COASTAL HOUSING GROUP. Coastal Housing Group. Interim Corporate Plan

Transcription

1 COASTAL HOUSING GROUP Coastal Housing Group Interim Corporate Plan

2 COASTAL HOUSING GROUP Introduction Coastal Housing Group is a housing association and a social business operating in Swansea, Neath Port Talbot, Bridgend and Carmarthenshire. We provide homes for rent and sale, and are actively involved in the regeneration of the areas in which we work. Our Vision To provide homes and services that enable our tenants to thrive and the communities we serve to prosper; supported by growing our social business and extending the reach of our homes and services. We are informed in all that we do by Our Values Trust we trust our staff to get the job done Respect we respect our tenants and our staff and have a no blame culture Innovation we try new things so we can do things better Learning and growing we think about what we do and learn from it High Standards we are proud of what we do and aim always to deliver the right service at the right time Coastal s Corporate Plan This corporate plan supports delivery of Coastal s purpose and is designed to ensure we continually improve. It is formed of a strategic document, which outlines the environment and context in which we work (Appendix 1), our key risks (Appendix 2) and key areas of strategic focus. It is an interim strategic document that supports our changing direction during a period of organisational restructure, complimented by an operational action plan against which Coastal will deliver. To enable successful leadership and management of the Group, the corporate plan is focussed in 4 specific areas that underpin Coastal purpose. These are: 1. Sustaining Tenancies 2. Sustaining Communities 3. Sustaining our Local Economy 4. Sustaining Coastal 2

3 COASTAL HOUSING GROUP Coastal Housing Interim Corporate Plan Our Mission Our Strategic Priorities Sustaining Tenancies Sustaining Communities Sustaining our Local Economy Sustaining Coastal Designing services around what matters Regeneration of local communities Commitment to community regeneration Service delivery through organisation capability Improved service to tenants Managing lettings Fostering sustainable housing communities Targeted recruitment and training Robust governance Applications for housing and transfers Collaboration with partners Community development Strategic risk management Repairs Service Lettings Agency IT capability Meeting the needs of young people Communications Maintaining or commitment to supported housing Access to services Wide range of services for older people Collaborative approach to service delivery Financial inclusion Rent policy Tenant skills, training and employability Digital inclusion Quality of our homes Meaningful data Measures & performance Team Objectives Our Purpose Our Values Collaboration with partners Development strategy Investigating innovative finance Maintaining financial strength 3

4 1. Sustaining Tenancies Our Strategic Focus Designing Services around what matters 1. Sustaining Tenancies 2. Sustaining Communities 3. Sustaining our Local Economy 4. Sustaining Coastal Tenants come first in the design and delivery of our services, so that what we provide is what matters to both service users and potential service users. We will design flexible services with capacity to respond to individual demand, and will continue to make sure that we make it easy for people to understand what they can expect from our services and how to access them. We will automatically identify trigger points that identify a shift in support or service required, such that we can further tailor and provide individual meaningful support. This will enable us to support tenants and applicants through changes in welfare benefits, in addition to changes in their lives that impact on their ability to manage their tenancies effectively. Improved Service to Tenants We will provide a housing management service that is a proactive, person centred and community focussed and that will help develop self-sustaining communities. This approach will allow us to understand tenants more holistically and engage with them more proactively. This tailored service, underpinned by the Vanguard method of continuous improvement, centres on asking tenants what matters to you about Coastal s service? and what does a good like look like to you? This outside in approach to the design of the way in which Coastal deliver the service, views the whole organisation as a system from end to end, and enables the implementation of changes resulting from outcomes of action learning. It enables the removal of waste and the eliminating failure demand. We will recognise the individual skills and talents that tenants have to offer so that they can be utilised to respond to tenant demand, and we will invest resources where they have the biggest impact in the community. As a result of this we will have a wider service offer to ensure that we can enable tenants to sustain their tenancies. 4

