Preliminary application form for registration

of new entrants as providers of

social housing

January 2018

Contents

About this form 4

Part 1: Declaration and consent 6

Part 2: General information 7

Part 3: Eligibility condition 9

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About this form

1. This form should be completed by applicants wishing to become providers of social housing registered under the Housing and Regeneration Act 2008 (the HRA 2008).

2. The form should be read in conjunction with the ‘Registration Requirements’ and the ‘Guidance for new entrants on registration as a provider of social housing’ (the registration guidance), both available on the website.

3. Before completing this application form, the applicant should familiarise itself with the detailed application process and with the requirements that will apply to it if it is registered. The applicant should not proceed with a preliminary application unless it is satisfied that it will be able meet all the requirements of registration.

4. This form should be completed in full. If the applicant has answered all the questions but thinks there is additional information that would aid the regulator’s assessment, then that information should also be provided.

5. There may be overlaps in the information sought in the individual questions and given this, the restructured body may cross refer to information already provided and does not have to provide the same information more than once.

6. The regulator expects the following to be enclosed when submitting this form:

a copy of the applicant’s governing document, for example rules, memorandum of association, articles of association, etc.

copy of any registration certificate or confirmation for the applicant issued by the applicant’s registrar/registration body, e.g. certificate of incorporation issued by Companies House.

7. The completed form will provide the information that will enable the regulator to establish whether the applicant is an English body as defined in section 79 of the HRA 2008 and whether it meets Condition 1 of the eligibility criteria for registration set out in section 112(2) of the HRA 2008: that it is a provider of social housing in England or that it intends to become a provider of social housing in England.

8. If the regulator confirms that the applicant is an English body that is, or intends to become, a provider of social housing in England, the applicant will be invited to submit a detailed application for registration. The applicant should then complete the detailed application form to provide the information that will enable the regulator to establish whether the applicant meets Condition 2 of the eligibility criteria set out in section 112(3) of the HRA 2008: that it satisfies the criteria set by the regulator as to its financial situation, its constitution, and other arrangements for its management.

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9. Applicants should note that, at its discretion, the regulator may not register an applicant with a name that is similar to the name of an existing or previous registered provider if it believes that the use of this name may cause confusion. It may also, at its discretion, not register an applicant with a name that it considers inappropriate or misleading.

10. Throughout this form, references to an applicant’s 'governing body' should, where an applicant does not have a board, be taken to include an equivalent management body as appropriate.

11. Definitions of terms used within this form are, unless otherwise indicated, taken from the Housing and Regeneration Act 2008 (HRA 2008) (as amended) or other cited legislation, all of which can be found on www.legislation.gov.uk.

12. The applicant should note that the Homes and Communities Agency (HCA) as a public authority is subject to the provisions of the Freedom of Information Act 2000 and the Environmental Information Regulations 2004. The regulator may also (section 109 of the HRA 2008) share information with a public authority if the regulator thinks the disclosure is necessary for a purpose connected with its functions or the functions or for a purpose connected with the authority’s functions.

13. This form asks for the consent of the applicant for the regulator to share relevant information with Homes England and Homes England to share relevant information about the applicant with the regulator. This sharing of information will only take place when it is appropriate to do so. The applicant’s consent may be withdrawn at any stage.

14. Any enquiries should be directed to the Regulatory Referrals and Enquiries Team on 0300 124 5225 or email enquiries@rsh.gov.uk.

15. The regulator’s preference is for electronic applications. The signed and completed form should be scanned and submitted to the Registry and Notification team: RNTeam@rsh.gov.uk. If it is not possible to submit electronically, the application should be posted to:

Referrals and Regulatory Enquiries Team

Homes and Communities Agency1st FloorThe Lateral8 City WalkLeeds LS11 9AT

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Part 1: Declaration and consent

Name of applicant: ………………………………………………………………………

On behalf of the above-named applicant, I apply for registration under section 116 of the HRA 2008 and:

I. confirm that the applicant has considered the eligibility condition set out in section 112(2) of the HRA 2008 and I believe that it meets the condition

II. confirm that the applicant has considered the rent-setting provisions in the Welfare Reform and Work Act 2016 (WRWA) and that the applicant complies with those provisions and, to the limited extent where it still applies, the Rent Standard

