Response to Sector Risk Profile & the increased challenges facing the sector.
TCW CEO Ryan Dempsey’s response to the latest Regulator of Social Housing’s Sector Risk Profile and the increased challenges facing the sector.
As many of you will be aware, the Regulator of Social Housing has recently published its latest Sector Risk Profile with the clear message that Boards of registered providers are responsible for managing the risks their organisations face (copies of which can be found here: https://www.gov.uk/government/publications/sector-risk-profile-2019). The Regulator of Social Housing’s Sector risk profile is intended to help boards have a better understanding of those risks, in an increasingly complex and diverse sector.
It sets out the main risks facing the social housing sector and some of the actions registered providers should be taking to manage those risks. It is great that the Regulator is now pushing the importance of data and assurance activities, but I believe there’s more that needs to be done to help towards quality social housing. When I say quality social housing I don’t necessarily just mean the stock itself, more how it’s managed by the many qualified people within organisations.
“The need for effective risk management and assurance in the sector must keep pace”
I agree that we are starting to understand the importance of wider visibility of what is happening in our organisations and feel the sector is starting to look for guidance to those who used to bang their heads on the table every day. The sector is highly qualified in many corners and we normally find that whatever is on the agenda gets the most attention. I believe there is one thing that needs to be placed back on the agenda; the community spirit that organisations provide. The need to do what’s legally obligated should not overshadow the need for us to provide people with somewhere nice to live.
The document refers to Brexit and the risk of goods and services having a delay or not being freely available. However, from experience, organisations in the sector have been building into specifications the need for British manufactured goods to take the leading role in work. Now that doesn’t mean everyone is at the same place on this but I do believe the risk profile should be less than anticipated.
“Health and Safety Compliance”
This is pushed in the document and a re-enforcement of what’s already in place is mentioned. This is great. The re-enforcement specifically points at High-Risk Residential Buildings (HRRB). As the Chairman of the Electrical Safety Round Table Social Housing committee, I am happy to see this as the group (who are all HA and LA providers of Social Housing) have been developing another Code of Practice for Compliance in HRRB. It is a comprehensive document that is sure to help organisations.
“Stock Condition and Asset Management”
One of the interesting points in the document is around stock condition and asset management activities. It’s important to understand that stock condition surveys are essential if carried out by your internal workforce or principle contractors during works. Employing a third-party organisation to survey is a definite no in my book as this almost always leads to a more restricted or forced relationship with the company providing these. I would also state that desktop audits, rather than physical onsite audits, will never return a true picture and again will lead to a forced relationship.
I was disappointed not to read in this document something around departmental silos. Asset Management refers to the task of managing whole life cost models ensuring all data and activity is used. A massive risk in UK Housing now is the issues around each department fulfilling their own objectives even if that means stepping over another department. Silo working and the culture around this needs to be addressed.
I couldn’t help but think a member of my team must have been on the panel that helped write this as data and assurance is at the heart of what The Compliance Workbook does. There were a few statements which I had to double-take!!
“Consumer regulation review reiterates the importance for providers to have systems in place to provide assurance”
Assurance is a very open word that depending on who you talk to depends on its meaning. However, taking into consideration the context of this document we have to assume that assurance is referring to knowing your asset, your workforce, your tenants, your risks and your policies and processes. This doesn’t mean looking forward from now but understanding what’s already there. The reason I thought about my own company at this point is because one major provider just uploaded over 70,000 compliance PDF documents into our platform to glean asset, risk and compliance data to help with benchmarking. To understand what you have, and where you fail, means you are fantastically positioned to include within specifications and process things that remove or reduce these going forward.
To conclude my opinion of this document.
I am very proud of the Regulator for pushing the risk profile document out and concur with the need for organisations to manage and improve data control and risk. I also fully agree that board-level involvement is essential when considering risk and how to deal with it. I would have liked to see a template risk assessment that organisations could use which detailed the common risks in the sector and potential solutions to help remedy this.
I am slightly disappointed that the document has clearly been written with the help of organisations who do Stick Condition surveys as a first step in. It would be great if in the future the regulator approached the coal face to understand the issues.
#UKHousing #AssetManagement #RegTech #Compliance #SocialHousing #Regulator