Link Housing Association Factoring Consultation Response 31 March 2017

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1 Link Housing Association Factoring Consultation Response 31 March 2017 Link values all customer feedback. Consultation with factored owners resulted in changes to our Written Statement of Services being made on 31 March Individual Property Specific Schedules have been provided to factored owners detailing costs from 1 April About the Consultation Twelve factored owners responded to the consultation. Some found our Written Statement of Services clear and easy to understand. Others raised specific queries or made suggestions for improvement. Where contact details were supplied, Link will contact owners about any property specific matters raised during the consultation. A summary of the general (rather than property specific) consultation responses to each section of our Written Statement of Services is as follows: 1.0 Introduction Link received no specific suggested changes to this part of the Written Statement of Authority to Act Further information about this is available within title deeds, independent advice agencies such as Citizens Advice Scotland, solicitors, or from the independent website: Fee levels and Affordability The Scottish Housing Regulator expects that we act fairly to recover the cost of running the factoring service and our revised fees reflect this expectation. Link signposts any customers advising of financial hardship to appropriate advice providers. Meetings with Owners Link is happy to attend meetings on request at a time of mutual convenience. Timing of the Consultation Changes will be implemented from 1 April 2017 following the consultation. However Link values feedback at any time and will continue to respond to any feedback we receive in writing, by telephone or at meetings.

2 2.0 Authority to Act Link received no specific suggested changes to this part of the Written Statement of Health and Safety Issues As explained in Link s Written Statement of Services, emergency repairs can be carried out without advance notification. Replacement Information about how to end the Factoring Agreement is included in Section 8 of the Written Statement of 3.0 Service Provided Link received no specific suggested changes to this part of the Written Statement of Timescales, Repairs and Inspection Frequency on a Property Specific Basis Where contact details were supplied, Link will contact individuals directly with a response. Whether More General Maintenance will be Carried Out Repairs will be provided as the need is identified through surveys or reports from residents, in accordance with the title deeds, Written Statement of Services and Property Specific Schedule. Whether the Service Offered will be more Pro-active Link will ensure a pro-active inspection is carried out least annually, as explained in our Written Statement of 4.0 Financial and Charging Arrangements As a result of the consultation Link will add to Section 4.3 of the Written Statement of Services, as follows: No charge will be made for issuing invoices in the first instance. A copy of contractor invoices will be supplied on request, free of charge in the first instance. Any further requests for copy invoices will be charged for in accordance with the Property Specific Schedule. 1

3 Comments were also received in relation to: Clarity of Factoring Invoices Link has recently improved the clarity of invoices following feedback from owners on this issue. We are in the process of making further changes following additional feedback. Link welcomes any additional specific feedback at any time. Definition of Major Works Link s Written Statement of Services defines Major Works as any work exceeding the value of Link s delegated authority. This may include, for example, replacement of a roof or lift. Insurance Costs Where Owners have their Own Policy in Place Link will contact relevant owners directly on this issue. Percentage Fee Increase The Scottish Housing Regulator expects that we act fairly to recover the cost of running the factoring service and our revised fees reflect this expectation. In 2016 the Scottish Housing Regulator published a report about Factoring Services provided by Local Authorities and Registered Social Landlords in Scotland. They found that management fees ranged from to per annum and recommended that factors have a clear and transparent approach to setting and increasing management fees that demonstrates that costs are accurately identified, apportioned and recovered. We believe our fees and block insurance charges are lower than those of commercial factors because we want them to be affordable to you, whilst still being viable to deliver and unsubsidised by other parts of our business. As a business we have also reviewed our own operating requirements to make efficiencies. The revised costs from 1 April 2017 are described in your Property Specific Schedule. Property Specific Queries about Reinstatement Valuation, Percentage Share of Repairs and Float Link will respond individually where contact details were supplied. Reasonableness of Charges for Copy Invoices Link has calculated the cost of providing copy invoices in terms of staff time, printing and postage (where applicable) and has also compared this with the prices charged by other factors, which can be considerably higher. What Commercially Sensitive Information Means There is no legal definition of this term however in general it is any information that could prejudice a supplier s commercial interest. For example, detailed pricing information at a level of detail in excess of the total price. Whether Additional Services will be provided in Relation to the Fee Increase Link will carry out pro-active inspections at least annually. In order to continually improve, Link carries out annual customer satisfaction surveys and also uses staff training, development and performance reviews to ensure all staff contribute to 2

