The Governor

Governorthe

HQN'S MAGAZINE FOR BOARDS, EXECUTIVES AND LEADERS SEPTEMBER 2012

The tasks facing Mark Prisk The HCA on regulation Boards of the future Governance round-up

To find out more call Anna Pattison on 01904 557197 or email: [email protected]

Rockingham House St Maurice’s Road York YO31 7JA

HQN Limited Registered in England Reg No. 3087930

Telephone 0845 4747 004Fax 0845 4747 006

Internet www.hqnetwork.co.ukEmail [email protected]

accredit:incomemanagement

The NCH team, including front row, second from left, NickMurphy (Chief Executive), second from right, Janet Storar

MBE (chair of the board and tenant), third from right,Victoria Chilvers (Rent Account Manager); back row, fourth

from left, Ben Chilvers (Rent Operations Manager), thirdfrom right, Tim Millns (Rents and Leaseholder Manager)

HQN Accredit: Income Management

It’s an ace for Nottingham City Homes! “We’re delighted and extremely proud to be the first ALMO in thecountry to receive HQN Accredit: Income Management”

“The accreditation reflects the work that’s gone intotransforming our income management service. It’s been madepossible by all the hard work the team has done both with localpartner agencies and with our own tenants to ensure theirviews are reflected in our policies and practices.

“The accreditation process was objective, rigorous andchallenging with a particular focus on positive outcomes forcustomers. It demonstrates that the work we’re doing really iscreating homes and places where people want to live.”

Richard Holland – Assistant Director of Housing Operations

Congratulations to Nottingham City Homes

HQN recognised the sustained performance and improvements madeover the past few years. The Panel was particularly impressed withNCH’s focus on balancing efficient income management with support for customers, especially those feeling the effects of the current economic downturn.

To find out more, please contact Anna Pattison on 01904 557197,or email [email protected]

support services

Damian Roche,HQN’s Operations

Director and accreditationassessor presents the trophyto Emma Marsh, Director ofCommunities, cheered on

by residents and theneighbourhood

teams

Accredited for estate services

Congratulations to New Charter Homes

It's a pleasure to find an organisation such as New Charter Homes. They're reallyfocused on delivering improvements for residents and adding value to everythingthey do. Getting estate services right is no easy thing. We're thrilled that New Charter has achieved HQN accreditation in estate management services.

HQN’s accreditation tests your services and demonstrates thatthey are best in class – giving you, your staff, your investors and,most importantly, your customers confidence in your service.

Are you up for the challenge?

“After tough scrutiny, we’re absolutely thrilled that our performancehas been independently recognised at a national level. It’sreassurance that we’re delivering a high standard of service whilefocusing on the right things for our customers and communities. I’m so pleased that the neighbourhood teams received such glowing feedback for their incredible dedication. To be awardedaccreditation without conditions or any recommendations is a dream result and a true testament to my teams.”Emma Marsh, Director of Communities

HQN’S MagaziNE foR BoaRdS, ExEcuTivES aNd lEadERS

the Governor SEPTEMBER 2012 3

3 Lessons from the Virgin/First Group squabbleComment by HQN Chief Executive Alistair McIntosh

4 Today I will...The new housing minister and the challengesahead

6 The regulatorWe talk to the man in charge of regulation at the HCA

8 A changing landscapeRichard Moriarty looks at lessons we can learnfrom other regulated sectors

10 Boards of the future Challenging times call for even better boards – but how to develop them?

13 Private propertyIs the increased use of the PRS a game changer for the housing sector?

14 Building the futureIt’s time to take a fresh look at good old-fashionedcouncil housing, says Chloe Fletcher

16 Tweet the neighboursHousing providers need to be part of the socialmedia conversation

From the pressOur regular round-up for the world press’s view of governance

18 Balancing actHow can councils improve performance whilemanaging funding cuts?

(E)merging issuesThe spectre of future merger plans being held up has receded

The hand that rocks the cradleGrant Shapps said he was cutting the nanny state’sapron string – but will they be retied?

The stock answerStock rationalisation deals are becoming more popular

CONTENTS

All articles in The Governor were written by Kate Murray unless otherwise stated.

designed by Paul Miller Prontaprint Scarborough

Print management Turnstone Media & PR (www.turnstonemedia.co.uk)

All summer long we’ve seen Richard Branson bleating on a grainySkype link from his holiday home. Who cares if blue trains are going to ousthis red trains? The answer is a lot of people. One hundred and seventythousand of them signed a petition urging the government to think again.It was another nail in the coffin of the transport minister. She got the sack.

Does this matter to us in housing? Yes it does. Branson claims hetransformed a poor service and boosted satisfaction. Our leaders say thattoo. Virgin outscores the First Group on satisfaction. Despite that, the bidwas lost to First Group as they promised to give the government a lot moremoney. Branson says the government will never see the cash. In any casemany of us will be pushing up daisies when the payments fall due.

For years in housing we have struck a balance between quality and cost.Many tenders place more weight on quality than price. We try and buildaffordable homes in popular areas. All of this is under attack.

Rail passengers are a captive market. Sooner or later governments will takeadvantage of that. Tenants are in the same position. Rents and fares arerocketing up. The government’s PR machine is crucial.

You see a hard-working commuter hunched over a laptop. Thegovernment spies a greedy playboy hogging more than their fair share ofsubsidy. You see a tenant in a home bringing up a family. The governmentspots a bed-blocker stealing a home from someone more deserving. Goodold-fashioned divide and rule.

Don’t look for any help from our regulator. Its predecessor tried to stand upfor tenants. Its one job now is to drive down costs so you can build morehomes. I expect the new housing minister will be demanding to know whythe HCA doesn’t have a firmer grip on value for money. We just can’t havean industry where the regulator does not know why costs vary.

The challenges are mounting up. Costs must fall, balance sheets need tosupport more building and tenants could run out of money to pay the rent.The private sector may get its act together. What are boards doing in response?

We are seeing two trends. Some boards are going down the mutual road.This locks them down into the community. At other places a small group ofexecutives and non-executives come together to call the shots. It doesn’treally matter what you do as long as people of quality and integrity takethe decisions. And they have to get it right. Heaven help them if they relyon experts.

Predicting house prices is a big part of everyone’s business plan. TheSunday Times found that nearly all of the top property analysts we usewere wide of the mark. That’s hardly a surprise as we are engaged inspeculation pure and simple.

