Social Housing Charter Performance 2023-24 - Half Year Update CaH 16 01 24
Renfrewshire Council · 16 January 2024
Back to Communities and Housing Policy Board — 16 January 2024 and its agenda
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___________________________________________________________________ To: Communities and Housing Policy Board On: 16 January 2024 __________________________________________________________________ Report by: Director of Environment, Housing and Infrastructure ___________________________________________________________________ Heading: Social Housing Charter Performance: 2023/24 Half Year Update ___________________________________________________________________ 1. Summary 1.1 Local Authorities and Registered Social Landlords are required to submit an Annual Return on the Charter relating to service performance to the Scottish Housing Regulator by the end of May each year. 1.2 This report provides an update on performance against the Charter indicators for the first six months of 2023/24. 1.3 We only report on 18 indicators for the six-month report, as opposed to 32 for the Annual report on the Charter. Of these 9 have improved since April 2023, the remainder have remained relatively stable or performance has dipped. 1.4 There is also a summary report on the response to the Scottish Housing Regulator’s consultation on the Single Regulatory Framework ___________________________________________________________________ 2. Recommendations It is recommended that the Communities and Housing Policy Board 2.1 notes the 2023/24 Half Year Update Report on Scottish Social Housing Charter Performance attached as appendix 1. 2.2 notes our response to the Scottish Housing Regulator on the consultation on the Single Regulatory Framework. _________________________________________________________
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3. Six Month Update on Charter Report for 2023/24 3.1 The Half Year Update on Scottish Social Housing Charter Performance provides information on the first two quarters of 2023/24: Section 1 provides performance information against the Charter indicators along with comparative data for the last three years. For ease of reference, indicators which are only reported on an annual basis are not included in this report (these annual indicators were reported to the Policy Board in August 2023). Section 2 reports on management information for key areas of the housing service – allocations and managing tenancy change; repairs; homelessness and housing advice; rent arrears. 3.2 The six month data for 2023/24 displays improved or stable performance in nine of the indicators, the key areas of improved performance are: Gas servicing has improved, although there were 6 occasions a service was not carried out before the anniversary date (Charter Indicator 11). All of these were in April and there have been no instances of ‘gas failures’ since then. All 6 have been completed since. The average time to complete emergency repairs has improved from 9.8 hours to 7.8 hours. Similarly, there has been improvement in repairs satisfaction from 73.3% to 75.6%, Letting activity, there were 512 properties re-let taking an average of 46.5 days. This is an improvement from the year end figure of 60 days; however, this will remain a priority area for the service for further improvement (Charter Indicator 30). Improving re-let performance has been reflected in a reduction in the percentage of rent due lost through properties being empty during the last year (Charter Indicator 18) from 1.95% in April to 1.48% at the end of September. 3.3 Within the six month data for 2023/24 there are also areas where performance has declined, reflecting the challenges faced by the Council in continuing to provide core housing services during the current challenging economic climate. Some of the key areas of performance are: Tenancy sustainment (Charter Indicator 16) has dipped from 95.3% to 91.2%. These figures relate to tenancies which commenced between October 2021 and September 2022. Similar to the same time last year, there has been a slight reduction in the rent collection rate. This is a consistent pattern for the first six months of the financial year – the amount collected usually increases in the second half of the year and this should be reflected in the arrears figure at the year end. The rent collected in the first six months of the year represented 96.4% of the total rent due, compared with 98.2% in 2022/23 (Charter Indicator 26).
