Why we are engaging with Clyde Valley Housing Association Ltd (Clyde Valley)
We are engaging with Clyde Valley about its development plans, tenant and resident safety and because it is a systemically important landlord.
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 Clyde Valley’s level of debt we consider it to be systemically important.
Clyde Valley identified weaknesses in its management of gas safety in October 2021. It is committed to addressing the weaknesses as quickly as possible. It has developed an action plan and is making good progress in carrying out its programme of improvements. As part of its action plan Clyde Valley is reviewing the accuracy of its data on gas safety. We have been engaging with Clyde Valley about the steps it is taking to address these issues and to ensure it is complying with the Regulatory Standards of Governance and Financial Management and its tenant safety duties.
Clyde Valley is one of the largest developers of new affordable housing in Scotland. It has plans to grow through a considerable programme of new homes for social rent, and will receive significant public subsidy to help achieve this.
What Clyde Valley must do
In order to allow us to complete our review of its regulatory status Clyde Valley must:
- provide us with assurance it is continuing to address the tenant and resident safety matters; and
- provide us with the outcome of its review of the accuracy of its gas safety data.
Clyde Valley must also
- Send us by 30 June 2022:
- its approved business plan and report to the governing body about the plan; and
- its updated risk register.
- provide copies of its Board and audit committee minutes as they become available;
- 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; and
- 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.
What we will do
To allow us to complete our review of Clyde Valley’s regulatory status we will:
- engage with Clyde Valley to monitor progress with its plans in response to the tenant and resident safety matters;
- consider the outcome of Clyde Valley’s review of the accuracy of its data on gas safety; and
- update Clyde Valley’s regulatory status when we have completed our inquiries.
We will also
- meet with Clyde Valley’s senior staff to discuss the business plan and other information;
- review the minutes of the Board and audit committee meetings and liaise as necessary; and
- review the development update and liaise as necessary.
Clyde Valley 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.