UK: RP Issues - A Briefing For Registered Providers Of Social Housing - Winter 2011/12

Last Updated: 9 November 2011
Article by Jonathan Pryor

Editor's comment

So much is changing at the moment for the RP sector that it is hard to keep up. We have dramatic changes to funding, the nature of regulation and financial reporting, all at a time when the spotlight on demonstrating to stakeholders the value for money delivered by the sector is about to become much more probing.

This newsletter provides an update on some of these changes. There is an informative article on the significant changes to service charge accounts. This is followed by two articles providing insight into the dramatic changes affecting the sector from the move towards international financial reporting standards (IFRS). We then discuss a really informative survey that we have commissioned covering both the sector's opinions of the challenges it faces and their views on Smith & Williamson. Thank you very much to all those RPs that took part; it has been invaluable.

Our last two articles discuss the new rules on tainted donations and some of the key accounting questions raised as a result of the new funding regime. Finally we round off with a reminder of our Executive Reward Survey, exclusively focused on the RP sector.

SERVICE CHARGES NEW GUIDANCE EXPECTED

By Andrew Bond

The Commonhold and Leasehold Reform Act 2002 was expected to have a major impact on a number of areas of leasehold management for housing associations and others. In the event, while many of the new regulations anticipated under the Act have come into law, those most directly affecting accounting were never enacted. Last year the new Government let it be known that it was unlikely that it would enact these regulations at all. As a result, legislation regarding the form and content of service charge accounts, independent accountants' reports and designated bank accounts are now no longer expected.

While the housing association sector has adopted good practice over a number of years and is exempt from some elements of the legislation, an imminent new publication produced by a joint working party of the ICAEW, Scottish and Certified accounting bodies, the Association of Residential Managing Agents and RICS is likely to be of interest. A working group was formed by these bodies largely as a result of the 'void' it was felt existed as a result of the failure of the anticipated regulations to come into force. An initial consultation document was issued in October 2010. Following that a range of issues were debated and, because of the difficulty in resolving some issues, Counsel's opinion was sought. The publication is now at final draft stage and may well have been issued by the time this newsletter is distributed. While not directed primarily at housing associations, RPs may wish to consider whether some of the content should influence their own working practices; key points are as follows.

There is a distinction to be made between service charge accounts and the statutory accounts of the company that makes the service charges. Service charge accounts should contain an income and expenditure account and ordinarily be drawn up on an accruals basis with a balance sheet.

The group was unable to resolve satisfactorily whether variable service charges should be accounted for within the accounts of the company owning the freehold to the relevant property. The current accounting determination for RPs requires that service charges are accounted for in the accounts of the RPs. However, the issue is likely to go to the ASB's Urgent Issues Task Force. It will be interesting to see what develops should that group decide that given that essentially an RP (or any other body) cannot benefit from trust funds raised to meet service charge obligations, these amounts should be excluded from the accounts.

Many contributors to the document argued that the content of leases, which in many instances mention an audit, did not mean an audit in accordance with International Standards on Auditing was necessary. Where leases are over 30 years old there were actually no auditing standards in existence when they were drawn up, so this is not unreasonable. A further issue arose in that International Standards on Auditing require a recognised accounting framework against which to report. No such framework exists for service charge accounts. In that context, ISA 800, relating to auditing special purpose financial statements, has been suggested as the appropriate auditing standard to report against. Also suggested, where appropriate, are agreed upon procedures leading to a report of factual findings where an audit is not required.

Model service charges accounts contained within the new guidance are likely to become standard for private sector residential managers. RPs may therefore wish to watch out for this publication, which is expected imminently and will provide a useful tool against which to review their existing practice.

THE FUTURE OF RP REPORTING

By Jackie Oakes

There has been a considerable amount of commentary in articles and conferences on the potential substantial changes to RP financial reporting that are likely to emanate from the move towards IFRS. The sector responded amazingly well to the recently completed consultation on the draft changes. As a result, some very significant and positive changes are likely to be made. The Accounting Standards Board (ASB) is yet to formally report back, but there is no doubt that they have been considering the responses made by the sector with considerable care and in some cases, some concern. This article therefore only provides an outline of what may happen next and readers should be aware that this is subject to change given this is a moving position.

There were arguably seven major areas of concern within the original proposals.