Over the next few years we will find out who got it right in housing. Will all the bonds, REITs and other devices work out? Time will tell. Should you bedancing to the government’s tune on costs like First Group? Is it better toenjoy customer support like Virgin does? Can we cut costs and keeptenants happy at the same time? That’s the prize.

Alistair McIntoshChief Executive, HQN

HQN’S MagaziNE foR BoaRdS, ExEcuTivES aNd lEadERSHQN’S MagaziNE foR BoaRdS, ExEcuTivES aNd lEadERS

the Governor SEPTEMBER 20124 5

When a new minister is appointed, it’s only a matter ofminutes before wishlists start landing in the ministerialin-tray. For the latest housing minister Mark Prisk, thepile of requests was a long, and at times contradictory,one. Build more homes to boost the economy and housethose who so desperately need a place to live. Don’t buildtoo many homes for fear of another boom and bust. Cutthe burden of regulation radically to allow developers tobuild more homes. Introduce more regulation to overseethe booming private rented sector.

So which way will Mr Prisk go as he settles in to his newjob? Will he pursue the new ideas he’s already said areneeded to build new homes? His track record suggestshe’ll be get stuck in quickly, if only because his housinglearning curve may not be as steep as some of the newhousing ministers we’ve seen over the years.

Certainly, with career experience as a chartered surveyorand then a stint as construction minister, he’s no strangerto the broader housing market. But what about socialhousing? Riversmead Housing Association, based in MrPrisk’s constituency, has worked with him over the yearsand welcomes his appointment. But the association’sexecutive director Paul Huckstep is in no doubt about thechallenges he will face.

“The message coming out of government is that housingis very much at the top of the political agenda but at themoment it is quite difficult to see where enough newhomes are going to come from that are affordable for themajority of people on low incomes,” he said. “The bottomline is there is a huge mismatch between supply anddemand that is potentially going to affect a wholegeneration of families. Housing should be a concern toeveryone.”

Talking the talk

The government is certainly talking the talk. In thedays after the reshuffle, Mr Prisk said the new housingpackage, announced just after he took on the new job,was an ‘ambitious’ programme in response to the scaleand importance of the challenge ahead, while hisfellow MP Jake Berry said housing was now ‘front andcentre’ of government policy. Many in the housingsector might be tempted to reserve judgement on that.

For although many measures included in the housingpackage launched by David Cameron and Nick Cleggthis month are welcome, there’s a focus on private rentand owner-occupation which might just make thesocial housing sector uneasy. Coming on top of monthsof outright negativity towards social housing – oneverything from housing association pay andtransparency to the ‘unsweated’ assets landlords holdin high value stock – it suggests that the governmenthas yet to be convinced of the central role socialhousing can and should play in ensuring the balancedcommunities of the future. Yes, the recognition of thelink between housing and growth is important. So toois the need to get development moving again, andsome housing providers will play a big role in that. Butwill we there be recognition and support too for sociallandlords in the work they do for those for whom theprivate rented sector and homeownership are not anoption – and for their existing tenants as welfarereform bites?

As social landlords strive to do more for less, what the new minister says and does beyond the numbersgame will be crucial.

”The National HousingFederation has long argued forthe vital role housing has to playin driving growth and MarkPrisk's strong economic andbusiness experience will proveinvaluable in making that case.”

David Orr, chief executive,National Housing Federation

”It is a really important job, and I am sure hewill bring to it much-needed skill and insight,and I sincerely hope he will also bring a newsense of understanding and urgency. Myexperience from dealing with [Mark Prisk] is that he is a modest man, unlike hispredecessor, who gave hubris a bad name.”

Jack DromeyShadow housing minister

”The ultimate test for [the housingpackage] announcements will not be in the corridors of Westminster andWhitehall but on streets up and downthe country: will they result in newbricks on the ground and asignificant increase in the delivery ofnew, decent, affordable housing?”

Leslie Morphy, chief executive, Crisis

”We call for the structure of the UK housebuilding sector and restrictive planning laws to be reviewed. Also, steps should also be taken to ensure house prices are aligned withpeople's wages, which would allow morepeople move out of private rented and socialhousing accommodation to becoming homeowners – a key aspiration for many.”

Grenville Turner, chief executive, Countrywide

”Enter Mark Prisk. He does not comewith a brief to rewrite housing policy,nor with any obvious axe to grind. Buthe does arrive at a moment when thegovernment is acutely interested in whathousing can do to reboot the economy.”

Matthew Warburton, policy adviser,Association of Retained Council Housing

the Governor SEPTEMBER 2012


7

“There’s a paradigm shift.” That’s how Matthew Bailes,director of regulation at the Homes and CommunitiesAgency, describes the changes shaking up the socialhousing sector. Less public funding, new pressures todrive efficiency, greater complexity in stacking upfinancing deals, coping with the affordable rent modeland the impact of welfare reform head the list ofchallenges for housing providers – and the new set-upcharged with regulating them.

“It’s a very different world from the world four or fiveyears ago – and it’s still changing,” says Mr Bailes. “Thebig challenge for me and for the rest of the team is tokeep pace with that.”

As he points out, the move away from what he calls the ‘settled model’ of social housing – whereproviders focused on one or two core products, hadstraightforward access to funding and where theywere guaranteed their rental stream by the benefitsystem – is transforming the face of the sector. And asthat change continues, providers need to ensure theirleadership teams are well placed to respond.

A risky, complex world

“What we really need is the skills and capacity oforganisations at board and executive level to line upwith this riskier world and more complex world,” saysMr Bailes. “We would expect boards and executives toevolve quite rapidly to meet these challenges.Different providers are very different – some willconcentrate on their core rented business and that’s aperfectly reasonable strategy. They may not needsome of the commercial skills that other organisationspursuing different things might do, but the key thingis that the quality of the decision-makers lines up withthe risk and complexity of the business.”

He says that ‘by and large’ the new regulatory set-up,in place at the HCA since the abolition of the TenantServices Authority in April, has the assurances it needsthat housing providers are ready to cope. But he admitsthat there are some areas where some organisationshave struggled – he cites treasury managements asone. And with ‘some big challenges around the corner’,the regulator will be expecting boards and executivesto be at the top of their game, especially if they areplanning on going into new business areas.

“The challenges will grow over time. People need to go in with a clear mind and clear strategy formanaging risks and with the right skills andexperience to manage those risks,” he says. “It will be a matter for boards to determine the best way ofmeeting their objectives in this new world.”