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The gross rent arrears figure has increased – up to 9.46% at the end of September from 8.6% at April 2022/23 (Charter Indicator 27). This reflects a similar pattern at the same point last year and as collection rates increase in the second part of the year the level of arrears should reflect this. 3.4 The Management information in appendix 1 notes the following: The number of applicants for housing at the end of September is down slightly from the year end (22/23). In the first six months of 2023/34 we let 512 properties, which is approximately in line with our annual figure. Most of these lets (72.5%) were made though the group system, we have exceeded our target of lets to homeless applicants for the first six months of the year (57.1%) and lets due to the Regeneration programme make up almost 60% of lets out with the group system. Overall repairs completed within target has dipped slightly, however there have been improvements in the emergency and urgent categories amongst others. Our performance in homelessness assessment continues to be positive, more than 90% of assessments are completed within 28 days. Satisfaction with Housing Options advice remains high. An increase in court activity is highlighted following the Scottish Government lifting of the ban on evictions. 4 Scottish Housing Regulator, Consultation on the Single Regulatory Framework 4.1 The Scottish Housing Regulator (SHR) issued a Discussion Paper earlier this year on the Single Regulatory Framework. It advised there would be a further consultation on this topic. In October 2023, they issued their consultation document with a response closing date on 15 December 2023. The key elements affecting local authorities are: A requirement for specific assurance, we responded that this would be appropriate if advised through our Engagement Plan. The SHR have suggested that they intend to review the indicators for the Scottish Social Housing Charter. We advised that we would be keen to participate in a review when this occurs. How landlords respond to tenants and tenants’ concerns, we noted that Renfrewshire Council has a range of ways in which tenants, residents and service users can provide feedback and raise concerns. As such we welcome any methods that would support tenants and residents in providing feedback to their landlord. A copy of our response is attached at appendix 2. ___________________________________________________________________
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Implications of the Report 1. Financial – None 2. HR & Organisational Development - None 3. Community/Council Planning Building strong, safe, and resilient communities – Improving and maintaining neighbourhoods and homes. Working together to improve outcomes – Increasing resident satisfaction with neighbourhoods and communities. 4. Legal – None 5. Property/Assets – None 6. Information Technology – None 7. Equality & Human Rights – The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report because it is for noting only. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website 8. Health & Safety – None 9. Procurement – None 10. Risks – None 11. Privacy Impact – None 12. COSLA Policy Position – N/A 13. Climate Risk – None _________________________________________________________
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Background Papers Report to the Communities, Housing and Planning Policy Board on 22 August 2023, ‘Scottish Social Housing Charter: Annual Return 2022/23’. The foregoing background papers will be retained within Communities, Housing and Planning Services for inspection by the public for the prescribed period of four years from the date of the meeting. _________________________________________________________ Author: Ray Walkinshaw, Housing Regeneration and Development Manager E Mail: ray.walkinshaw@renfrewshire.gov.uk
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1 Scottish Social Housing Charter 6 Month Update 2023/2024
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Scottish Social Housing Charter 6 Month Update 2023/2024 2 Table of Contents 1. SECTION 1: OUTTURN REPORT (April-September 2023-2024) .......... 3 2. SECTION 2: MANAGEMENT INFORMATION ....................................... 7 2.1. Allocations and Managing Tenancy Change ......................................... 7 2.2. Repairs ................................................................................................. 11 2.3. Homelessness and Housing Advice .................................................... 12 2.4. Rent Arrears ......................................................................................... 13
