuss the business plan and any risks to the organisation;
- review the development update;
- consider the de-registration application for Charing Cross; and
- update our published engagement plan in light of any material change to our planned engagement with West of Scotland.
Regulatory returns
West of Scotland 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.