5 Managing Lettings We are learning from working more closely with tenants what matters to them when they move into a new home, both in terms of how and when we let properties, and how we manage void properties. We will use this knowledge to redesign the flow of our lettings processes. Applications for Housing and Transfers With regard to transfers and new applications we will work with individual tenants to find a solution that meets their circumstances while sustaining their tenancies. We will ensure our stock is designated in the most appropriate way to meet local demand. Repairs Service Through restructuring our services, we will look at how repairs calls are managed, and how repairs appointments are organised. We will monitor resources required and technologies available to provide this service. Lettings Agency We will review the pilot ethical lettings agency model and identify the success and learning about how we manage private sector lettings with transparent costs and fair rents. We will do this in addition to the Welsh Housing Partnership (WHP) scheme. From this we will identify the required business model and way forward for the lettings agency, the resources needed and integrate this fully into our offering. Meet the Housing Needs of Young People and Maintain our Commitment to Supported Housing The provision of ethical lettings through our lettings agency and the WHP enables the provision of additional housing options that may potentially help with both younger people and other groups affected by welfare reform. For tenants with support needs our priority will be to protect existing schemes in the face of budget cuts. In addition we will work with statutory authorities to seek ways to achieve integrated service provision that enables us to maintain the service while saving public money. We will continue to offer tailored support to those tenants that have more intense support requirements, through our Independent Living Assistant service, which will operate across all of our stock 5

6 We will also work with young people in collaboration with partnership agencies and will work more closely to map out how we can better and collectively provide the right support at the right time. Develop a Wide Range of Services for Older People We have already moved towards a fully personalised service that is not dependent on the form of housing. We plan to further develop this service to all our older tenants. We will also consider whether other older people, not in our stock, might want to pay for our highly personalised and high quality service and potentially also for maintenance services provided by our Repairs Team. The Group currently provides housing ranging from extra care to housing in mixed schemes. We plan to develop additional schemes for older owner occupiers that are asset rich and cash poor, providing a safe and secure environment within which to live. Where this involves downsizing we will consider a more explicitly marketed to offer to provide an estate agency service to sell their homes. Collaborative Approach to Service Delivery We will work with partner organisations and managing agents to review the service. This will enable us to map what support and relationship is needed so that we can best support each other to achieve our purpose, and seek to extend the support provided to our tenants by being clear on what good support looks like. Financial Inclusion Tenants may need support with managing money and making claims for Universal Credit. We will restructure our housing management services so that we can respond to tenant demand in these areas. We will continue to work in partnership with organisations that have specific skills in areas such as benefits advice and financial inclusion e.g. Credit Unions and Moneyline Cymru and we are developing skills in house to signpost and provide support. Rent Policy We will monitor and review our rents policy to make sure that rent plus service charges together equate to affordable rents and do not exceed local housing allowance, but in the same time we will make sure our rental income gives adequate resources to manage and maintain our homes. Specifically we will review our rents in line with the new rent policy, consider how we can better reflect differences in property, size, quality, cost in use, and location in the rent and consult our tenants on these changes. 6

7 Tenant Skills, Training and Employability We are developing a clear strategy that supports our purpose and enables the identification and growth of skills amongst our tenants, along with the support required to be more work ready. Through the extension of our targeted recruitment and training initiatives to help tenants we will focus on employability and skills development, identification of potential employment and volunteering opportunities. We will do this in partnership with stakeholders. Digital Inclusion Our digital inclusion strategy will be reviewed and tailored in light of our learning from working more closely with tenants. We will identify what matters from the perspective of our tenants, align our approach to digital inclusion with our IT strategy, and embed this from the outset of the tenancy as part of our offering. Quality of Our Homes We will continue to maintain the quality of our stock so that it continues to meet the Welsh Housing Quality standard and will upgrade our older stock, to improve energy efficiency and ensure that it is meeting current market expectations. We will also continue a programme of selective disposal of housing that no longer meets the needs of our tenants and re-invest the proceeds. We have expanded our in-house repairs team to include electrical works. We will continue to expand this team as is necessary to cover the increasing portfolio of our housing stock. This team provide both responsive repairs and voids that enables us to deliver a consistently high maintenance standard. A further learning outcome of working more closely with tenants will enable us to improve the way in which we operate our repairs service. We will continue to investigate appropriate software and systems that improve the efficiency and value of this service to our tenants. Meaningful Data We will make sure our information systems can give us the right information at the right time and in the right place, so that will include the ability to access data on the doorstep. We will also ensure our dataset is fit for purpose and can capture our exposure to bedroom tax, can pick up missed payments and monitor our arrears in a timely manner. To do this we will restructure the way we are delivering our IT service. 7