Appropriate safeguards

The regulator plans to do more work in this area, hereveals, in particular looking at ring-fencing and whatthe ‘appropriate safeguards’ might be to protect a socialhousing business against the risks of unregisteredactivities carried out by another part of the organisation.

One of the big changes for providers is the newexpectation that they will drive value for money. Thatwill require them going further than they have beforein looking at the way they run their business. The HCA’sown work on unit costs could, through the statisticalmethod of regression analysis, only explain about halfof the variation in unit costs across different providers.But it is up to boards, says Mr Bailes, to be asking thequestions about their running costs and those ofother organisations. Plus, they should be looking atnew ways of running their business better.

”Boards are responsible for running theirorganisations and the regulator is looking forassurance from them that risks are beingmanaged effectively. This places a premium onthe boards and executive teams having theappropriate skills and insight to manage theirbusiness. One of the biggest dangers to the long-term success of providers is having a boardor senior staff with inappropriate skills trying tomanage risks they do not really understand… The underlying message is that good governanceis at the heart of a strong business and thoseorganisations most likely to mismanage theserisks are those with poor governance.”

Sector risk profile, June 2012

”Within this new world of socialhousing there is space for a range ofbusiness models from small, locallyfocused providers of social rent tolarge diversified businessesundertaking a full range of activitiesincluding considerable commercialactivity. The strategic issue forboards is to have a clear view of howtheir organisation is going tonavigate this new environment andhow they can continue to delivertheir organisational objectives.”

Sector risk profile, June 2012

“The provider’s ability to drive value formoney across its operations and assetbase will be taken into account by theregulator as a key indicator of the qualityof governance.”

Regulating the standards, May 2012

”It is providers’ responsibility to defineobjectives against which value for moneyis assessed. Unit costs do not equal valuefor money, but are an important part of it.”

Understanding unit costs of housingproviders – regression analysis, July 2012


the Governor SEPTEMBER 20126 the Governor SEPTEMBER 2012

It’s tough out there for housing providers. How does the regulator plan to ensure they’re

up to the job? The Governor spoke to the man incharge of regulation at the HCA to find out

Governance and regulation: what the HCA is saying

9the Governor SEPTEMBER 20128


“Traditionally value for money has been seen as shavingmoney off running costs and procurement costs, which isimportant,” he explains. “But there are wider questionssuch as ‘what about asset values?’”

For some organisations, he says, that might meanconsidering whether the social benefits of retaining ahome in a higher value area worth, say, £300,000 are worthmore than the opportunity to dispose of it to anotherlandlord better placed to manage it or to sell it and ‘buildtwo down the road’. It’s a suggestion which chimes withrecent calls from the Policy Exchange for stock in highervalue areas to be sold off to fund new development.

It’s your responsibility…

But Mr Bailes says he is not talking about disposal ‘writlarge’ – simply a willingness to look at the issue. “There areoptions with assets we are expecting people to explore,”he says. “There are bits of the sector which have thoughtabout this but for the majority of the sector it’s somethingthey have got to go a bit further with. There is not onestory on value for money – what we are looking for is theassurance that organisations have a clear set of objectivesand a strategy for meeting them.”

Value for money and the other economic standards areclearly the regulator’s prime focus. But Mr Bailes warnsthat providers cannot afford to be complacent over theirservices to residents just because the regulator will not bepro-actively monitoring the consumer standards: “The keymessage to boards is ‘this is your responsibility’. It alwayswas, but boards shouldn’t be loosening grip on theseissues one iota. They still need to meet the standards.”

The regulator will only step in on the consumer standardsside where it believes failings are likely to cause ‘seriousdetriment’ to tenants – an area where there is not yetenough ‘case law’ to show exactly how or where providerswill be most at risk of intervention. But areas like healthand safety and discrimination are those where theregulator might need to intervene – and Mr Bailes stressesproviders would be ‘extremely unwise to take their eye offthe ball’ in their core business.

Yet some across the housing sector have voiced fears thatthe lack of pro-active regulation on the consumer side willinevitably lead to falling standards. That has promptedcalls, most recently from the Lib Dems in their housingpolicy paper, for a return to inspections. The prospect ofyet more regulatory change doesn’t faze Mr Bailes.

“We are focused on the day job, which is economicregulation. We are not worrying about changes which mayor may not happen in the future,” he says. “The day job ismore than sufficient to keep us busy.”

The housing landscape is changing as for-profit providers enter themarket and social landlords diversify their businesses. Richard Moriartylooks at what lessons might be learned from other regulated sectorsAs the economic regulator, it is our role to be mindfulthat with new opportunities come new risks thatmight need managing. Although most profit-seekingregistered providers will be motivated to delivershareholder returns through a genuine commitmentto provide great service, new investment and freshideas, we need to be vigilant to instances of profitbeing driven by less creditable means.

Safeguards

Other regulators have developed a range of safeguardsto ensure profit is generated from genuine effort andskill rather than by unfairly exploiting customers orabusing unintended regulatory loopholes. In thesesectors, clarity on some regulatory boundaries isimportant: the letter of the rules can be just as importantas the spirit of the rules – something that has been lessof a feature in the regulation of not-for-profit socialhousing providers as we rely on simple outcome-basedregulation and avoid prescription where possible. Forexample, a casual glance at the rules in place forprofit-driven regulated companies such as NationalGrid, Thames Water, BT and Heathrow airport suggeststhe regulatory boundaries for these companies aremore defined than some of the rules applying to socialhousing providers. Typical features include caps onprices, minimum service standards and restrictions onthe activities that the business can undertake and risksit can assume. With unacceptable routes to profitblocked, the business has no choice but to earn itsreturns from genuine endeavour on delivering valuefor money, innovation and service.

Does this suggest we need to evolve our co-regulatoryphilosophy for profit-seeking providers? Notnecessarily – we shall be keen not to throw the baby

We all have an interest in successfully managing theintroduction of profit-seeking landlords in affordablehousing. It is a key priority for the HCA’s newregulation committee and you can expect a detailedconsultation from us on the issue later this year. Mightwe be able to draw any lessons from other regulatedsectors where it is the norm, not the exception, fordirectors to have legal duties to shareholders ratherthan more socially orientated objectives?