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Scottish Social Housing Charter 6 Month Update 2023/2024 3 1. SECTION 1: OUTTURN REPORT (April-September 2023- 2024) No. Indicator 20/21 21/22 22/23 23/24 Six Month position Notes Complaints 3/4 The percentage of all complaints responded to in full at Stage 1 100% 95.1% 97.9% 97.8% Out of 378 Stage 1 complaints received, 370 were responded to in full, in an average of 6.32 days The average time in working days for a full response at Stage 1 4.97 days 6.56 days 5.76 days 6.32 days The percentage of all complaints responded to in full at Stage 2. 100% 96.2% 84.6% 88.0% Out of 25 Stage 2 complaints received, 22 were responded to in full, in an average of 15.73 days The average time in working days for a full response at Stage 2. 13.9 days 16.6 days 14.5 days 15.73 days Repairs, maintenance and improvements 8 Average length of time taken to complete emergency repairs. (hours) 6.2 7.1 9.8 7.8 hours The average time to complete emergency repairs has improved over the first six months of 23/24. 9 Average length of time taken to complete non-emergency repairs. (days) 10.7 14.6 6.1 6.6 days Performance has remained relatively stable 11 How many times in the reporting year did you not meet your 1471 142 58 6 The six ‘fails’ were in April and there have been no missed safety
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Scottish Social Housing Charter 6 Month Update 2023/2024 4 No. Indicator 20/21 21/22 22/23 23/24 Six Month position Notes statutory obligations to complete a gas safety check within 12 months of a gas appliance being fitted or its last check? checks since then. All the safety checks have been completed. 12 Percentage of tenants who have had repairs or maintenance carried out in last 12 months satisfied with the repairs and maintenance service. 92.0% 95.0% 73.3% 75.6% There has been a slight improvement in repairs satisfaction. 1266 repairs customer surveys were completed between April-Sept 23 and of these 958 said they were very or fairly satisfied with the repairs service Neighbourhood and community 14 Percentage of tenancy offers refused during the year. 24.1% 39.6% 39.3% 39% Performance has remained stable since April 15 Percentage of anti- social behaviour cases reported in the last year which were resolved. 99.8% 99.7% 98.0% 94.88% Figure slightly lower due to small number of investigations (7) commencing in week of 25 September 2023. Access to housing and support 16 Percentage of new tenancies sustained for more than a year, by source of let. Existing tenants 95.5% 93.5% 95.2% 93.22% Overall 919 properties let with 838 having sustained for more Homeless applicants 88.4% 89.4% 91.6% 88.33%
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Scottish Social Housing Charter 6 Month Update 2023/2024 5 No. Indicator 20/21 21/22 22/23 23/24 Six Month position Notes Housing List applicants 92.8% 94.5% 94.5% 92.35% than a year. These figures relate to tenancies which commenced between October 2021 and September 2022. Sustainment across all applicant types has dipped over this period by 4.2 percentage points. Notably, tenancy sustainment by homeless applicants has decreased by 3.3 percentage points. However, in many circumstances there are positive reasons for tenancies not exceeding one year, for example: families re-uniting or young homeless applicant returning to stay with relatives. Other 0.0% 0.0% 0.0% 0.0% Overall 92.0% 92.2% 95.3% 91.19% 17 Percentage of lettable houses that became vacant in the last year. 6.6% 8.3% 7.2% 3.74% 428 properties have become void in the first six months of 2023/24. 18 Percentage of rent due lost through properties being empty during the last year. 1.58% 2.0% 1.9% 1.48% Performance in area is consistent with Q1 and demonstrates improvement when compared to Q2 last year where figure was 1.95%. 22 Percentage of the court actions initiated which resulted in eviction and the reasons for eviction. Non-payment of rent 0.0% 0.0% 4.4% 13% 191 cases called Anti-social behaviour 0.0% 0.8% 0.6% 0.05% Other 0.0% 0.0% 0.0% 0
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Scottish Social Housing Charter 6 Month Update 2023/2024 6 No. Indicator 20/21 21/22 22/23 23/24 Six Month position Notes All 0.0% 0.8% 5.0% 13.05% Homelessness 24 Homelessness (LAs only) – the percentage of homeless households referred to RSLs under section 5 and through other referral routes. 32.1% 32.0% 28.2% 18.9% 82 homeless households referred to RSLs under Section 5 433 homeless households to whom the local authority has a statutory duty to secure permanent accommodation Rents and service charges 26 Rent collected as percentage of total rent due in the reporting year. 99.0% 98.2% 100.0% 98.46% Performance is consistent in line with collection rate in previous years – Q2 position in 22/23 was 96.36% 27 Gross rent arrears (all tenants) as at 31 March each year as a percentage of rent due for the reporting year. 6.4% 8.0% 8.6% 9.46% Performance continues to improve in both current and former tenant rent collection in line with collection rates at this point in the financial year – Q2 position in 22/23 was 10.07% 30 Average length of time taken to re-let properties in the last year. (days) 85.7 66.0 60.6 46.5 Performance continues to improve, and number of properties let has increased from Q1.