8 Measures and Performance We will compile a suite of high level measures. This will enable us to make sound decisions to shape our services. Our measure will include leading measures, based on what matters to customers, and lagging measures that are a consequence of the outcome of doing what matters to customers. Performance information will include data on key areas of operation in the business, to include: Complaints Calls received Calls answered Calls answered Housing Management Housing Management Housing Management Rents The total number of complaints received each quarter. Number of Calls Received % of Calls Abandoned Average Call Answered Wait Time Tenancy Turnover Tenancies Ended Tenancy Turnover - % Tenancy Turnover Average Duration of Tenancies Ended Rent Collection to date - including current arrears expressed as a % of rent due Health, safety and asset management Gas safety Repairs and Maintenance End to End Time for Repairs 8

9 2. Sustaining Communities Regeneration of our Local Communities We will continue a programme of city/town centre mixed use regeneration in Swansea, Neath, Port Talbot and Bridgend, and in doing so ensure that developments contribute to a mixed and vibrant local environment. Our properties will continue to be built and regenerated to a high standard, with a focus on sustainable, mixed use urban regeneration schemes that demonstrate sound financial viability and value for money. We will continue to progress the planning phases of phase two of Urban Village and consider how best to fund and constitute Swansea Creative Hub as a regeneration initiative. We will use investment in housing to lever in community gain, in the form of physical regeneration of an area, the provision of specific facilities, or providing services to a wider population. We will use investment and dedicated staff resource to promote local employment and create opportunities for training and apprenticeships, and to help sustain and grow local firms and industry. We are aware of the impact of the Group on other local services such as schools, health, transport and the police and we will seek to support them. Fostering Sustainable Housing Communities We will continue the roll out of our community intervention project underpinned by the Vanguard method, to identify how we develop and achieve a whole organisation approach to the creation of attractive, safe and well-maintained neighbourhoods with good quality of life for our tenants. This will be through self-sustaining communities, where focus is on the wider community environment, relationships with neighbours, providing the opportunity for tenants to use their skills to give something back to their community. What this looks like in practice will vary from community to community. Collaboration with Partners We will work closely with partners to deliver proactive services to support our tenants and communities, to develop and enhance our service delivery and enable us to better manage risk. This will include working with the Local Authorities in our operating areas in the delivery of strategic housing, such that we can identify and provide solutions to local issues (such as the Ynys Lee Communities First LIFT project). 9

10 We are the preferred partner in Swansea, Neath Port Talbot and Bridgend for the Vibrant and Viable Places and People Programmes, and will continue to develop and foster these and other partnerships. We will also work in partnership with the Local Heath Boards, where we can share and use local knowledge and resources to enable the delivery of preventative health initiatives and part of the wider health agenda. We will continue to engage proactively with all our stakeholders, where we will seek and monitor feedback and expectations, foster relationships and share expertise and support so that we can jointly deliver desired outcomes and continually improve. 10

11 3. Sustaining our Local Economy Commitment to Community Regeneration We will continue our commitment to community regeneration and promote the collective benefits of community regeneration as well as physical regeneration. We will continue to play an active part in alleviating poverty and inequality and sustaining and growing the local economy. This in turn will benefit our tenants and our communities. Targeted Recruitment and Training We have a dedicated targeted training and recruitment function and have invested resources in growing this resource to ensure we maximise the benefits derived from our development and maintenance contracts. We are working to identify a clear strategy that supports our purpose and enables the identification and growth of skills amongst our tenants along with the provision of opportunities in our local communities. Community Development We will continue to utilise the resource of our Community Inclusion Manager to address the more complex issues in our communities and to promote our Tenancy Sustainability Scheme. We will continue to work with the Swansea High Street artistic and social enterprise community as part of our creative cluster initiative and will build on our successful collaboration as a key partner in the Ideas, People and Places partnership. 11