  1. Capitalised interest The original proposals would have led to capitalisation being barred, with restatement of previously capitalised interest into expense. It seems certain now that the ASB will reverse this and either permit or possibly require interest to be capitalised.
  2. Valuations of housing properties The original proposals would have prevented future valuation movements from being reflected in the accounts, although there were transitional provisions that permitted existing valuations to be "frozen". Again, it seems certain now that the ASB will permit valuations to be used, although we will need to watch the precise phrasing carefully to ensure that the various types of valuation applied within the sector are not inappropriately restricted.
  3. Cost The original proposals were likely to lead to substantial transitional costs for the sector. There are no specific indications from the ASB as to its response to this point, but it has signalled that it also has concerns and will be considering this point further.
  4. Recognition of grant in the income and expenditure account The original proposals required grant to be shown gross and implied that there would be no necessary correlation between the recognition within the income and expenditure (I&E) account of the grant and the underlying expenditure. Although the requirements for depreciation were similar, it was proposed grant would be recognised in the I&E account once the performance conditions were met. At this stage, it is unclear how the ASB will respond to the concerns expressed on this point, but we understand that it is trying to devise an appropriate model by which the I&E can legitimately be more in line.
  5. Grant grossed up The original proposals would have prohibited the netting off of grant on the balance sheet, as is presently the case within the housing association sector. We are expecting this to remain the case and that netting off will be barred. This clearly will have profound implications for the sector with up to £40bn of grant being shown within creditors, subject to the point above on whether some of the balance can be treated as income. The Statement of Recommended Practice (SORP) working party is considering this point pending the outcome of the ASB's deliberations and therefore more guidance should be available in the coming months.
  6. Financial instruments The original proposals would have revolutionised accounting for this area. This remains very much the expectation. Please see the separate article on this subject on the next page.
  7. Inconsistency in requirements for those RPs with listed bonds The original proposals envisaged classifying RPs with listed bonds differently from other RPs. This would require them to produce financial statements in accordance with full EU adopted IFRS rather than the simplified and modified version, financial reporting standard for medium-sized entities (FRSME). The ASB have indicated that this will no longer be the case, except possibly for entities with listed bonds that also happen to be Companies Act entities. We are not aware of any association that falls into both of these categories, but it might still be a problem for a very small number.

The ASB is expected to issue a revised draft of the FRSME in early 2012 for consultation. It will be important for the sector to review this in-depth to ensure that any further concerns are highlighted and discussed with the ASB. We will be monitoring the position carefully.

FOOD FOR THOUGHT

By Jonathan Pryor

This article is not a light read. Before starting, we strongly recommend you take a deep breath and be prepared to need to read it more than once. Unfortunately, it is only an amuse-bouche in what might be described as a full seven course banquet awaiting you from the delights of accounting for financial instruments once the draft FRSME comes into effect. In fact, a more appropriate analogy might be that it represents a single crumb left over from the meal enjoyed by the previous patrons.

There is a huge amount of change coming to the sector as the previous article on the future of RP reporting stated. However, the most challenging area is undoubtedly the accounting for financial instruments. This article comments on only one specific part of the proposed changes: how to decide whether a financial instrument is categorised as 'basic' or 'other'.

If it is 'basic', it will fall within the relatively straightforward environment set out in section 11 of the draft FRSME. However, if it is 'other', it will need to be accounted for in the much more challenging environment within section 12. This matters because (with a few exceptions) if a financial instrument falls within section 12, the normal accounting treatment will be to record it at fair value at each period end. This could potentially result in huge volatility. Although in some cases there may be steps an entity can take to mitigate the effect, for example by establishing hedge accounting, these are also very complex and can easily fail because one or more of the detailed requirements are not adequately met. Some particular instruments in place within the sector are unlikely to ever be able to meet the hedge accounting requirements, suggesting that either the affected association will need to break the instrument before the changes come into effect, establish another method of limiting the volatility (e.g. entering into a similar but opposite financial instrument) or accept the volatility.

The current accounting process that we are familiar with is largely benign in that most financial instruments are recorded at either the lower of cost and net realisable value (if they are an asset), or the level of net proceeds from the instrument with issue costs, such as arrangement fees, amortised over the life of the instrument (if they are a liability).

Under the current proposals within the draft FRSME, although the logic is different, in practice most 'basic' financial instruments are treated in much the same way as they have been in the past. However, there will be exceptions, for example suppose an association provides an interest-free loan to a subsidiary. This will be recorded initially at the present value of future payments discounted at a market rate of interest for a similar debt instrument. It will therefore be recorded at a lower figure than the amount lent, resulting in a gain in the subsidiary and a loss in the association.