The provision of social housing has been well servedby its traditional and diverse model of public andprivate not-for-profit landlords such as localauthorities, charities, and industrial and providentsocieties. This broad group is likely to remain thedominant delivery model for the foreseeable future.But it does not have exclusive rights over the SocialHousing Register. Parliament lifted its restrictionagainst ‘for profits’ coming on to our register in 2008.

So far we have seen only a trickle of ‘for profit’registrations. But many expect this could build to asteady flow in the future as the twin politicalimperatives of deficit repair and returning theeconomy to growth continue to challenge our sectorfor new thinking and new approaches towardsdelivering more affordable housing.

Real opportunities

There are real opportunities from encouraging greater diversity and innovation in the provision ofnew affordable homes. In regulated sectors such asenergy, water and communications, shareholder-based providers have supported massive investmentin badly needed infrastructure. The current shortage of affordable homes has echoes of the past in theseregulated sectors where demand increased but a lackof public funds built up a cumulative infrastructuredeficit.

It is understandable that some people are anxious thatthe profit motive cannot be reconciled with the ethosof affordable housing. But these same fears accompaniedthe introduction of shareholder-based models in otherregulated sectors too. And in most cases these fearsproved misplaced as the public got used to theirtelephony, water, energy and transport beingprovided by companies driven by their bottom line.

out with the bathwater. But it may be prudent to ensurethat the regulatory rules that protect ‘public value’ in thesocial housing stock, such as rent monitoring and disposalconsents, cannot be abused in a way that would simply endup with the taxpayer funding dividends rather than thembeing generated through more productive endeavours.

Other regulated sectors may also offer insight into howto respond to providers seeking to diversify as part ofmore complex group structures that involve profit-seeking and related non-regulated businesses. Forexample, regulators of vital services such as water,energy, and air traffic control set rules to avoid theregulated business being exposed to unacceptable riskbridges with non-regulated activities within the samegroup structure. Financial ring-fence provisions aredesigned to put a firewall around the regulated businessand rule out practices such as pledging regulated assetsas security for non-regulated purposes. Regulators tendto ensure these businesses have sufficient independentgovernance and they are not unduly beholden to theinterests of the parent group’s non-regulated enterprises.

Our consultation later this year with stakeholders willenrich our view on the opportunities and risks. Byensuring that our regulatory response is risk-based,proportionate and transparent, we shall be able toembrace innovation and new funding models while atthe same time safeguarding the interests of taxpayers. In doing so, we can achieve our aim of successfullymanaging to profit in affordable housing.

Richard Moriarty is a non-executive director on theregulation committee of the Homes and CommunitiesAgency. He is director of economic regulation at theCivil Aviation Authority and the former director ofregulation at the TSA


a cHaNgiNg

LANDSCAPE


When the going gets tough, the tough get going.The woman at the top ofthe CIH explains why she thinksstrong and effective boards hold thekey to the housing sector’s success



Nine-year limit

According to Mr Bull, a key catalyst for change has been theintroduction of the nine-year limit for board membership setout in the federation’s code of governance, which givesorganisations the opportunity to review their boardmembership as their organisation takes on new challenges.Payment too is a factor. “It’s about identifying nine to 12people, each of whom is really adding value. Organisationsaren’t in a position to carry slack on the board.”

Paul Tennant says the need to ensure organisations ‘get everypenny of benefit’ from their board members might seemruthless – but it’s a necessary reality. “At one time organisationsmight have been stuck with their board members. Now weneed to actively manage what we’ve got.”

But with this increasing professionalisation, how do you ensurethat the values upon which housing providers are foundedaren’t squeezed out? Bill Barkworth says ensuring yourselection process is built around your values will safeguard yourorganisation’s ethos. And Paul Tennant says: “We are very keento retain our social purpose, and whoever joins has to buy intothat. We don’t want a plc-type board, purely and only driven byprofit. That’s where accountability is important and that’s whyvalues are so important as part of the interview process.”

For the future, some observers believe we will move to evenmore streamlined boards across the housing sector. “Longerterm I’m sure we will move to unitary boards with equalnumbers of officers and board members,” says Malcolm Levi.“It’s all becoming more professional. But I would hope that thevalues that we like to think are taken for granted with mosthousing organisations will continue.”

BOARDSof THE fuTuRE


Challenging times call for even betterboards. How are housing providers

developing their boards of the future?

satisfy the regulator without necessarily embedding adesire for change. The new world will require somethingelse – organisations need to embrace the idea that we arechanging because we believe we should not because theregulator is telling us to.”

Emotional intelligence

So what are housing providers now looking for inprospective board members? Bill Barkworth, lead associatefor HQN’s Urbica search and selection service, says breadthof experience, the ability to challenge constructively anda capacity to work well in a team are all important. So toois emotional intelligence. “You need to be sensitive toothers’ points of view and specialisms,” he says.

Housing providers are getting much better, he says,about thinking about the mix they need on a board – andtailoring their recruitment process to match. “It’schanging quite dramatically. Organisations are doingmore long-term planning, scoping out the skills theyneed and pulling together better role profiles and jobdescriptions.”

But there are still some, he says, who need to go further.“There are still examples of boards that need moreexperience and stronger leadership. There are somepacesetters who have gone a long way in the design of a professional selection process but it’s often the smallor medium-sized organisation which needs to invest inboard training and development and selection processes.That requires time and money and the issue is

persuading them that there’s that a long-termbenefit going in getting a better qualified board.”

Back in the old days, so the story goes, getting onto ahousing association board was more about who you knewthan what you knew. Someone would recommend anindividual they’d come across who might fit the bill, andwith a quick word in the right ear, the new recruit would bearound the board table before they knew it.

“It was John Baker, a former deputy chief executive of theHousing Corporation who called housing associationboards self-perpetuating oligarchies,” says Malcolm Levi, a current board member looking back over his long careerin housing. “It caused an awful fuss at the time but he wasright really. At many associations, the chair would just invitehis friends or business acquaintances onto the board. In practice it was not always terrible, but you got a veryone-sided type of board.”

Hotting up

Things have been changing for some time now, of course.But thanks to the increasing challenges and complexity ofthe housing world, the pace of that change is hotting up.There’s a huge premium on valuable skills and experience,with housing organisations increasingly seeking toprofessionalise the way they recruit, train and performancemanage their boards.

“Organisations are looking for people sitting at the toptable to drive the business forward and we are seeing themreally skill up, getting in new people and younger people,”says Stephen Bull, head of governance at the NationalHousing Federation. “Organisations are really lookingat what skills they need for the future, rather than maybe as it was in the old world where somebody was elected on and didn’t really

have an idea what they were being asked to do.”