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Scottish Social Housing Charter 6 Month Update 2023/2024 7 2. SECTION 2: MANAGEMENT INFORMATION 2.1. Allocations and Managing Tenancy Change Table 1 notes the number of applicants on housing list. The number of applicants at the end of September is down slightly from the year end (22/23). 20/21 21/22 22/23 23/24 Six Month position Number of applicants on housing list - at 30 Sept 2023 5,901 5,672 4,951 4,678 Of which, number who have their application on hold 1,034 983 788 726 Table 2 provides the source of housing applicant from the allocation policy which notes that the source of the applications remain relatively unchanged from previous years. Group 20/21 21/22 22/23 23/24 Six Month position Applicants % Applicants % Applicants % Applicants % Statutory Homeless 254 4.3% 215 4% 245 4.9% 231 4.9% Mobility 435 7.4% 479 9% 571 11.5% 617 13.2% General Applicants (not landlord’s own tenant) 3,859 65.4% 3,400 63.6% 2,995 60.5% 2,801 59.9% Transfer Applicants (with housing need) 745 12.6% 676 12.6% 624 12.6% 573 12.2% Transfer Applicants (no housing need) 608 10.3% 577 10.8% 516 10.4% 456 9.7% Total 5,901 100% 5,347 100% 4,951 100% 4,678 100%
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Scottish Social Housing Charter 6 Month Update 2023/2024 8 Table 3, 4 and 5 shows lets made through and out with the group system. There were 512 properties let by the Council, this is on par with the annual figure for lets. Most of these lets (72.5%) were made though the group system. We have exceeded out target of lets to homeless applicants for the first six months of the year ((57.1%). Lets due to the Regeneration programme make up almost 60% of lets out with the group system. 20/21 21/22 22/23 23/24 Six Month position Number % Number % Number % Number % Lets through group system 500 83% 426 90.3% 764 81% 371 72.5% Lets outwith group system 99 17% 46 9.7% 181 19% 141 27.5% Total Lets 599 100% 472 100% 945 100% 512 100% Table 4 shows lets to each group and the target for lets to each group. 20/21 21/22 22/23 22/23 Six Month position Targets Group Lets % Lets % Lets % Lets % % Statutory Homeless 245 49% 368 42.9% 316 41% 212 57.1% 49% Mobility 74 14.8% 117 13.6% 98 13% 47 12.7% 10% General Applicants (not landlords’ own tenant) 128 25.6% 255 29.8% 265 35% 87 23.4% 23% Transfer Applicants (with housing need) 47 9.4% 93 10.9% 72 9% 24 6.5% 15% Transfer Applicants (no housing need) 6 1.2% 24 2.8% 13 2% 1 0.3% 3% Total 968 100% 857 100% 316 41% 371 100% 100%
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Scottish Social Housing Charter 6 Month Update 2023/2024 9 Table 5 gives details for lets outwith the group system. 20/21 21/22 22/23 23/24 Six Month position Category Lets % Lets % Lets % Lets % Sheltered 25 25.2% 39 46.2% 42 23% 20 14.2% Special Lets 25 25.2% 40 48.9% 66 36% 38 26.9% Regeneration 49 49.5% 4 4.9% 73 40% 83 58.9% Total 99 100% 83 100% 181 100 141 100% Table 6 shows lets by house type. House Type 20/21 21/22 22/23 22/23 Six Month position No. % No. % No. % No. % Tenement Flat 232 39% 210 44.5% 418 44.2% 236 46.1% Own Door Flat 122 20% 94 19.9% 153 16.2% 108 21.1% Multi-storey Flat 42 7% 54 11.4% 95 10.1% 35 6.8% House 122 20% 48 10.2% 139 14.7% 51 10% Other 80 14% 66 14% 140 14.8% 82 16% Total 599 100% 472 100% 945 100% 512 100.00%
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Scottish Social Housing Charter 6 Month Update 2023/2024 10 Table 7 shows Section 5 and Nomination Lets information. The percentage of lets to Section 5 nominees and overall lets to the Council remains broadly similar to the previous year end position. Table 7 Nomination & S5 Lets Council nomination lets % of overall lets to Council nominations Section 5 lets % lets to Section 5 % overall lets to Council General stock Specialist/sheltered /supported Total stock 20/21 19 1 3.3% 165 31.8% 30% 21/22 74 3 8.6% 174 24.2% 28% 22/23 48 11 7.6% 171 26.5% 29.6% 23/24 Six Month 15 2 5% 80 28.8% 28.6% Section 5 = general stock only (excludes specialist housing)
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Scottish Social Housing Charter 6 Month Update 2023/2024 11 2.2. Repairs Overall repairs completed within target has dipped slightly, however there have been improvements in the emergency and urgent categories amongst others. Table 8- Category of Repair completed within target 20/21 21/22 22/23 23/24 Six Month position Emergency Completed 98.7% 97% 95% 97% Right to Repair Completed 99.5% 100% 95% 97% Urgent Completed 87% 86% 61% 74% Routine Completed 90% 87% 92% 88.5% Programmed Completed 98.8% 100% 99% 99.1% Total Repairs Completed 96.2% 93.6% 93.1% 92.1% Table 9 provides information on Customer Contact Centre performance in relation to housing repairs calls. This shows the volume of calls for the first six months of 2023/24 and the outcomes for calls received. Almost 32,000 calls were made to report repairs and 94% of these were answered. Table 9 - Customer contact centre Indicator Number Percentage Total calls attempted 31,799 Calls answered 29,837 94% Calls abandoned 1,563 5% Calls answered within 40 second target time 22,413 % of all attempted calls answered within 40 sec target (service level) 70%