More complex financial instruments are also treated very differently from current practice. Furthermore, quite a few instruments that at present we would regard as not that complicated are nevertheless classified as 'other financial instruments' and therefore fall within this more challenging accounting section.

The decision over whether something is 'basic' or 'other' is based on rules spelt out in the draft FRSME. They specify that if the instrument meets the tests, it is 'basic', however, if it does not, then it is 'other'. The definition does not seem to permit any judgement or flexibility. The tests are that the financial instrument needs to be in one of the following four categories:

  1. cash
  2. a debt instrument that meets certain conditions (see below)
  3. a commitment to receive a loan that meets these same conditions and in addition cannot be settled net in cash
  4. an investment in shares that are both non-convertible and non-puttable.

The conditions that need to be met for a debt instrument or commitment to receive a loan to be classified as 'basic' are as follows.

  1. The return to the holder (e.g. a lender or bond holder) must be either a fixed amount, a fixed rate of return over the life of the instrument, a variable rate that is equal to a single referenced quoted or observable interest rate (such as the London interbank offered rate (LIBOR)) or some combination of these rates provided that they are all positive.
  2. There is no contractual provision that could result in the holder losing principal or interest.
  3. Any contractual provision permitting the borrower to prepay or permitting the issuer to request early payment are not contingent on future events.
  4. There are no conditional returns or repayment provisions except for the variable rates or prepayment provisions as discussed.

At first glance, these may seem reasonable definitions. However, there are many examples of financial instruments in place within the sector which will not meet these definitions and will therefore be classified as 'other'. Here are a few illustrative examples:

  • a loan which includes a clause that enables the lender to request repayment if the applicable taxation or accounting requirements change (fails (c))
  • an option, unless it is embedded within another financial instrument and the combination meets the tests specified above (fails (a))
  • an inter-company loan to a subsidiary which has net liabilities, or is otherwise reliant on intra-group support to meet its obligations and in relation to which the lender and borrower have agreed that parts of the balances will be waived in the event that the subsidiary is unable otherwise to meet its obligations as they fall due (fails (b))
  • a loan in which part of the interest charged is linked to RPI (fails (a)).

However, there are many more types of financial instrument that will not pass this test.

Our advice is for each association to summarise the financial instruments it has in place and then assess which may fall into the 'other' category. You will then need to consider carefully what the accounting treatment will be and whether this is potentially damaging to the association.

We will be writing further articles on this subject in the future but professional advice is almost certainly going to be wise, even if you think your financial instruments only fall into the 'basic' category.

SURVEYING THE FIELD

By Julie Mutton

Smith & Williamson is always keen to provide the highest quality service to clients. We monitor client satisfaction and perception of our services in the marketplace and so recently commissioned a survey from Resolve Marketing UK Limited. 33 clients (finance directors (FDs) and audit committee chairs) and 35 nonclient FDs were interviewed. A number of conclusions were drawn regarding Smith & Williamson specifically, as well as perceptions about the audit market generally. The survey also enquired as to what are the current concerns of FDs. We were able to compare results to those of a similar survey undertaken on behalf of Smith & Williamson in 2007.

Challenges for the RP sector

56% of respondents considered uncertainty and change in government policy to be their biggest challenge compared to 23% in 2007. Conversely, 21% of respondents were most concerned about the economic climate in 2007 compared to 3% in 2011. This is despite the current recession and confirms that changes and uncertainties in government funding are expected to have a greater impact on the RP sector than the present economic climate – although arguably the former is a byproduct of the latter.

There was a marked (though perhaps unsurprising) change in opinion regarding regulation. In 2007 76% of respondents agreed (with 7% disagreeing) that there was too much regulation in the sector. In 2011 only 27% agreed and 51% disagreed.

Opinion regarding zero-carbon homes has also moved significantly over the four years between surveys. In 2007 66% agreed (14% disagreed) that zero-carbon homes should become standard, whereas in 2011 only 32% agreed and 38% disagreed.

Client and non-client FDs were asked how helpful their auditors were in assisting them to respond to the challenges identified. 68% of Smith & Williamson clients felt that the help given by their auditors was either good or very good, compared to 65% of non-client FDs.

Smith & Williamson services

Key findings of the survey were as follows.

  • 96% of client FDs stated that Smith & Williamson's performance met or exceeded expectations.
  • The percentage of those whose expectations were exceeded had increased significantly compared to 2007.
  • 26 out of 28 client FDs would recommend Smith & Williamson and 50% of them already had.