Future-proofing is certainly the approach of Orbit HousingGroup, which has recently been recruiting board membersand a new chair, who is due to be named later this month.Orbit’s chief executive Paul Tennant says: “One of the thingswe have been using as a bit of a mantra is ‘the board of thefuture’. Organisations do need to be thinking about howthey will develop a board that will take them into the future.”

High-level skills and experience

Housing providers now often hunt for specific high-levelskills and experience – particularly in finance, given thegrowing complexity of funding deals. Life on a board ismuch more challenging than it used to be, says Mr Levi,formerly chief executive of Home Group and now a boardmember at Peabody Trust and Richmond HousingPartnership. “If you go back to when I started in housing,provided you didn’t cock it up, life for board members waspretty easy. Nowadays everything is more complex. We aregetting treasury reports usually by expert outsiders. I’m notsaying I struggle, as it’s an area I’m quite strong in, but youhave to really think it through. Being a board member isdeeply interesting and fascinating but, yes, it’s hard.”

Yet as important as the technical skills are, says Mr Tennant,the right attitude to change is also crucial.

“It’s very easy for organisations to get carried away by a skillset. Sometimes boards think they are a finished product,

but they need to be encouraged to develop asa team,” he says. “In the past, unless

you really wanted to drive change, you could

Baroness Jo Valentine joined Peabody Trust’sboard earlier this year. As chief executive ofbusiness membership organisation LondonFirst – of which Peabody is a member – she wasalready familiar with the work of social housingproviders. “I am very interested in how one doesregeneration for real as opposed to what mostpeople do, which is a great deal of talkingabout it,” she says.

She says she likes the role of Peabody boardmember for its combination of ‘harder’ issues –like development – and ‘softer’ ones, such as itswork combating social exclusion andpromoting employment. But was joining theboard of a housing association very differentfrom her previous experience, which includes

corporate finance? “It’s not wholly new. The waythe board works is very professional,” she says. “Idon’t know the evolution the board has gonethrough in the past but people seem to thinkabout things the way I do. Taking a business-like approach but having a broader perspectiveon the issues is one I’m quite used to. But whatI’m still on a learning curve on is housing policy.”

Baroness Valentine is keen ‘not to go native tooquickly’, but is busy listening, asking questionsand visiting Peabody’s estates. “It’s like goinginto any company – if people tell youeverything on the first day it tends to goin one ear and out the other. I’m beginning to understand the questions I should have asked and need to know answers to.”

Abigail Lock is another 2012 recruit. She saysher interview for her place on the board of anarm’s-length management organisation wasvery challenging and she’s also been struck byhow good the induction process has been.“There is a real commitment to offering trainingand support,” she says. “And there’s a real senseof supporting each other on the board. Otherboard members are really open to you askingquestions. They realise that you are in a learningstage and encourage that.”

Ms Lock has plenty of expertise to bring to thetable – she is head of external relations atcontractors Mears and has also been acouncillor. But she’s also keen to develop herskills in areas where she might not have somuch experience. “It’s still early days for me asboard member. They went through my variousinterests and expertise and they have said these

are the committees that are most applicable,but also, do you want to learn different skills inother areas?” she says. “There’s a real flexibilitythere. It’s been great as a new board memberto feel you can explore the different areas thatboard members can involve themselves in.”

Most important for Ms Lock is her keennessto make a difference. “I have expertise incommunications and in the equality agenda and in care and support, but for me it’s moreabout the fact that actually I’m passionateabout the sector. I have a really strong beliefthat I can make a contribution to d riving upstandards. It’s all about that commitment tobeing a critical friend, to ask questions and tochallenge. To me, it doesn’t matter what walk oflife you come from: if you’ve got passion andcommitment you can make a real contribution.”


the Governor SEPTEMBER 201212 13the Governor SEPTEMBER 2012

When Sir Adrian Montague was invited to look atencouraging more investment in the private rentedsector he found ‘real potential’ for growth.

“Conditions now are more favourable to this kind ofdevelopment than they have been in recent years,” hisreport, published at the end of August, said.

The government was quick to pick up on a couple ofhis key recommendations. As part of this month’shousing package, it announced it would be putting£200m into making housing sites available toinstitutional investors to provide rented homes. It willalso be establishing a taskforce which, according tocommunities secretary Eric Pickles, will ‘bring togetherdevelopers, management bodies and institutionalinvestors to broker deals and deliver more rented homes’.

Barriers

Will it be enough to overcome the barriers theMontague review talked about? After all, we’ve beenhere before. As Sir Adrian points out, ‘significantinterest’ for several years has not been translated intolarge-scale investment. A key problem, his report says,is that the market is still not offering what investorswant. Novelty too is an issue. Investors have apparentlybeen pulling out of deals because they haven’t wantedto be prime movers in a big expansion of the market.

That’s where the experience of those who are alreadyinvolved will no doubt be crucial. Not just on theprivate sector side – social housing providers aremoving in to get a slice of the market. Some, likeThames Valley HA, with its Fizzy Living subsidiaryhighlighted in the Montague report as an example ofgood practice, are already very involved. Others, keenfor new opportunities which can help cross-subsidisetheir core business, are likely to make their presencefelt over the coming months and years.

Game changer

Government support for the Montague recommendationshas been welcomed by those with a strong stake in themarket. Property company Grainger, which managesresidential assets of £3bn in the UK and Germany, saysbuilding quality homes for rent will be a ‘game-changer for the UK economy. According to the firm’s executiveproperty director Nick Jopling, who sat on Sir Adrian’sreview group, it is ‘imperative to provide enough homes,and the right type of homes’. As Grainger points out,renting is the fastest growing housing tenure in the UK.Some 3.6 million households now rent privately – up fromtwo million in the 1980s. That number is set to soar, withSavills suggesting a further 1.1 million homes will beneeded to meet demand by 2016.

Yet, given that demand is in large part fuelled by negatives– the difficulty of getting on the homeownership ladder,the shortage of social housing – how will we ensure thatthe continuing boom in the private rented sector delivershigh quality well-managed homes? The involvement of thebest, from the private and social sectors, will be important.But the poor landlords, and worse, the rogues, continue toblight the experience of many renters. The CIH supportslooking at how a voluntary standards regime couldimprove the quality of private rented homes, and theirmanagement and maintenance. But might we see evenmore? How far to go with landlord accreditation andregulation was a key issue in this year’s London mayoralelection – and the calls for more intervention are likely togrow as the sector continues to expand.