4 service improvements, particularly those related to customer feedback. Link is one of only six organisations in Scotland to hold both Investors in People Gold and Investors in Young People accreditation. Whether Property Specific Schedules have been Supplied Previously Link has introduced these for the first time in response to our most recent customer satisfaction survey which identified a need for increased transparency. 5.0 Payment Methods and Debt Recovery As a result of the consultation, Link will add to Section 5 of the Written Statement of Services as follows: Charges in Dispute - Charges will show on invoices for information only until disputes are responded to. Where a charge is in dispute and is being referred to the First-tier Tribunal for Scotland (Housing and Property Chamber), Link will not apply any interest or late payment charges in respect of the disputed items during the period that the committee is considering the case. Comments were also received in relation to: Implications of Non-Payment Section 5 of Link s Written Statement of Services explains the implications of nonpayment and associated charges. Implications of Postage Timescales for the Application of Late Payment Fees in Respect of Reminder Letters Link s Written Statement of Services clearly states that invoices are due for payment within 14 days of the date of the invoice, irrespective of postage timescales. Link offers a range of payment methods including Direct Debit to make it easy for customers to pay on time. The vast majority of factored owners manage to pay on time. 6.0 Contractors As a result of the consultation, Link will add to Section 4.1.3: of the Written Statement of Services as follows: Link will carry out post work quality inspections on a sample basis. Comments were also received in relation to: Acting in the Majority Interest In accordance with the title deeds and legal framework, Link may on occasion be entitled to implement majority decisions following consultation. 3

5 Link s future plans for using in-house or external contractors. A combination of both in-house and trusted external contractors will be used to ensure work is carried out as quickly and economically as possible. Local Contractors Link procures contractors in accordance with the Link Group Procurement Strategy, which includes community benefits as part of the tendering process in certain contracts (works over 2m and supplies and services over 50,000), even where the contractor is not local. 7.0 Communication Arrangements Link received no specific suggested changes to this part of our Written Statement of Customer Service Centre Link continually invests in the training and development of staff, using a comprehensive performance management system to manage individual and team performance. Link welcomes any specific feedback on our service quality to help us improve Invoice Timing Link issues invoices quarterly in arrears, prior to the end of the next quarter, unless otherwise specified within Property Specific Schedules. Direct Debits can be set up to enable payment on fixed regular dates. Invoices are not always issued on the same date each quarter because the volume of repairs and associated invoices that we administer and apportion on behalf of owners varies each quarter. 8.0 How To End The Factoring Arrangement Link received no specific suggested changes to this part of our Written Statement of Factoring Fees Relative to Council Tax As the Scottish Housing Regulator expects that we act to recover costs of running the service, it is necessary to charge owners the costs of providing the service in accordance with title deeds. Whether Senior Management within Link will take the Consultation Response into Consideration 4

6 Link values customer input and has used this consultation to improve the Written Statement of Services following consideration by both frontline staff and Senior Management. Link will only charge for services provided up to the date of termination and will not charge a penalty for early termination by homeowners. Conclusion - Using Feedback to Improve Link s consultation with factored owners has led to a number of improvements to our Written Statement of Services that will make our services more transparent. Link recognises that individual contact is needed with a number of the owners who responded to the consultation and will do so on an individual basis. Link values feedback about our services at any time. Contact details for providing feedback are contained within the Written Statement of Services and are also available on our website. Link Group Limited is a registered society under the Co-operative and Community Benefit Societies Act 2014, Registered Number: 1481 R(S), Registered Office: Link House, 2c New Mart Road, Edinburgh, EH14 1RL. It is a Charity registered in Scotland, Charity Number: SC and a Registered Social Landlord with the Scottish Housing Regulator, Registration Number: HAL 148. Link Group