Why we are engaging with Sanctuary Scotland Housing Association Ltd (Sanctuary Scotland)
We are engaging with Sanctuary Scotland about its development plans, the transfer of Thistle Housing Association (Thistle) and because it is a systemically important landlord.
Sanctuary Scotland is part of the Sanctuary Group.
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 Sanctuary Scotland’s size, turnover and level of debt we consider it to be systemically important.
Following a successful ballot of its tenants, Thistle transferred its assets to Sanctuary Scotland on 1 April 2021 and was removed from the Register of Social Landlords on 27 April 2021. Sanctuary Scotland continues to progress delivery of the commitments it made to transferring tenants and service users.
Sanctuary Scotland 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, mid-market rent and low cost home ownership, and will receive significant public subsidy to help achieve this. The number of affordable homes provided by Sanctuary Scotland will increase by around one fifth over the next five years.
What Sanctuary Scotland must do
Sanctuary Scotland must:
- provide copies of its Board and audit committee minutes as they become available;
- provide quarterly updates on progress with the delivery of the commitments Sanctuary Scotland made to transferring tenants and service users;
- 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
- review the minutes of the Board and audit committee meetings and engage as necessary;
- review the quarterly progress updates on the delivery of the commitments Sanctuary Scotland has made to transferring tenants and service users and engage as necessary;
- meet with Sanctuary Scotland’s senior staff to discuss progress with the business plan and any risks to the organisation;
- review the development update and engage as necessary; and
- update our published engagement plan in light of any material change to our planned engagement with Sanctuary Scotland.
Sanctuary Scotland 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.