It remains to be seen how new housing minister Mark Priskwill approach the challenge of ensuring the quality as wellas the quantity in the new rented homes the governmentwants to see. Those keen for more regulation of the sectormay find encouragement in his attempt five years back tointroduce more regulation for lettings agents. He saidthen: “As a Conservative, I am instinctively cautious aboutarguing for more regulation. However, as a charteredsurveyor and a constituency Member of Parliament, I know that we need to put lettings on the same regulatoryfooting as sales.” More regulation was, he said, longoverdue then. A step too far now? Watch this space.

PRivATE PRoPERTyIt makes up a growing share of thehousing sector. And now thegovernment wants to boost the privaterented sector further. Will this be agame changer for the housing sector?

BOARDSof THE fuTuRE

Baroness Jo Valentine

Abigail Lock

JOINING THE BOARD: RECRUITS OF 2012

HQN’S MagaziNE foR BoaRdS, ExEcuTivES aNd lEadERS HQN’S MagaziNE foR BoaRdS, ExEcuTivES aNd lEadERS

self-financing only allowed councils to have anaverage debt of up to £17,000 per unit there is clearlymore capacity for sensible, affordable borrowingwithin the prudential borrowing framework. This isespecially true if that borrowing is for building newhomes that rent is payable on. Councils are able toborrow relatively cheaply and easily and crucially overa 30- or 40-year period from the Public Works LoansBoard. This mechanism already exists and requires nonew legislation or systems. Any borrowing undertakento build new council housing would be repaid throughthe rents collected on the new homes and wouldtherefore not be a call on taxpayers’ money. In thisrespect it is similar to any government-backed loan toa housing association or private developer.

There are a number of options that government couldconsider to allow councils to join housing associationsand private developers in helping to kick start theeconomy through house building. It could temporarilyraise the debt cap to recognise the need for an economicstimulus and the under-utilised capacity in the localauthority sector; raise the debt cap now and then linkit to RPI for the future to allow for continued prudentialand fairly low level building by councils; or acknowledgethat council housing as a trading activity isn’t a call on

taxpayers’ money and funds itselfthrough rental income and usethe GGGD to measure nationaldebt and let councils managetheir finances according to thewell-tested prudential code.

CIPFA estimates that, with SocialHousing Grant, councils couldbuild an extra 100,000 homes inthe next five years, if releasedfrom the restriction of the cap.Even without grant, they could build some50,000 new homes. Many local authorities andALMOs have shovel-ready schemes that could begot underway very quickly. This new developmentwould help use under-utilised land and helpregenerate communities. It would provide local jobsand get money flowing into the real economy onceagain. It would even help the private house builders as councils and ALMOs tendered contracts for thebuilding works. And most importantly of all, it wouldprovide the housing the country desperately needs.

Chloe Fletcher is policy manager at the NationalFederation of ALMOs

As the coalition government looks for ways toencourage house building to boost economic recovery,it appears to be focusing on the housing association andprivate sectors to solve the problem. Ideas such asgovernment-backed housing association bonds or loanguarantees to associations and private developers arebeing trailed. Yet the government seem to be ignoringthe very sector best placed to provide quick, easy andfinancially transparent new build schemes – councils.

Private house builders are having a hard time not justbecause of a lack of finance for their developments. Theyare also facing a lack of demand for their product asfirst-time buyers find it difficult to access mortgages.Some see institutional investment in private renting asthe solution; but as welcome as a stable, long-term highquality private rented market would be within Britain’shousing market, its development is still at an early stage.And it would only provide for a section of the housingmarket – leaving many still in need of good quality,affordable housing.

Social housing is vital

The social housing sector is still vital, possibly more thanever. But the government’s favoured delivery agents,housing associations, are also having a tough time. Withcuts to Homes and Communities Agency grant levels, areduction in loan finance from banks and buildingsocieties and many associations already heavily debt-laden, there just isn’t the capacity that there once wasacross the sector.

Before the credit crunch, associations enjoyed easilyobtainable 30-year loan agreements from banks andbuilding societies at attractive rates as well as grant ratesof up 50% of the total cost of building. These bankfacilities have all but ended and margins are muchhigher. At the same time the government has cut grantlevels and introduced a new higher rented ‘affordablehousing’ product. Some associations have also had to tieup assets to cover their financial deals and that meansthese assets are not available to cover borrowing fornew development.

These factors have sparked a renewed interest in bondfinance, essentially loans from other investors, on whichan agreed rate of interest is paid by the company issuingthe bonds for a set period until the original investmentis repaid. Investors still require a return on theirinvestment and if some housing associations are alreadytoo indebted these bonds may be of little help. Yet ashousing associations grapple with a riskier and morecomplex financial world to help fund new affordablehousing, councils, tied down with arbitrary and restrictivedebt caps by central government, are being denied anopportunity to utilise their public assets to help deliverthe new homes the country so desperately needs.

A real route to what society needs

Council housing – now a self-financing, self-containedbusiness with comparatively very little debt – could offera real route to delivering what the government andsociety as a whole needs. As the debt settlement for

WiTH cuTS To HcagRaNT lEvElS aNdMaNy aSSociaTioNSalREady HEavilydEBT-ladEN, THEREjuST iSN’T THEcaPaciTy THaTTHERE oNcE WaS acRoSS THE SEcToR


FuTuREWith the economy stuck in recession, a chronic lack of affordablehousing and politicians desperate to find a cheap and easy way to kick start growth again, it’s time to turn once more to good, old-fashioned council housing. Chloe Fletcher explains...


BuiLDiNgThE


There’s a big conversation goingon around social media – and

housing providers need to be part of it


fRoM THE PRESS mean? According to Mike Myatt, writing for Forbes, theattributes of a good leader are rarely defined – meaningmany at the top end up suffering an identity crisis. Hisresponse is a definition of leadership which says: “Leadershipis the professed desire and commitment to serve othersby subordinating personal interests to the needs ofthose being led through effectively demonstrating thecharacter, experience, humility, wisdom and discernmentnecessary to create the trust and influence to cause theright things to happen, for the right reasons, at the righttimes.” How many do you know who match up to that?

Nearly half of businesses plan to restructure their HRdepartments over the next year, according to a surveyreported by People Management magazine. Of thoseplanning an overhaul, four in ten said they were moving

to a shared services environment, while one quarterwere proposing to outsource.

