SHR letter to landlords: adjusting our approach in light of the Coronavirus
31 March 2020
Dear colleague
I hope you are in good health in these challenging times. I’m getting in touch to tell you more about how are we adjusting our regulation in response to the Coronavirus pandemic and to explain what that means for your organisation. This follows our initial announcement on 18 March about realigning our regulatory approach.
I know that landlords are working extremely hard to manage and mitigate the impact of Coronavirus on their services and to safeguard their tenants, people who are homeless and other service users, and to look after staff’s wellbeing and safety. Clearly this is your priority. Almost all landlords have contacted us over the last fortnight to tell us how the pandemic is affecting key services.
Our immediate priorities have been to support the work of the newly-convened Social Housing Resilience Group and to put in place arrangements to monitor the impact of Coronavirus. We have scaled back our routine regulatory work, postponed the publication of Engagement Plans and extended the timescales for landlords to submit annual returns. I can now share further details about changes.
Annual regulatory returns
As you know, our Annual Return on the Charter (ARC) for all landlords, and Five Year Financial Projections forms for RSLs open on 1 April each year. Our RSL Loan Portfolio return opens on 1 May. Normally the deadline for the ARC return is by the end of May and June for the Five Year Financial Projections and Loan Portfolio, however in our 18 March announcement we extended the return dates to the end of July. We will keep the return date under review, and we will extend it further if appropriate.
A number of landlords have asked whether the returns will open on 1 April. I can confirm that they will be available, and you will be able to submit data to us from this date. This means that if you are in a position to, you can provide this information to us. But please give us this information only if you have the capacity to do so. Do not let it divert you from your focus on delivering services in these very difficult circumstances.
Notifiable events
Many RSLs have used our existing Notifiable Events mechanism to inform us of about the impact of the pandemic on their core services. This is helping us put together a picture of the early impact. We ask that you continue to provide us with Notifiable Events as your response to the pandemic develops, including in the following circumstances:
- you reduce or further reduce your service levels as a response to the Coronavirus pandemic
- you are unable to deliver a minimum service, including statutory health and safety requirements, because of staff absences or other factors, such as contractors withdrawing services
- staff absences means you cannot maintain safe levels of staffing in care or supported accommodation
- there is an imminent risk to your solvency, including any issues that arise from unregistered subsidiaries
- your governance contingency arrangements do not operate effectively
- you experience a significant reduction in the capacity of you senior leadership team
We ask local authorities to notify us in the following circumstances:
- you reduce or further reduce your service levels as a response to the Coronavirus pandemic
- you are unable to deliver a minimum service, including statutory homelessness and health and safety requirements, because of staff absences or other factors, such as contractors withdrawing services
Monthly Coronavirus information return
You may be aware that we are working with key sector partners, including the Scottish Government, SFHA, GWSF, ALACHO and CIH in the Social Housing Resilience Group (SHRG). This group will help us all respond to the pandemic and ensure we can work together to minimise the impact on the most vulnerable people in our communities and on social landlords. We are working with the Group to finalise the details of what will be a short monthly return for all social landlords. The aim of the return is to gather critical information from each landlord to help us and the SHRG understand the scale and nature of disruption and to help us plan co-ordinated responses. We will provide more information on this soon.
If you have any questions or you want to raise any issue in connection with this update please contact your lead regulator.
Yours
Michael Cameron
Chief Executive