The Government first announced plans for a shared ownership right to buy in October 2019. At the time the sector raised concerns about the impact the plans would have on housing associations ability to borrow. An election and a pandemic later the Government announced, during the CIH Housing Festival last week, the return of the right to shared ownership as part of its Affordable Homes Programme (AHP).
Many housing providers are now re-thinking about gathering information to complete their data return to the Regulator of Social Housing (“RSH”), with the initial exercise having been delayed by Covid-19.
The ‘Setting rents for social housing – Addendum to Sector Risk Profile 2019’ published recently by RSH only seeks to emphasise the importance of that return.
What is the return?
While our housing association registered provider clients will be well aware of the return, for the benefit of local authority registered providers the return requires providers to submit data recording organisational information, different property types and rent levels. It sets out the position as of 31 March each year.
Private registered providers will be used to completing the Statistical Data Return (“SDR”). The deadline for the SDR return has been delayed from 31 May 2020 to 31 October 2020 in view of Covid-19. The information required varies according to whether the entity is a small (less than 1,000 units) or large provider.
Local authority landlords will complete the Local Authority Data Return (“LADR”). This was optional for local authorities last year but is now compulsory reflecting the fact local authorities will have to comply with the Rent Standard 2020. The deadline for the LADR is now also 31 October 2020 (delayed from 17 July 2020).
Both returns are made through the NROSH+ system.
Why is it important?
We have seen RSH use the information collected through SDR’s to identify ‘outliers’ and anomalies, and challenge providers about compliance with the Regulatory Standards. In recent years in particular, this has focused on compliance with the rent decrease regime set out in the Welfare Reform and Act 2016.
In RSH’s recent publication, the importance of the data was emphasised:
- High-quality data must underpin internal controls on rent and service charge requirements;
- There remains room for improvement on data quality, particular regarding formula rent;
- Poor data may be indicative of weak internal controls and effective governance; and
- RSH will be changing the way in communicates in cases of non-compliance on data quality, through regulatory notices where it lacks sufficient assurance.
Given the importance of getting the return in on time and the current situation, it is more important than ever to have a prompt start.
How can we help?
We have assisted providers in responding to queries raised by RSH following the data submission, giving detailed advice about the correct application of different property/rent categories (particularly specialised supported housing and temporary social housing) and helping to identify practical solutions to help address any issues of non-compliance.
We are also being asked to proactively assist clients with completion of the return by:
- Helping to interpret the guidance for completion; and
- Reviewing the data to be used either in the submission or the supporting data, to identify and anticipate any issues that RSH may raise working with providers to engage with RSH at an early stage.
For more information
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