12 4. Sustaining Coastal Service Delivery through Organisational Capability The quality of a service depends on our ability to deliver what people want at the point of demand. That in itself relies on: clarity of organisational purpose and a clear set of values, whole organisation aligned to delivery of our purpose, with the capability, skills and tools to deliver successfully, the engagement, motivation and skills of staff, the capability of the organisation to deliver resources to that person at the point of demand. In a period of rapid change the ability of Coastal to be flexible and adapt quickly will be critical to its success. The Leadership team we will need to have the strategic planning and delivery capability to make step changes effectively. Coastal s HR and Organisational Development strategy focuses on areas to include cultural change, organisation capability, leadership and succession planning and underpins our corporate plan. As part of this strategy we will continue to embed systems thinking to facilitation a lean, agile business capable of delivering change. We will continue to review and develop structures that encourage innovation and sound timely decision making, where learning and collaboration is embedded into our day to day working. We will continue to foster an environment which stimulates innovation and creativity both staff and board, so that we can continue to be an employer of choice that attracts and retains the best possible staff and board members. We will further embed our leadership, management development and coaching programmes and will implement a performance framework based on sound principles, underpinned by the Vanguard method. This will be complimented by objectives in areas of accountability. Our learning and development strategy will be flexible to support staff to acquire the skills needed to deliver our services and we will continue to be a learning organisation through systems thinking, measuring whether we are doing a good job, learning by experimenting and from feedback, working across the organisation and sharing knowledge. Our regular monitoring of staff engagement through third party surveys such as Best Companies, in-house surveys and peer to peer reviews enables us to obtain 12

13 and use feedback to make further improvements. We will continue to help to lead CHC s HR Network with a view to learning from and providing support to our peers. We will continue to act in the interests of the organisation, its tenants and service users. The way we work is underpinned by a robust group structure that supports the delivery of our services that is able to withstand change in demand and in the environment in which we operate. We will continue to review our structures such that they remain fit for purpose, and will maintain openness and transparency, with activities aligned to the diversity of the community on which we operate. Robust Governance We will continue to develop our governance model so that it enables a structure and culture that supports a high performing board. We are committed to maintaining a diverse board, representative of a mix of the right skills and gender balance, with a development and a succession plan that supports and facilitates this. We will continue to monitor the performance of the board and enable specialist skills development through subcommittees focussing on specialist areas i.e. governance & remuneration, finance & development, audit and risk. Strategic Risk Management We manage strategic risk collectively as a management team and board, through annual risk workshop and quarterly reviews focussed on sector risk and wider strategic risk. Our areas of risk are highlighted and incorporated within this corporate plan so they can be proactively managed to mitigate them and new or emerging risk can be identified and planned for. IT Capability Our Information Technology strategy continues to be aligned to our service delivery and our corporate plan will be implemented holistically and proactively across the Group. Our focus is on data and information management, ability to access information remotely so that staff can work more closely with tenants providing relevant accurate information on the doorstep, the provision of equipment, systems and Apps that support our strategy, the building of internal skills and IT capability and digital inclusion. Security of systems and of data and information remain high in our priorities. Communications We will continue to implement our Communications strategy, focussing on external and internal communication, with clear and relevant messages to our stakeholders. We will measure the impact of what we are doing and the message we are sending to make sure our message is aligned to our values and our reputation is maintained. 13

14 We will continue to develop our website to provide a comprehensive tenant area and utilise other communication channels and social media to compliment this. Access to Services Access to services at Coastal will remain fair and open, based on a set of principles to help is be clear on what fair looks like. We will take into account Equality Impact Assessments guidance in making such decisions. A focus on what matters to our tenants underpins our view on fairness. We will continue to deliver flexible services that deliver what matters to individuals, with a fair outcome being what needs to be done from a tenant perspective to create a sustainable tenancy and achieve what they regard as a good life. This is underpinned by the design of service delivery based on the what matters to you? approach. Collaboration with Partners Coastal operates in a collaborative environment. The support of stakeholders is critical in all areas of the business. We will continue to build support by establishing long term relationships, so that stakeholders know that we are committed to the communities that we serve and by delivering on promises, by being trustworthy, entrepreneurial and taking relationships seriously. We will continue to play an active role in helping the sector through our umbrella body CHC contributing to leading the National Council, Finance Forum and HR network. Development Strategy Our 5-year development strategy to include Pennant Homes is to prioritise our areas of focus and enables us to have a robust 5-year pipeline for delivering the social housing programme. We will continue to pursue S.106 planning, seek opportunities for social rent, build or acquire schemes for the next phases of the Welsh Housing Partnership, pursue opportunities to provide low cost home ownership where it is economic to do so, and look to take advantage of the Help to Buy scheme. We will look to deliver mixed schemes where possible, and we will work up a methodology for how we arrive at the mix. We will continue to develop our ethical lettings agency model through further establishing relationships with private landlords to widen the offer to the public and in particular those groups in housing need who cannot easily access social housing, as highlighted under 1. Sustaining Tenancies above. 14