III. undertake to submit to the regulator any necessary documentation and information to demonstrate that the applicant meets the eligibility requirements for registration

IV. certify that to the best of my knowledge and belief, the information given in this form is correct and has been seen and approved by the governing body of the applicant and will ensure that any information subsequently provided to the regulator during the application process will be seen and approved by its governing body

V. confirm that I understand that any information regarding this application held by the regulator, including any information provided in this application form and supporting documents, or which is provided to the regulator during the application process, may be disclosed by the regulator where this is in keeping with its obligations as a public authority under the Freedom of Information Act 2000 and/or the Environmental Information Regulations 2004

VI. confirm that the applicant understands that information concerning the applicant provided for registration may be shared with Homes England

VII. agree to receiving electronic communications from the regulator.

Signed by …………………………………………………………………………………….

Name …………………………………………………………………………………….

Date …………………………………….………………………………………………

Position ……………………………………...……………………………………………..

This form should be signed by someone who has the authority, in accordance with the applicant's governing instrument, to sign on behalf of the applicant.

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Part 2: General information

Complete all sections of this part:

Contact details

Contact name:

Contact’s position/role:

Applicant’s website address:

Registered office address:

Telephone number:

Correspondence address of contact named above (if different to registered office):

Tel number:of contact named above (if difference to registered office):

Email address of contact named above:

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Information about the applicant

1. Is the applicant a parent of one or more organisations? If so, please provide details.

2. Is the applicant a subsidiary of another organisation? If so, please provide details of the applicant’s immediate parent and the ultimate controlling body of the applicant.

3. Please confirm who are the shareholders or members of the applicant

4. Please confirm who are the directors or board members of the applicant

Guidance:

For the information provided above, any official documents confirming this (such as Companies House or Financial Conduct Authority records) should be included with the application.

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Part 3: Eligibility condition

Eligibility

Before submitting a detailed application for registration, an applicant must first demonstrate to the regulator that it is an English body which is, or intends to become, a provider of social housing in England

English body

Section 112() of the HRA2008 requires that applicants are English bodies as defined in section 79 of the HRA 2008:

Section 79 of the HRA 2008

(1) In this Part "English body" means--

(a) a registered charity whose address for the purposes of registration by the Charity Commission is in England,

(b) [a registered society] whose registered office for the purposes of [the Co-operative and Community Benefit Societies Act 2014] (c 12) is in England,

(c) a registered company which has its registered office in England,

(d) a community land trust which owns land in England, and

(e) any other person (whether or not a body corporate registered under the law of the United Kingdom) which:

(i) is not a Welsh body within the meaning of section 1A of the Housing Act 1996 (c 52) [or a local authority in Wales], and

(ii) makes available, or intends to make available, accommodation in England.

5. Please indicate below how the applicant meets the definition of ‘English body’ set out in section 79 of the HRA 2008 (tick the relevant box).

A registered charity whose address for the purpose of registration by the Charity Commission is in England

A registered society whose registered office for the purposes of the Co-Operative and Community Benefit Societies Act 2014 is in England

A registered company which has its registered office in England (a registered company includes a community interest company)

A community land trust which owns land in England and meets the conditions specified in section 79 of the HRA 2008.

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Note that the wording in section 79 of the HRA 2008 relating to community land trusts (CLTs) states that the CLT must own land in England. CLTs that do not yet own land in England but are intending to do so should tick this box and the regulator will treat them as intending providers, subject to the applicant providing satisfactory evidence of intent.

Any other person (whether or not a body corporate registered under the law of the United Kingdom) which is not a Welsh body within the meaning of Section 1A of the Housing Act 1996 and makes, or intends to make, available accommodation in England.

Details should be provided below of the type of person, for example limited liability partnership, for the purposes of registration:

Details of type of ‘other person’:

Please tick to confirm a copy of the applicant’s governing document and evidence of registration with the relevant registrar is enclosed with this form

Provider

The HRA 2008 requires that applicants are providers or intending providers of social housing in England. The definition of a provider is in section 80 of the HRA 2008:

Section 80 HRA 2008

(1) In this Chapter, a reference to the provider of social housing is to be construed as follows.