A surprise for the Smith & Williamson team was the view expressed by 54% of clients that Smith & Williamson should improve their communication about additional services provided by the firm. We will of course be addressing this point.

Awareness of the firm is high, with 94% of non-client FDs being aware of the firm and 41% having had direct commercial or personal contact with the team. There was an increase in those that felt that Smith & Williamson was "very" rather than "reasonably" well known compared to 2007, reflecting a considerable improvement in the firm's profile.

Tainted donations Do the new rules really help?

By Claire Perrett

Since 2006 we have had specific rules for substantive donor anti-avoidance, targeting donations where value can be extracted from the charity. These caught donations of over £25,000 within 12 months or £150,000 over 6 years, but there were some RP exemptions. However, care was still needed to ensure that donations were not caught.

The new tainted donations rules introduced in April 2011 are meant to simplify the use of the exemption for RPs and stop the innocent from being caught. However, given the complicated structures that some housing association groups currently operate under, the new exemptions may not apply. The new rules also do not have a de minimis and so can catch any size donation or return of value. Care therefore continues to be needed when structuring donations.

The new tainted donation rules will apply if all the following conditions are met.

  • the donor or a person connected with them enters into an arrangement where it is reasonable to assume that the donations and arrangements would not be entered into separately
  • one of the main purposes of the arrangements is to obtain a direct or indirect financial advantage from the charity
  • the donor is not a qualifying charityowned company or relevant housing provider linked with the charity to which the donation is made.

A relevant housing association is linked with a charity if it is a whollyowned subsidiary or both the housing association and charity are under the same control; as such the new rules will help most housing associations. However, because of the variety of structures that have arisen within this sector, not all housing association groups will meet the exemption definitions. This means that trading entities within the housing association group could lose gift aid relief on their entire donation if it can be found to be associated with another transaction between the donor company and the charity, where the terms are even marginally unfavourable to the charity. This is a major change to the old rules where there was a size test and the relevant effect was on the receiving charity not the donor entity.

It is important to review your structure to ensure you will not be caught by the new rules that apply for the current year. If you rely on charity donations to eliminate your tax charge it is important to ensure that you will not be caught under the new rules. If the exemption does not apply then all transactions with the charity must be reviewed to ensure there is no risk of return of value.

Accounting under the new funding regime

More questions than answers

By Stuart Quilter

As readers will be aware, the new funding regime is very different in nature to its predecessors. Instead of grant being payable on the basis of the approval level for each individual scheme, it will be paid at a flat rate for the association. There will therefore be some schemes where the grant received is going to be much higher than the association sought to apply and others where the converse will be true. One of the questions arising is therefore going to be how to account for this?

The SORP working party is presently looking at this issue and so we are hoping further advice will be forthcoming early next year. It is possible therefore that when specific guidance is received, some of the questions raised here might need revisiting. However, in the meantime there appears to be a consensus that the grant should not be allocated to a scheme on the basis of the amounts paid. Instead it should be allocated based on the amount claimed in the association's bid, adjusted pro rata for any shortfall in the amount claimed compared to the contract total. This will therefore result in a timing difference between the amounts paid and the amounts recognised, which will be included in debtors or creditors.

A further question arises as to whether grant (now payable under contract) should be accrued. It seems to us to be logical that grant should be accrued as expenditure is incurred, and therefore not recognised solely at the point it becomes payable. The accrual would be made pro rata. This would represent a significant departure from the current accounting norm within the sector.

There is a further set of questions to consider. To the extent that the basis for justifying the bid for grant included conversions of relets into affordable rents, if these were not to happen at the assumed rate would this trigger grounds for impairment? Our view is that the answer to this is no. The assessment made by each association of what it is able to finance is not relevant to the accounting treatment. Impairment would not arise if the scheme proceeds broadly to plan and the level of shortfall (or planned internal subsidy) of the capital costs less grant compared to 'value' is within the parameters set at the date the contract was signed.

What happens if schemes drop in or drop out? The broad answer is that we should continue to account using the above principles but varying the amounts for any schemes not yet completed proportionately. This may prove difficult where the outturn position is not known or where there is a lack of clarity over the impact of the variation. However, the best estimate at the time should be applied. This point is not certain and we will need to discuss further to reach a consensus.

Finally, what happens if relets vary? In our view there are no implications for the accounting for the schemes as the relets are important for the overall affordability of the investment in property but not actually for the specific funding on a scheme by scheme basis. The only area affected is going concern.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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