15 Investigating Innovative Finance and Maintaining Financial Strength The ability to fund our activity effectively is fundamental. We will continue to seek efficiencies and to create a culture that supports running a social business. We will look to protect our existing income streams, develop new sources of income and use our assets and resources as effectively as possible. We will use our financial strength to lever in additional finance at competitive rates for the development of new properties and will continue to maintain close relationships with funders. We will continue to monitor and review our loan portfolio and treasury management, level value from our commercial portfolio, and review our value for money strategy, so that our financial arrangements and provision support our business plan for the next 3-5 years. We will pursue new sources of funding, for example regeneration grants and new financing from the capital markets. We will also continue to investigate financing via joint venture partnerships and the opportunities presented. We will continue to implement our value for money strategy and seek to further improve cash generation through economies of scope and scale, effective VAT and tax planning and widening our service offer. 15

16 External Environment Appendix 1 Demographic Factors Older People The number of older people is rising, it is predicted that households headed by someone over 65 will rise from 25% to 33% of the population, with the biggest increase in the over 85 s age group. The traditional models of housing for older people do not meet the differing aspirations and needs of this growing group. Housing and Young People Lack of available credit, shortage of housing supply and high youth employment are impacting the age group. Research predicts that young people in particular will struggle both to get on the housing ladder and to access social housing. Those most affected will be young families, those on low incomes and those who have support needs. By 2020 around 1.5 more million young people in the UK will need to access the private rented sector, but this sector currently provides unsecure tenancies, requires bonds and charges higher rents. Without reform and / or specific interventions in the housing system young people will find the private sector increasingly out of their reach. Poverty, Social Exclusion and In-work poverty During this recession GDP has flat-lined but unemployment has not risen as much as predicted. This is largely due to the increase in the low-pay, no-pay jobs market and the growing phenomenon of in-work poverty. 6.1 million people in poverty are in working households, more than those who are unemployed, and 1.4 million part time workers want full time work. People also fall in and out of poverty; 33% of people experience one period of poverty in a four year period. Welfare Reform The reduction on housing benefit for over-occupation, or the bedroom tax came into effect on 2 nd April 2013 and whilst there are now more exemptions from this, many tenants are still affected. Universal Credit will gradually be phased in, and begins in Neath Port Talbot in February The results from the universal credit pilots have been published and they show rent arrears running at best around 5% and in many cases in the region of 8-9%. The UK government welfare reform agenda will inevitably impact on the financial viability of Associations. 16

17 Housing Policy, Government Funding and Health The overall capital grant programme in Wales, along with capital budgets generally, has been reduced. Whilst the Welsh Government remains committed to social housing, there is an increasing divergence from the policy in Westminster, where there is a move away from social housing to affordable housing with a low grant high rent regime, and reliance on the private sector. This accompanied by other public spending cuts result in lower income and a need to identify innovative ways of financing Coastal s activities. The general election in 2105 creates uncertainty and is likely to impact on housing policy. Health, housing and social care is becoming more integrated, leading to increased pressure on the health service and resultant budget cuts. This will impact on housing and housing demand, and will lead to the need for closer working between Housing Associations and Local Health Boards to enable the provision of housing, care and support. Local Authority Reorganisation and Reduction in Public Sector Funding The impact of the Williams Commission 2014 report is yet to be implemented and local authority reorganisation is expected as a direct result. Funding streams are likely to reduce due to rationalisation due to a shift in priorities, leading to a direct an impact on decision making and longer term planning. Development Costs and Financing Despite rising margins, long term financing rates are at historic lows. However land costs have not dropped as low as they might in a recession with owners holding rather than selling. Developers and contractors are increasingly risk averse with many developers pulling out of Wales, or at least Wales west of Cardiff. Main contractors are becoming increasingly risk averse too, which is reflected either in them not bidding for contracts unless they are very large, or in them pricing in risk resulting in a significant increase in their margins. Environmental/Regulatory changes Associations need to meet higher standards for both new and existing stock to meet both regulatory and tenant needs, particularly around energy efficiency, and fire safety. 17