Type of social housing Provider

Low cost rental accommodation The landlord

Low cost home ownership accommodation: shared ownership

The landlord

Low cost home ownership accommodation: equity percentage

"The seller" within the meaning of section 70(5)(a)

Low cost home ownership accommodation: shared ownership trust

The "social landlord" within the meaning of paragraph 7(3) of Schedule 9 to the Finance Act 2003

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The provider will be the landlord except:

for low cost home ownership accommodation made available under equity percentage arrangements, where it will be the seller i.e. the owner of a freehold or leasehold interest in residential property - as defined in section 70(5)(a) of the HRA 2008:

section 70(5)(a) of the HRA 2008

“the owner of a freehold or leasehold interest in residential property (“the seller”) conveys it to an individual (“the buyer”),”

and

for low cost home ownership accommodation made available under shared ownership trusts, it will be the social landlord as defined in paragraph 7(3) of Schedule 9 to the Finance Act 2003:

paragraph 7(3) of Schedule 9 to the Finance Act 2003

Para 7(3):

……("the social landlord") is a qualifying body . . ..

Para 7(7):

….."qualifying body" means:

(a) a qualifying body within the meaning of paragraph 5(2)(a) to (f), or

(b) a [private registered provider] of social housing within paragraph 5(2)(g) (subject to sub-paragraph (8)).

Para 5:

(2) A "qualifying body" means:

(a) a local housing authority within the meaning of the Housing Act 1985 (c 68);

(b) a housing association within the meaning of:

(i) the Housing Associations Act 1985 (c 69), or

(ii) Part 2 of the Housing (Northern Ireland) Order 1992 (SI 1992/1725 (NI 15));

(c) a housing action trust established under Part 3 of the Housing Act 1988 (c 50);

(d) the Northern Ireland Housing Executive;

[(e) the Homes and Communities Agency;]

[(ea) the Greater London Authority so far as exercising its housing or regeneration functions or its new towns and urban development functions;]

(f) a development corporation established by an order made, or having effect as if made, under the

New Towns Act 1981 (c 64)

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[(g) a [private registered provider] of social housing that is not within paragraph (b) (subject to sub-paragraph (2A))].

(2A) A [private registered provider] of social housing within sub-paragraph (2)(g) ("R") is only a qualifying body in relation to a lease of premises if the following has been funded with the assistance of a grant or other financial assistance [made or given] under section 19 of the Housing and Regeneration Act 2008 [or by the Greater London Authority]:

(a) the purchase or construction of the premises by R (or a person connected with R); or

(b) the adaptation of the premises by R (or a person connected with R) for use as a dwelling.

Para 7:

(8) A [private registered provider] of social housing within paragraph 5(2)(g) ("R") is only a qualifying body in relation to a shared ownership trust if the following has been or is being funded with the assistance of a grant or other financial assistance [made or given] under section 19 of the Housing and Regeneration Act 2008 [or by the Greater London Authority]:

(a) the purchase or construction of the trust property by R (or a person connected with R): or (b) the adaptation of the trust property by R (or a person connected with R) for use as a dwelling.

Guidance

The regulator interprets landlord for the purposes of section 80 of the HRA 2008 as meaning the person entitled to the immediate reversion of the lease and who issues the tenancy agreements to the social housing tenants. A superior landlord (such as the owner of the freehold who leases the property to the landlord) would not be considered to be a landlord for the purposes of the HRA 2008 and so would not be eligible for registration.

The regulator does not regard corporate entities where they act solely as the corporate trustee of an unincorporated charity as being landlords for the purposes of section 80 of the HRA 2008 and so they would not be eligible for registration.

If the applicant is already a landlord of social housing in England then evidence of the existing housing provision should be supplied. This could be, for example, copies of tenancy agreements.

Additional guidance for intending providers

If the applicant does not already provide social housing in England but is applying as an intending provider, the regulator needs to be satisfied of that intent before the applicant can progress to the detailed application stage. It expects to see that the applicant has a viable plan in place that appears to be deliverable.

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The applicant should provide evidence either of existing housing that is to become social housing or of financial provision for leasing, buying or developing new social housing. This may include:

details of existing land/property ownership, leasing or development, including copies of Land Registry title or head lease

details of planned land/property ownership, leasing or development

financial arrangements, for example application for financial assistance lodged with Homes England or the Greater London Authority (GLA), loans, general funding provision

details of contact with the local authority about the applicant's plans

any existing and planned contractual relationships

any other supporting evidence.

