Scottish Housing Regulator chair, George Walker, says the Regulator’s discussions with stakeholders will inform what goes into the new Regulatory Framework which it plans to publish next year.
We launched our discussion paper on the future of social housing regulation in January. Since then I have had the pleasure of talking to lots of you about it. Thank you to everyone who has already shared their ideas with us. The paper has sparked a really engaged and constructive discussion, and we’ve had useful feedback across all of the proposals. In particular, people have wanted to talk to us about landlord self-assurance.
The ideas in our discussion paper are about building a culture of assurance and openness. From talking to landlords, my sense is that most are already thinking about how they can assure themselves that they are delivering what their tenants want and need at a price they can afford. Our proposal for Annual Assurance Statements aims to support landlords to do this in an effective and meaningful way. We believe that this will help RSL (Registered Social Landlord) Boards and local authority committees to ask questions, consider whether they have seen enough evidence, and support honest self-assessment.
A number of people have asked us what the Assurance Statement would look like, and what the self-assurance processes and framework to underpin it should include.
Our early thinking is that the Statement will be short, simple and concise. Whilst some have said “keep it simple” others have asked for a “comprehensive template” and yet others for “guidance”. We will of course reflect on the best way forward.
The Statement would be an end point in each landlord’s own self-assessment and assurance processes. This is about landlords assuring first themselves, then their tenants, and last the regulator. And I purposely put us last, as this is principally about Board and committee members getting the assurance they need. If they are getting the right assurance about the right things, we will be able to take great comfort and assurance from that.
There’s a clear link between this and our proposals on Internal Audit and Audit Committees for RSLs. Our thinking is that both, done effectively, can help Boards to get the assurance they need and provide important checks and balances. So far the feedback we’ve had on these proposals has been broadly positive, though some have questioned whether there is a need for Audit Committees to be mandatory or if these aims can be achieved in other ways. Again, we’ll reflect on the feedback and the best way forward.
Many of the discussions I’ve had with stakeholders have also turned to Boards themselves, and the skills that members need to both self-assess their organisation’s current performance and set its direction for the future.
We’ve heard a number of suggestions that aren’t in the discussion paper, three in particular which seem to resonate with people I’ve spoken to. Firstly that we should require RSLs to have effective Board development and succession plans; secondly that we should promote, or perhaps even require, continuous learning for Board members; and thirdly that we should require RSLs to publish the length of tenure of Board members. We’ll reflect on these ideas alongside all of the other suggestions and responses to the discussion paper, and we welcome views on them.
We are also keen to hear more on how we can promote a strong tenant voice and get more accessible, useful information to more people. This information could come directly from us, or from landlords. We welcome your views and ideas on this. For example we have had some early suggestions that tenant satisfaction information and learning from complaints could perhaps be used more, or differently, as part of this picture.
The discussion paper is open for formal responses until the end of March. And the discussion won’t stop there, as we’ll be reflecting on the feedback and considering next steps over the coming months. I look forward to continuing these discussions, and would encourage everyone to share their ideas with us and vitally to send their formal written feedback.