CROSS-SUBSIDY
62. The Council of Mortgage Lenders argues "the
continual reduction of grant rates has created an over reliance
on cross subsidy for both the delivery of affordable housing but
also the business operating models of associations".[113]
The National Housing Federation states that, typically, 10% of
the cost of building new affordable housing is met by housing
associations through "cross-subsidy". This could take
the form of¯
a) S.106 contributions from the developers of
private homes on sites also being used for affordable housing.
the Home Builders Federation states "in 2006-07, 58% of all
Affordable Housing was delivered through such agreements".[114]
As developers reduce their total number of developments, the contribution
to affordable housing made by s.106 agreements also decreases.
The London Assembly Planning and Housing Committee learnt that
"perhaps 50 per cent to 75 per cent of the expected section
106 financed homes [in London] will not now be delivered due to
the slowdown in the private market sector".[115]
b) Funding from the housing association's own
reserves. These could be made up of, for example¯
i. Shared ownership "staircasing" receipts.
"Staircasing" refers to the practice of selling further
portions of a shared ownership home to the tenant/owner. Until
recently, tenants/owners could only "staircase up" by
increasing their share of the property but, under one of the terms
of the Government's housing rescue package, tenants/owners at
risk of repossession will be given the option to "staircase
down" by decreasing their share of the property. We were
told that the "reduction in mortgage availability, partly
as a result of some lenders now classifying shared ownership mortgages
as "sub-prime", had resulted in reduced sales for associations.[116]
In turn this reduces the level of potential staircasing receipts.
ii. Proceeds from the market sale of existing
properties. The Gentoo Group states "an increasing number
of RSLs are balancing their books through property sales with
6 of the top 20 providers of social housing reporting a combined
total of £129 million through surplus on the sale of fixed
assets in 2007/08".[117]
As the housing market declines, it becomes more difficult for
housing associations to raise money in this way.
Housing associations may also use money from their
"recycled capital grant fund". This is money generated
through the sale of affordable housing which was itself funded
by Social Housing Grant. This money is not returned to the Homes
and Communities Agency but is held by the housing association
and accounted for as if it were new Social Housing Grant.
63. All the different funding streams listed
above are exposed to the vagaries of the housing market and are
liable to dry up during the credit crunch. This is an issue which
was raised repeatedly in both written and oral evidence to our
inquiry. G15 told us "the credit crunch has brought to a
standstill housing associations' ability to cross-subsidise new
homes. This calls into question their ability to meet Government
supply targets without increased Government assistance".[118]
The Intermediary Mortgage Lenders' Association states "the
development model in use in recent years by large and medium sized
associationscross-subsidyis now broken and must
be replaced by one based around higher grant rates and with a
focus on social renting".[119]
Without being able to make up the funds which would previously
have been derived from cross-subsidy, housing associations cannot
continue to develop new homes. This is explained by NHF as follows:
"overall sector viability remains strong and sound because
housing associations are well run and well managed organisations.
But it is precisely this astute financial management that means
associations will not take unwise development risk and will not
continue to develop using a financial model unsuitable for the
current economic climate".[120]
64. The ability of housing associations to
build new affordable homes is critical to the attainment of the
Government's housing targets. If, because of market failures,
they are no longer able to cross-subsidise their development activities
at the same high rate as before, we see no alternative but for
the Government to replace this funding with a higher average percentage
rate of Social Housing Grant. This inevitably means each allocation
of Social Housing Grant will produce fewer units than before,
but this is a better outcome than funding allocations remaining
partially unspent because associations are unable to bring viable
schemes forward.
Contingency planning
65. Given the high levels of exposure to financial
risk being experienced by housing associations as a result of
the credit crunch, it is of fundamental importance that they undertake
robust contingency planning. Some of the written evidence we received
suggested that this was not happening. Unison, for example, reports
"a third of social landlords contacted in a survey by Baker
Tilly [
] have not made contingencies for dealing with the
crisis".[121]
We heard in oral evidence, however, that over 80% of housing associations
already had strategies in place.[122]
Similarly, the Housing Corporation states in written evidence
that a "significant number" of housing associations
have begun to review their business models since the onset of
the credit crunch. It details a number of the measures being taken,
including¯
- "reviewing all uncommitted
development and in particular scaling back on shared ownership
assumptions;
- reviewing their operating cost base;
- looking at sales dependence and how the exposure
can be mitigated; and
- ensuring treasury management strategies are appropriate
for the current situation".[123]
66. As the new independent regulator, the Tenant
Services Authority has oversight of the contingency planning process.
Oral evidence from Peter Marsh, its Chief Executive, suggested
that it is already being very proactive in this role. He told
us that, of the 250 housing associations in development partnerships
with the Homes and Communities Agency, approximately one in three
has tended to be heavily reliant on cross-subsidy. Of that number,
there are "half a dozen which have risks which need to be
addressed and managed in the next six months". The TSA is
managing these six housing associations by asking "to see
cash flows on a weekly basis and we want to talk to the boards
and we want to and are engaging with both their chairs and their
lenders to ensure we understand their response to the threats
posed to them".[124]
The authority is also generating "a cab rank, if you like,
of organisations that would be ready and willing to step in"
should a housing association fail and require takeover by another
housing association.[125]
On 9 January 2009 three large housing associations, Affinity Sutton,
Circle Anglia, and L&Q Group, told the TSA that they would
be willing to lend to housing associations facing financial difficulties.[126]
The TSA has been scenario-testing to ensure it is able to respond
quickly in the event of such a takeover.[127]
A detailed guide to its contingency plans is set out in Annex
C to the Government's response to supplementary written questions
posed by us following the oral evidence session on 16 December
2008.[128] We welcome
the proactive approach being taken by the Tenant Services Authority
to managing the contingency planning of housing associations and
look forward to an update on its effectiveness later in 2009.
100 Cred 43 Back
101
The L & Q Group, Financial Statements 2008 (2008),
p 7. Back
102
Cred 43 Back
103
Cred 39 Back
104
Cred 59 Back
105
Cred 60 Back
106
Crispin Dowler, "Grant rates rise for associations",
Inside Housing (16 January 2009). Back
107
Cred 08 (Intermediary Mortgage Lenders' Association) Back
108
Cred 08 Back
109
Cred 08 Back
110
Cred 06 Back
111
Q 23 Back
112
Q 78 Back
113
Cred 30 Back
114
Cred 42 Back
115
Cred 59 Back
116
Cred 25 (Unison). Back
117
Cred 26 Back
118
Cred 05 Back
119
Cred 08 Back
120
Cred 43 Back
121
Cred 25 Back
122
Q 76 Peter Marsh (TSA) Back
123
Cred 61 Back
124
Q 76 Back
125
Communities and Local Government Committee, oral evidence session
with the Tenant Services Authority, 21 October 2008, Q 7, Peter
Marsh (http://www.publications.parliament.uk/pa/cm200708/cmselect/cmcomloc/uc1123-i/uc112301.htm). Back
126
Crispin Dowler, "Cash-rich landlords agree to bail out peers",
Inside Housing (9 January 2009). Back
127
Communities and Local Government Committee, oral evidence session
with the Tenant Services Authority, 21 October 2008, Q 7, Peter
Marsh (http://www.publications.parliament.uk/pa/cm200708/cmselect/cmcomloc/uc1123-i/uc112301.htm). Back
128
Cred 60A Back