Blog: Discussing proposals of a new regulatory framework

Michael Cameron

Scottish Housing Regulator chief executive Michael Cameron provides an update on meeting stakeholders to discuss the new regulatory framework.

We’ve spent the summer talking to landlords and other stakeholders about their feedback on our discussion paper and how we develop our detailed proposals for consultation. It’s been great to have the opportunity for these discussions, and I’d like to thank everyone who has contributed and worked with us to make this happen. This collaboration has shaped our thinking and helped to improve our proposals.

We had our third meeting with a group of volunteer RSLs in early August. We continued our discussions about the Annual Assurance Statement and how to make this work in practice. In particular, we considered the format of the Statement and whether a template would be best, or guidance with prescribed or example wording. The group agreed that the Statement needs to be owned by the governing body or committee that is preparing and signing it, so a fixed template might not be appropriate. We concluded that the guidance should set clear requirements for what the Statement needs to cover, and provide some example wording but not a template. We will also provide some illustrations of what Statements might look like for information alongside the consultation, to help stakeholders visualise how the process might work.

Our discussion with the RSL group turned to what governing bodies and committees will need to support effective self-assurance. We spoke about information that could be useful,  for example illustrations of sources of assurance, questions for governing bodies to ask themselves and examples of what ‘good’ looks like, with signposting to information from SHR and others.

We agreed that rather than putting this sort of information in statutory guidance on the Assurance Statement, it would be better to work towards an advisory toolkit. This could be online, and something that we keep up to date and add to over time as a resource to support governing bodies and committees.

We are keen to develop the toolkit collaboratively, and to take some time to really explore content and what would be most useful. As an advisory toolkit it won’t be part of the consultation, so we have time to continue these discussions.

Following the RSL group meeting, we met with a group of local authorities to discuss how the Assurance Statement would work for them. We tested the principles and ideas we had developed and we will reflect their feedback in the guidance for consultation.

We also discussed our future approach to equality and human rights with both groups, and we’ve been talking to the Equality and Human Rights Commission. Our consultation proposals will set the detail of this out. In essence, landlords would be required to have assurance and evidence that they are giving proper consideration to equality and human rights in how they take decisions, set policies and deliver services. We would stop collecting the small number of equality indicators that we currently get through the Charter Return, but require landlords to collect a fuller set of indicators to cover all of the protected characteristics. This would be about landlords using the data themselves to better understand their customers’ needs and discharge their legal duties. Our sense is that this approach, coupled with some thematic work by us, would be more meaningful in terms of promoting equality and human rights. The landlords we’ve spoken to have suggested that this would be a useful area for the toolkit to cover.

At the end of August, we also met with the SFHA’s Regulation Sounding Board to discuss our emerging consultation proposals. The group highlighted lots of really interesting opportunities for future collaboration, not just on the toolkit. For example we spoke about exploring how we can make data as useful as possible for benchmarking, and how we can measure tenant satisfaction in a way that reflects modern methods of getting feedback. I’m really keen that we continue these conversations beyond the consultation, so we’ll be talking to landlord representatives and others about how we do that.

We are on track to launch the consultation in October, and we’ll continue to discuss the proposals at meetings and events between now and then. We’re also working with stakeholders to arrange a programme of engagements for during the consultation period. So much more on this to follow soon, and I look forward to hearing your feedback.

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