And finally… if you’re looking for a way to get yourboard or senior team to work together even moreefficiently, how about board breaking? No, we’re nottalking here about another governance review, butinstead a way of splitting a wooden board using martialarts techniques. Apparently it’s become a bit of a crazeamong companies looking for a new team bondingexercise. Martial arts instructor Chris Allen, quoted in theHemel Gazette, said: “It’s about telling yourself that youare going to put your hand through the wood and bydoing that you reinforce your belief in yourself… It works well as an added extra after a managementmeeting.”

The banking crisis has advanced the cause of womenin the boardroom, because organisations now realisethey need ‘fewer Bob Diamonds’ and more peopleprepared to challenge macho culture. That was the viewof city fund manager Helena Morrissey, speaking at anEvening Standard-sponsored debate on women in theboardroom this month. Ms Morrissey said the crisis hadmade company leaders realise that having ‘differenttypes of people making decisions, challenging eachother and creating the right culture’ could help avoidsimilar problems in future, the newspaper reported. “Wehave travelled a huge way and the real driver is thefinancial crisis,” she said.

Meanwhile the Evening Standard also reported thatsmaller organisations have ‘finally woken up’ to theneed for more female bosses. The paper highlightedresearch from the Quoted Companies Alliance andaccountants BDO, which found that of small andmedium-sized companies that had recently hired directorsor senior managers, almost a quarter sought femalecandidates, 38% had had women on their shortlists andalmost 30% ended up appointing a woman. No causefor celebration yet, you might think. There's a long wayto go in the private sector – of the 1,039 companies onthe Stock Exchange’s Alternative Investments Market foryounger, growing businesses, 77% had all-male boards.

Job descriptions often list ‘leadership ability’ amongthe must-haves for senior posts – but what do they

Social media is changing the way government works.So says @sirbobkerslake – better known to the non-Twitter addicts simply as Sir Bob Kerslake, the head of thecivil service. The former Homes and Communities Agencychief says tools such as Twitter and Facebook arebecoming an ‘integral part’ of the work of the civil servant,allowing the government to be more in touch with itsstaff and the public than ever before.

Just as the civil service is embracing the social mediarevolution, so social landlords too are realising its potential. Asthe government points out, half of the UK population nowuses Facebook – so organisations can’t afford to ignore thepotential for engaging residents and stakeholders alike.

Yet some landlords have been wary of getting involved– often for fear of the complexities and risks – or havedone little more than establish a Facebook page andthen pretty much leave it at that. For both the novicesand the more seasoned users the government’s recentsocial media guide makes worthwhile reading. Althoughdesigned for the civil service, the guide has some goodpointers for social landlords looking to build their socialmedia presence. As it points out, using social media canreally help organisations to consult, engage and bemore transparent – but it takes work to get it right.

Interesting pointers in the guide include:

• “The use of social media is not simply a numbers game.The quality of interaction and audience demographicsshould influence your choice of social media channels”

• “Use social media to have discussions with your serviceusers or the people whose behaviour you want tochange. Ask them to elaborate on the issue, and if youknow something that could help, share it with them”

• “If you're receiving praise for work done within yourteam, make sure you pass it on. Social media is one ofthe few ways you can directly and instantly receivefeedback on your policies and decisions”

• “Decide whether you want to engage or not basedon if one, or both, of you will gain somethingfrom the exchange. You don’t have torespond to everything”

• “In social media the boundaries between professionaland personal can sometimes become more blurred –so it's important to be particularly careful”

All of this is good stuff – and the organisations who areblazing a trail report that a positive approach can payoff, with their feedback from and consultation withtenants often much increased through the use ofsocial media, particularly Facebook. But there are stillquestion marks about how seriously landlords canand should take social media as an engagement tool,until more residents have online access. It’s estimatedthat half of social housing tenants have never goneonline – a situation former housing minister GrantShapps last year called ‘digital apartheid’. The signsmore recently are more encouraging. Work andpensions secretary Iain Duncan Smith has pledged toexplore the idea of a broadband tariff for socialhousing tenants to encourage more to go online.This ‘crusade’, as he called it, is particularly aimed athelping benefit claimants to claim online – but itcould also have a significant impact in improvingcommunications between landlords and theirresidents. As the voices joining social media grow,surely all landlords will need to join in.

17the Governor SEPTEMBER 201216 the Governor SEPTEMBER 2012

govERNaNcE ROuND-uPHQN’S MagaziNE foR BoaRdS, ExEcuTivES aNd lEadERSHQN’S MagaziNE foR BoaRdS, ExEcuTivES aNd lEadERS

When Grant Shapps announced the end of housinginspections, he said he was cutting the nanny state’sapron strings. But could those strings be retied in thenot too distant future? The former housing minister mayhave seen inspections as a waste of money. But thereare others who still hold the view that inspections werevital in raising standards across the housing sector – andthat without them, services to tenants could slide.

The Lib Dems are the latest to join the fray. The party’shousing policy paper, due to go to its conference thismonth, recommends reintroducing inspections as part ofa more proactive approach to protecting tenants’ interests.

“While broadly accepting the standards with the presentregulatory framework, Liberal Democrats believe thatthe social housing regulator should have a morecomprehensive remit,” the paper says. The current approachto regulating on the consumer standards, it adds, meansthere is ‘no external check on the quality of housingservices delivered to tenants and little or no enforcementif the provider is not complying with the standards’.

“We believe that social housing tenants need and deservemore protection than this as their social landlords areeffectively monopoly providers,” it says.

The paper proposes proactive regulation of the consumerstandards and bringing local authorities fully within theregulatory framework as well as the reintroduction of aninspection programme. Interestingly the paper says the partywould also introduce a ‘value for money regime’ for allproviders, including councils, requiring them to report VfMperformance data on a ‘transparent, timely and consistent’basis. And all providers in receipt of public funding wouldneed to demonstrate that they are ‘fully accountable’ to theirtenants including having guaranteed involvement in decision-making. “We will also give tenants the right to trigger a vote onwhether to move to another housing provider when things gowrong. Tenants would choose their preferred manager, subjectto approval from the Housing Ombudsman,” the paper says.