The regulator will expect the applicant to have a board in place that is actively involved in the registration process, in any decisions taken about, for example, finance arrangements and in engagement, where relevant, with the regulator.

The regulator would not usually expect to register an applicant if the business plan showed a period of longer than 12 months after registration before the applicant became a provider of social housing, although it recognises that in some cases development timescales may be longer. Applicants that are intending providers will be required to commit to key milestones and a date by which they expect to have become landlords of social housing.

The position of the intending provider will be kept under review after registration. In the event that the regulator is not satisfied that there is continued, evidenced, intent to provide social housing after registering a provider, the regulator is likely to propose compulsory de-registration under section 118 of the HRA 2008. This action would be taken on the basis that the provider is no longer eligible for registration. If circumstances change after de-registration, applicants can re-apply for registration at any stage.

If there are material changes in the business plan or scheme in this period, the regulator may need to review the provider’s continued compliance with the regulatory standards.

If the regulator is not satisfied that the evidence of an applicant's intent is sufficient to proceed to registration and the application is refused, or if a provider is de-registered because the regulator is not satisfied of its progress towards becoming a provider, a re-application may be made at any time if the applicant's circumstances change.

6. Please detail how the applicant is a provider as defined above. Please provide evidence of the applicant’s status as a landlord or seller or (for shared ownership trusts) social landlord

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7. If the applicant is not a provider as defined above, please provide evidence of its intention to become such a provider (the evidence should relate to an identified scheme or project to provide social housing within a specified timeframe after registration)

Social housing

The housing that the applicant provides must be social housing. By section 68 of the HRA 2008, social housing means:

low cost rental accommodation; and

low cost home ownership accommodation

Low-cost rental accommodation

By section 69 of the HRA 2008, low cost rental accommodation is accommodation:

which is made available for rent; and

the rent is below the market rate; and

which is made available in accordance with rules designed to ensure that it is available to people whose needs are not adequately served by the commercial housing market

The rents that may be charged by registered providers are subject to regulatory and legislative requirements. Registered providers must demonstrate that they operate in compliance with these requirements and the regulator will assess the applicant’s proposals in this respect at the detailed application stage.

Guidance:

The applicant will need to demonstrate to the regulator that the housing it provides or proposes to provide is or will be social housing.

Question 8

To assess whether the existing, or proposed, housing provision is social housing, the regulator will first consider whether the housing provided by the applicant has been, or is to be, funded by Homes England or the GLA as social housing. The regulator is likely to consider all such housing as social housing, although there may be exceptions.

In the absence of grant funding, the regulator does not consider the following to be social housing:

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accommodation let on the open market accommodation made available only to students in full-time education or training a care home (within the meaning of the Care Standards Act 2000) where nursing is

provided accommodation provided in response to a request by the Secretary of State under

section 100 of the Immigration and Asylum Act 1999 (support for asylum seekers); property of a kind specified in regulations made by the Secretary of State. (Note that

no such regulations have so far been made.)

The regulator has based this view on the exceptions set out in section 77 of HRA 2008.

Question 10

If the accommodation is not grant-funded and is not one of the exceptions listed above, the regulator will need to be satisfied that the accommodation is made available for rent. The regulator will expect to see evidence of how a potential social housing tenant would know that the applicant had properties available. This might be accepting tenant nominations from a local housing authority or through other routes. The types and lengths of tenure offered must meet the requirements of the Tenancy Standard.

Question 11

The regulator will need to be satisfied that rents charged, or to be charged, are below market rate in order to be satisfied that the applicant is a provider of this type of social housing. The regulator will expect to see evidence of:

(a) how the applicant has determined the market rate for rents in the areas where it operates, including evidence of the methodologies, comparators, and definitions used in the determination

(b) the rents charged, or to be charged, for this accommodation, expressed both in absolute terms and as a percentage of the relevant market rate

(c) the methodologies used in setting rent levels for new and existing tenants

(d) the relevant rents are not, and will not be, subject to contractual arrangements that will result in those rents ceasing to be below market rate

(e) all the valuations have been prepared by an appropriately qualified professional in accordance with a Royal Institution of Chartered Surveyors (RICS)-approved methodology and using RICS definitions

(f) the observance of key principles of transparency, accountability, probity, independence and professionalism in procuring valuations.