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Scottish Social Housing Charter 6 Month Update 2023/2024 12 2.3. Homelessness and Housing Advice Table 10 provides information on the number of applications that were assessed as being statutorily homeless or threatened with homelessness. Performance in terms of time taken to complete assessments continues to compare well with other Scottish Local Authorities. Table 10 Applications and Decision Making 20/21 21/22 22/23 23/24 Six Month position Number of homeless applications requiring assessment 832 909 935 525 Total number of service users – those who were homeless, threatened with homelessness, or requiring housing options advice. 2,084 2,256 2,384 1,396 Number of applications assessed as ‘homeless or threatened with homelessness’ (i.e. the Council had a duty to rehouse) 682 712 766 433 Proportion of assessments completed within 28 days 99.7% 100% 99.70% 93.2% Table 11 measures satisfaction with Housing options service. Satisfaction with Housing Options advice remains high. Table 11 – Satisfaction 20/21 21/22 22/23 23/24 Six Month position % pleased with the quality of advice and information they were given 96.3% 100% 94.6% 91.4% % pleased with the overall quality of the service they received. 96.3% 100% 94.6% 91.4% % Satisfied with temporary accommodation 94.7% 98.3% 94.7% 96.4%
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Scottish Social Housing Charter 6 Month Update 2023/2024 13 2.4. Rent Arrears Table 12 shows that the rental due to be collected between April and September was over £25 million. At the end of September 2023, £3.103 million was owed in current tenant arrears, which excludes former tenant arrears. Table 12 - Current Tenant Rent Arrears 20/21 21/22 22/23 23/24 Six Month position Annual Rental Income £47,627,600 £47,658,100 £48,238,167 £50,638,912 Number of Tenants 11,121 11,036 11,005 11,004 Total Arrears Owed All £1,849,868 £2,334,578 £2,322,033 £3,103,242 Table 13 shows the recovery action taken. The six month figures demonstrate an increase in court activity following the lifting of evictions ban by the Scottish Government. Table 13 – Recovery Action 20/21 21/22 22/23 23/24 Six Month position NPRP issued 4 106 622 334 All Cases calling at Court 67 22 158 129 Decrees Granted 0 3 38 51 Evictions enforced S/Officer 0 0 0 4 Average time first calling 11 weeks n/a 12 weeks 10 weeks Average time recalled at court 23 weeks 4 weeks 8 weeks 5 weeks
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Scottish Social Housing Charter 6 Month Update 2023/2024 14 Table 14 provides a profile of arrears by value. The level of arrears has increased in all categories with the exception of arrears over £1,000. This is reflected in the increase of the arrears percentage. Table 14 – Profile of Arrears by Value 20/21 21/22 22/23 23/24 Six Month position Under £250 £109,500 £110,600 £111,919 £234,663 Between £250 & £500 £187,500 £186,500 £181,078 £401,117 Between £500 & £1,000 £333,700 £336,800 £307,683 £503,306 Over £1,000 £1,219,200 £1,700,600 £1,721,353 £1,148,222 TOTALS £1,849,900 £2,334,500 £2,322,033 £3,103,242 Table 15 shows the status of arrears debt. Table 15 – Status of Rent Debt 20/21 21/22 22/23 23/24 Six Month position Arrears Pre-Court £1,493,900 £1,839,500 £2,868,200 £2,524,178 Arrears Post Court £201,800 £241,800 £288,500 £500,822 Arrears Rent Direct £154,200 £253,200 £106,900 £78,242 TOTALS £1,849,900 £2,334,533 £3,263,600 £3,103,242
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Scottish Social Housing Charter 6 Month Update 2023/2024 15 Table 16 shows the amount owed in rent by the age of tenants. There has been an increase across all age ranges. Table 16 – Profile of Arrears by Age 20/21 21/22 22/23 23/24 Six Month position Under 25 years £112,700 £137,600 £168,165 £218,784 Between 25 & 49 years £1,230,100 £1,565,100 £1,511,231 £2,033,214 Between 50 & 60 years £358,100 £453,200 £436,090 £608,858 Over 60 £149,000 £178,600 £206,547 £242,386 TOTALS £1,849,900 £2,334,500 £2,322,033 £3,103,242 Table 17 provides summary information on benefit levels compared to previous years. Benefit uptake remains at 76% in the first six months of 2023/24. Table 17– Housing Benefit 20/21 21/22 22/23 23/24 Six Month position Number of tenants 11,121 11,036 11,005 11,004 Tenants with benefit 8,498 8,408 8,392 8,404 Tenants without benefit 2,623 2,628 2,613 2,600 % in receipt of Housing Benefit 76% 76% 76% 76%
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16 Environment, Housing and Infrastructure Renfrewshire Council Renfrewshire House Cotton Street Paisley PA1 1BR
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Appendix 2 Our regulation of social housing in Scotland Consultation questions We welcome your general feedback on our proposals as well as answers to the specific questions we have raised. You can read our consultation paper on our website at www.housingregulator.gov.scot Please do not feel you have to answer every question unless you wish to do so. Send your completed questionnaire to us by 15 December 2023. By email @: regulatoryframeworkreview@shr.gov.scot Or post to: Scottish Housing Regulator 2nd floor, George House 36 North Hanover Street, G1 2AD Name/organisation name Louise Feely, Renfrewshire Council Address Renfrewshire House Cotton Street Paisley Postcode PA1 1JD Phone Email How you would like your response to be handled To help make this a transparent process we intend to publish on our website the responses we receive, as we receive them. Please let us know how you would like us to handle your response. If you are responding as an individual, we will not publish your contact details. Are you happy for your response to be published on our website? Yes X No If you are responding as an individual … Please tell us how you would like your response to be published. Pick 1 Publish my full response, including my name Please publish my response, but not my name