18 Coastal s Risks Appendix 2 Welfare Reform and Increased Support Requirements for all Tenants Many Coastal tenants are under-occupying their homes according to the definition in the welfare benefit changes. A reduction in income means not all rent will be paid. Universal credit is being phased in with full implementation by Claimants will be paid their benefits direct four weekly in arrears. Universal credit begins in Neath Port Talbot in February This potentially will lead to a reduction in income for the Group. As a consequence of welfare reform a wider group of tenants will need support as well as older people and people with special needs. They will need in support in areas such as responding to bedroom tax, claiming universal credit and managing their money and tenancies, leading to a potential increase in demand. (Identified in Coastal Housing Strategic Risk Register risk 1. and 14.) Public Sector Reorganisation The Williams Commission report 2014 recommends significant pubic sector reorganisation in Wales. This may impact on funding streams and is likely to have an impact on decision making and longer term planning in the short to medium term (2-5 years). Maintaining and further developing relationships with key stakeholders is essential. (Identified in Coastal Housing Strategic Risk Register risk 2. and 8.) Restructure of the Sector Restructure within the sector or failure of another Association could lead to consolidation, which would require careful planning, structuring and sound management. Focus could be lost on the core business leading to impact on service delivery if not managed correctly. (Identified in Coastal Housing Strategic Risk Register risk 3.) Regeneration The group is heavily committed to mixed use regeneration, particularly in and around High Street, Swansea. This carries both financial and reputational risk if the programme does not succeed. (Identified in Coastal Housing Strategic Risk Register risk 4.) 18

19 Development Strategy The Group has a clear development strategy across Swansea, Neath Port Talbot and Bridgend. There are challenges with delivering this strategy, particularly relation to contractor choice and quality of build, product mix, managing expectations and political pressure. The Group is working towards a mixed development model, which includes the sale of properties. A further fall in the housing market, land values remaining inflated, and / or risk averse pricing from contractors may make this difficult to deliver. (Identified in Coastal Housing Strategic Risk Register risk 5.) Governance The Group has sound governance arrangements in place that have been recently reviewed and enhanced. It is essential to continue to make sure that these arrangements are robust, fit for purpose, effectively monitored and support Community Housing Cymru s (CHC) Code of Governance, whilst also underpinned by a good and transparent relationship with Welsh Government s Regulation Team. This will enable us to ensure regulatory compliance and confidence in the Group, and will avoid increased scrutiny and reputational damage. (Identified in Coastal Housing Strategic Risk Register risk 6., 7. and 9.) Clear Vision and Direction Supported by Aligned Organisational Development The Group has a corporate plan spanning a 5 year timeframe. It is essential that the Group has a clear vision and direction for the next 3 5 years, with a Board and senior management who have the right skill sets and capability to deliver. Further embedding robust leadership based on sound principles and consistent management style, underpinned by a performance framework is required. This, along with continuing to embed the Vanguard method of systems thinking are key to enabling Coastal to be high performing, sustainable and financially sustainable, and enable Coastal to make the step changes required to be fit for purpose and growth in a challenging environment. (Identified in Coastal Housing Strategic Risk Register risk 6., and 13.) Developing New Income Streams and Making Further Efficiency Savings Welfare reform will reduce our income. We will need to have the organisational skills and capacity to develop new income streams and make further savings. We will also need to ensure that we have sufficient assets to secure against borrowing and an appropriate level of gearing. (Identified in Coastal Housing Strategic Risk Register risk 10.) 19

20 Information and Data The Group realises the importance and benefit of having accurate, up-to-date, clean data underpinned by measures that enable us to be informed, make sound decisions and to ensure business continuity. Alongside this is need to ensure maintenance and security of that data to avoid data loss, unreliable information and a negative impact on service delivery and reputation. (Identified in Coastal Housing Strategic Risk Register risk 11. and 15.) Understanding Our Business Model We are developing our business model in response to a changing environment driven by changes both in Wales and emanating from Westminster. There is a lack of understanding on the part of local and national government of the impact on Association s of these fundamental changes that are taking place in public funding, the market and the environment. As a result they do not fully understand the changes we are making to the way we work, or the challenges we face. The Regulatory regime in Wales has only partly recognised the implications of the amount of long term debt many Registered Social Landlord s (RSL) have on their balance sheets and what this means for their risk profile in the light of Welfare Reform. If an RSL does get into financial difficulties it will impact the sector as a whole with an adverse effect on our ability to borrow at an affordable price and lender relationships. (Identified in Coastal Housing Strategic Risk Register risk 2. and 8.) 20