To enable the regulator to make an assessment of this evidence, the applicant should ensure that the information clearly separates out core rents from service charges or any other charged elements, such as support costs, so that a direct comparison can be made between the core rental element and the market rate valuation.

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Temporary accommodation used to discharge statutory homelessness duties is, like any other accommodation, not considered to be social housing unless it is provided at below-market rate and is made available in accordance with rules designed to ensure that it is made available to people whose needs are not adequately served by the commercial housing market. The regulator’s understanding is that such temporary accommodation will often be provided at market rate or above and, therefore, its presumption is that it will not be social housing. If the applicant makes such housing available at below-market rate rent levels, the regulator will need to be satisfied that this presumption is not the case.

If the applicant provides housing where no ‘rent’ is paid, for example, where the housing is occupied under a licence and the residents pay a weekly contribution to the maintenance of the property (as is usually the case for almshouses), section 275 of the HRA 2008 and section 33 of the Welfare Reform and Work Act 2016 provide that such payments are to be treated as rent, and the applicant should ensure that it has all the evidence referred to in question 11 as if that were the case. If the nature of the payment means that it cannot be compared with the prevailing market rate rent levels, then the applicant should provide evidence that this is the case.

Question 12

The regulator must be satisfied that the applicant makes the housing available in accordance with rules designed to make sure that it is available to people whose needs are not adequately served by the commercial housing market. This may be demonstrated by, for example, reference to reasons of affordability, the specialised/adapted nature of the housing, the security of tenure offered, the vulnerability of tenants or by referring to the objects in the applicant’s governing document.

The Tenancy Standard requires providers to put in place processes for allocation of their social housing, to address the housing needs and aspirations of tenants and potential tenants, and (regarding allocation processes) demonstrate how providers have made use of common allocation registers, common allocations policies and local lettings policies. Processes that meet this Standard are likely to include the rules on which accommodation would be allocated that explain the basis on which the applicant will allocate the social housing while meeting the requirements of the Tenancy Standard that homes are let “in a fair, transparent and efficient way”.

The regulator will expect to see a copy of ‘the rules’ on which the social housing will be made available, such as the applicant’s allocation policy.

Additional guidance for intending providers

The regulator expects intending providers to provide the information set out above or, where it is not yet available, information that enables the regulator to determine whether the eligibility requirements are met. Where the applicant has not yet drawn up an allocation policy, the regulator expects that the applicant will have considered how it will allocate its social housing and so the applicant can set out these principles.

Similarly, the regulator expects that an applicant will know the basis on which it will be charging rent, especially as this may be linked to conditions of grant funding, and so will be in a position to set this out even if it is not yet charging rent.

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8. Does the applicant provide, or intend to provide, low-cost rental accommodation as defined above? If yes, please provide details and evidence that the accommodation meets the definition above.If no, go to question 13.

9. Has the applicant applied for or received funding from Homes England or the GLA for the provision of low cost rental accommodation? If so, please provide details and evidence of this.

10. The applicant should outline how its accommodation is or, for intending providers, will be made available in line with the requirements in section 69 of the HRA 2008, as set out above

11. The applicant should provide details of all the low- cost rental accommodation it makes available or, for intending providers, intends to make available, at a rent which is below market rate. Such information should include:

(a) evidence as to how it has determined market rate rent levels in the areas where it operates or, in the case of intending providers, intends to operate, including evidence of the methodologies, comparators, and definitions used in the determination;

(b) details of the rents it charges or, in the case of intending providers, intends to charge for this accommodation, expressed both in absolute terms and as a percentage of the relevant market rate rent;

(c) evidence of the methodologies used, or for intending providers to be used, to set rent levels for new and existing tenants;

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(d) evidence that all the valuations upon which this application relies have been prepared by an appropriately qualified professional in accordance with a RICS-approved methodology and using RICS definitions;

(e) evidence that the applicant has observed key principles of transparency, accountability, probity, independence and professionalism in procuring such valuations;

In providing evidence about rent levels, applicants must always clearly distinguish core rents from service charges, and explain how each is being treated under the relevant legislative or regulatory regime.

12. The applicant should provide evidence as to how it is or, in the case of intending providers will be, making the accommodation ‘available in accordance with rules designed to ensure that it is made available to people whose needs are not adequately served by the commercial housing market’, as required by section 69 of the HRA 2008 (Please provide a copy of the rules or the principles on which any rules will be based).