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Appendix 2 1. Do you agree with our proposed approach on specific assurance in Annual Assurance Statements? We agree that a provision for a requirement for specific assurance may be required in certain circumstances. We welcome the suggested approach that in some circumstances, specific assurance may be requested through the Engagement Plan. 2. Do you agree with our proposal to initiate a comprehensive review of the Annual Return on the Charter which we will consult on next year? Yes, we would welcome a comprehensive review of the Annual Return on the Charter and look forward to participating in it. 3. Do you agree with our proposed amendments to strengthen the emphasis on landlords listening to tenants and service users to include a requirement that landlords: a. provide tenants, residents and service users with appropriate ways to provide feedback and raise concerns, and b. ensure that they consider such information and provide quick and effective responses? Renfrewshire Council has a range of ways in which tenants, residents and service users can provide feedback and raise concerns. As such we welcome any methods that would support tenants and residents in providing feedback to their landlord. We provide a quick and effective responses to service users but believe that it should be recognised some requests for information are more complex and that response times would need to be proportionate. There may remain some work to do on differentiating between complaints and serious issues. It could be concluded that a serious issue for a tenant is a complaint, which we would address using our complaints process. We would not welcome additional timebound measures from the regulator. 4. Do you agree with our proposed approach to Notifiable Events? Although local authorities are not required to declare a notifiable event, we have as a rule of thumb, contacted our regulation manager to determine whether something should be considered a Notifiable Event. 5. Do you agree with our proposed approach to regulatory status? We note that this applies to RSLs and as such will not comment. 6. Do you agree with our proposed approach to Significant Performance failures? The proposed approach seems reasonable. We look forward to the revised document on Significant Performance Failures. 7. Do you agree with our proposed changes to the guidance on Annual Assurance Statements? Yes, this appears reasonable. However, if there is a specific requirement for explicit assurance by individual landlords then the landlord should be advised of this at the Engagement Plan stage. 8. Do you agree with our proposed changes to the guidance on Consultation where the Regulator is directing a transfer of assets? We note that this applies to RSLs and as such will not comment. 9. Do you agree with our proposal to maintain the Determination at this time? We note that this applies to RSLs and as such will not comment.
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Appendix 2 10. Do you agree with our proposed changes to the guidance on Determination of what is meant by a step to enforce a security over an RSL's land? We note that this applies to RSLs and as such will not comment. 11. Do you agree with our proposal to maintain the guidance on Financial viability of RSLs? We note that this applies to RSLs and as such will not comment. 12. Do you agree with our proposed changes to the guidance on Group structures? We note that this applies to RSLs and as such will not comment. 13. Do you agree with our proposed changes to the guidance on How to request an appeal of a regulatory decision? We note that this applies to RSLs and as such will not comment. 14. Do you agree with our proposal to maintain the guidance on How to request a review of a regulatory decision? We note that this applies to RSLs and as such will not comment. 15. Do you agree with our proposed changes to the guidance on Notifiable events? We note that this applies to RSLs and as such will not comment. 16. Do you agree with our proposed changes to the guidance on Preparation of financial statements? We note that this applies to RSLs and as such will not comment. 17. Do you agree with our proposal to maintain the guidance on Section 72 reporting events of material significance? We note that this applies to RSLs and as such will not comment. 18. Do you agree with our proposed changes to the guidance on Tenant consultation and approval? We note that this section titled ‘Tenant Consultation and approval’ applies to RSLs and as such will not comment. 19. Would you like to give feedback on any aspect of our impact assessments? Are there other potential impacts that we should consider? No Thank you for taking the time to give us your feedback!