So how likely are we to see the kind of proactive consumerregulation regime the Lib Dems talk of? Will inspectors be backat a landlord near you any time soon? It’s too early to say, ofcourse. Not only will it depend on who’s in power next timearound, but also on just how effective local resolution hasbeen at dealing with failings in performance. A few horrorstories, and we might just find that the ideas floated by thecoalition bedfellows of today’s red-tape-cutting ministers startto find favour at the top once more.

As The Governor reported in our last issue, stockrationalisation deals are becoming more popular ashousing providers strive for greater efficiencies – and fornew business in these challenging times. But organisationswhich are keen to take the plunge need to approacheach deal carefully to avoid landing themselves withfinancial or reputational problems. Now Sovereign hasproduced a useful guide to the process – based on the‘steep learning curve’ it has gone through in acquiringsome 2,700 homes in stock rationalisation deals since 2006.

There are some fascinating insights into the problemswhich can emerge. For Sovereign, issues it has discovered– in some cases only after a deal has been completed –include supposedly general needs stock which was in factsupported housing for people with learning difficulties, andrestrictive covenants preventing the sale of some properties.In another case, a poorly managed leasehold scheme ledto a leasehold valuation tribunal post-transfer which brought‘considerable charges for repairs and maintenance

obligations unfulfilled by the selling association’.

So what are the key tips to be distilled from Sovereign’s experience? As Sovereign chief executive Ann Santry stresses, with all stockrationalisation deals ‘the devil is in the detail’. Organisations should notrush deals through and should ensure they have effective duediligence and dedicated resourcing for each deal. Good communicationsand relationship building are also essential. And of course, deals needto be part of a well-thought-through organisational strategy ratherthan seen as a short-term opportunity to boost stock numbers.

http://www.sovereign.org.uk/media-centre/current-press-releases/stock-rationalisation/


THE HaNd THaT RockS

ThE CRADLE

The spectre of future merger plans being held up bycompetition rules has receded after the Office of FairTrading ruled that they would not investigate Harvestand Arena’s merger.

The two housing groups came together in April thisyear, creating a new organisation called Your HousingGroup with some 32,000 homes across the north west,Cumbria, Staffordshire and Yorkshire.

The Office of Fair Trading launched an investigation

earlier this summer into the move, and its inquiry wasbeing watched with interest because of potentialimplications for future merger plans. But the OFT has now said the merger does not fall under itsjurisdiction both on the size of turnover and on theshare of supply of the newly merged group. The shareof supply test is met when the merged parties supplyor acquire at least 25% of all goods of a particular typein the UK or in a substantial part of the UK.

As part of its inquiry, the OFT asked the neworganisation for figures on their market share in anumber of areas, including social housing stock andrepairs and maintenance work.

It’s a big ask for councils. How do they improveperformance and respond to the demands for moretransparent decision-making while trying to managehuge funding cuts? Key to responding to the challengeeffectively is good governance. So are existingarrangements up to the job?

A review of local authority governance by GrantThornton gives a few pointers. According to the review,based on information from a survey, desktop reviewsand a roundtable discussion, local government hasmore to do to ensure its procedures and systems aregood enough to improve performance and manage risk. Key areas for improvement include training,scrutiny and anti-fraud measures.

The review identified that:

• One-fifth of respondents did not feel their authorityhad robust enough systems to develop the capacityand capability of officers and members

• Around 80% of councils carry out annualgovernance reviews

• A third of respondents felt their council’s scrutinyfunction was not effectively responding to thechanging risks their authority faced

• Some 85% felt their authority had goodarrangements for engaging with local people andother stakeholders to ensure robust publicaccountability

• Nearly 30% of cabinet members – but just 12% ofleaders – are women.

Councils could significantly improve on theirreporting, the review suggests. There is a strongcase, it says, for all councils to publish a consolidatedannual report, with performance and financialinformation.

(E)mERgiNg

BALANCiNg acT


THE STockANSwERiSSuES

Thursday 4 October 2012 London Book now – www.hqnetwork.co.uk/forthcoming_events

Rockingham House, St Maurice’s Road, York YO31 7JA

Telephone 0845 4747 004 Fax 0845 4747 006Internet www.hqnetwork.co.uk Email [email protected]

HQN Limited Registered in England Reg No. 3087930

Terms and conditions

Terms and conditions apply. www.hqnetwork.co.uk/events_training

Guarantee

As with all our events, our guarantee is that if a delegate attends thisevent and for any reason does not find it worthwhile, we will refundtheir delegate fee in full. To take advantage of this guarantee, thedelegate fee must be paid in full prior to the date of the event.

“We will expect to see evidence that boards are upto the job of navigating their organisationsthrough some challenging times ahead.” Julian Ashby, chair of the HCA RegulationCommittee

Each and every day the papers are full of scandalsin governance. Banks are usually the culprits. Howwell are the boards of housing organisationsdoing? What can we learn from the best? What arethe pitfalls to avoid? What are the expectations ofthe regulator?

This is a must-attend event for all boardmembers and executives

HQN has put together an intensive programme toexamine the key elements of governance today.

• Julian Ashby will set out his views on theserious challenges we all face and how boardsshould go about meeting these – including thekey ingredients of effective co-regulation

• Liz Potter (chair of Orbit Group) will share herexperience of what works and what doesn’t inboards

• Anne Hayes, head of market development,

governance and resilience, The British

Standards Institute will explain their approach

to governance and the new BSI governance

standard

• Bill Barkworth, HQN lead associate Urbica

executive search and selection, and SusanKashyap, HQN lead associate Urbica leadership

assessment, will discuss how to select and

assess the right people for your board

• Our chief executive Alistair McIntosh will chair

the event and is on hand to make sure all your

questions get answered.

This event will be directly relevant to: chairs

and board members of housing associations

and ALMOs, housing related not-for-profit

organisations, charities and community land

trusts, chief executives, directors, senior

executives, governance managers and officers

that work with boards.

Registration 10.00amStart 10.30amFinish 4.30pm

Timings

KEEPCALM

AND

HQN

Fast, practical guidance on everything to do with housing. HQN provides high-quality advice, tailored support and training to councils, ALMOs, housing associations and otherhousing providers. Find out more aboutus and our network membership byvisiting www.hqnetwork.co.uk or call us on 0845 4747 004.

Who are we?

The standard delegate fee is £265 + VAT.

The fee includes refreshments, lunch anda detailed e-information pack. Pleaseinform us in advance of any specialdietary requirements.

www.hqnetwork.co.uk/forthcoming_events

Delegate fees

in association with

Documents

The Governor