Size shouldn't matter to the TSA
Does it seem a little odd to anyone else that the new regulatory regime announced by the Tenant Services Authority is not just light on guidance as to how the new rules will apply to providers with 1,000 units or less, but is completely silent?
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For boards of smaller associations like mine, this must be a worry. What are we to make of this new world of self propelling co-regulation? Is this the unbearable lightness of regulation?
What is a little irritating is that smaller housing associations will be subject to an unspecified and lighter regime than larger, more risky associations but while this is welcome on one level, it is difficult to see what that might mean in practice.
Is it particularly sensible to expose those organisations without the in-house capacity for policy and strategic analysis?
Unfortunately, this is a repeating pattern. The Housing Corporation tended to issue guidance that was primarily focused on larger associations and smaller providers had to try to work out, sometimes by a process of divination, how the regulator was thinking.
Yes, we like the idea of co-regulation and we very much welcome this new approach. In practice, the TSA has an awful lot on its plate, with its long-term future hanging in the balance for example, and we will report to our boards on what we understand by the thrust of the new regime.
However, it is high time for the regulator to say whether it was its intention to work out the details of the (very unclear) arrangements for smaller associations post 1 April, that is, what does ‘proportionality’ look like in practice, or to have deliberately decided that, in this new ‘grown up’ world of consumer-focused regulation, that small associations should not expect any more ‘hand holding’ and just get on with it.
If there is no master plan or road map for further discussion on these matters with umbrella bodies - which the TSA hints at - then do please let us know.
We can bear the lightness of regulation (and apologies to Milan Kundera for (mis) appropriating the title of his book) but it would be better if the TSA could be clear and we can all get on with it.
Mike Wilkins, chief executive of Ducane Housing Association and treasurer of g320 (representing smaller housing associations in London)