Low-cost home ownership accommodation

By section 70 of the HRA 2008, low-cost home ownership accommodation is accommodation occupied, or made available for occupation, in accordance with:

shared ownership arrangements

equity percentage arrangements; or

shared ownership trusts.

The accommodation must be made available in accordance with rules designed to ensure that it is available to people whose needs are not adequately served by the commercial housing market.

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Guidance

The regulator will need to be satisfied about which types of low-cost home ownership accommodation the applicant provides, or is intending to provide, and that it satisfies the requirements set out in the HRA 2008 for the accommodation to qualify in order to assess that the applicant is providing, or intends to provide, social housing.

In each of these cases of low-cost home ownership, the applicant should follow the guidance for low-cost rental accommodation above, on the rules under which the accommodation is made available.

Shared ownership arrangements

By section 70(4) of the HRA 2008, shared ownership arrangements means arrangements under a lease which :

is granted on payment of a premium calculated by reference to a percentage of either the value of the accommodation or the cost of providing it; and

provides that the tenant (or the tenant’s personal representatives) will or may be entitled to a sum calculated by reference to the value of the accommodation

13. Does the applicant provide, or intend to provide, shared ownership accommodation as defined above? If no, go to question 16

If yes, please provide details and evidence that such accommodation meets the definition above.

14. Has the applicant applied for or received funding from Homes England or the GLA for the provision of shared ownership accommodation of which it will be the landlord?

If so, please provide details and evidence of this funding.

15. Please outline how the applicant’s shared ownership accommodation is made available in line with the requirements in section 70(4) the HRA

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2008.

Equity percentage arrangements

By section 70(5) of the HRA 2008, equity percentage arrangements means arrangements under which:

the owner of a freehold or leasehold interest in residential property (“the seller”) conveys it to an individual (“the buyer”)

the buyer, in consideration for the conveyance:

- pays the seller a sum (“the initial payment”) expressed to represent a percentage of the value of the interest at the time of the conveyance, and

- agrees to pay the seller other sums calculated by reference to a percentage of the value of the interest at the time when each sum is to be paid, and

the liability to make any payment required by the arrangements (apart from the initial payment) is secured by a mortgage

16. Does the applicant provide, or intend to provide, equity percentage accommodation as defined above?

If yes, please provide details and evidence that the accommodation meets the definition above.

If no, go to question 19.

17. Has the applicant applied for or received funding from Homes England or the GLA for the provision of equity percentage accommodation as set out in section 70(5) of the HRA 2008?

If so, please provide details and evidence of this funding.

18. Please outline how the applicant’s accommodation is made available in line with the requirements in section 70(5) of the HRA 2008 as set out above.

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Shared ownership trusts

By section 70(6) of the HRA 2008, shared ownership trust has the same meaning as in Schedule 9 to the Finance Act 2003 (c.14) (stamp duty land tax) (for definition see above)

19. Does the applicant provide, or intend to provide, shared ownership trust accommodation as defined above? If yes, please provide details and evidence that such accommodation meets the definition above.

20. Has the applicant applied for or received funding from Homes England or the GLA for the provision of social housing of which it is or will be the "social landlord" within the meaning of paragraph 7(3) of Schedule 9 to the Finance Act 2003?

If so, please provide details and evidence of this funding.

21. Please outline how the applicant’s accommodation is made available in line with the requirements in section 70(6) of the HRA 2008 as set out above.

Location

The social housing provided, or intended to be provided, by the applicant must be provided in England

22. Please provide evidence that the social housing provided or to be provided by the applicant is in England.

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© HCA copyright 2018

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Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned.

This publication is available at www.gov.uk/social-housing-regulation-england

Any enquiries regarding this publication should be sent to us via enquiries@rsh.gov.uk or call 0300 124 5225.

or write to:

Regulator of Social HousingFry BuildingMarsham StreetLondon SW1P 4DF

Regulation of social housing is the responsibility of the Regulation Committee, a statutory committee of the Homes and Communities Agency (HCA). The organisation refers to itself as the Regulator of Social Housing in undertaking the functions of the Regulation Committee.

References in any enactment or instrument to the Regulator of Social Housing are references to the HCA acting through the Regulation Committee. Homes England is the trading name of the HCA’s non-regulation functions.

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