Decision

St Mungo Community Housing Association (LH0279) - Regulatory Judgement: 30 April 2025

Updated 30 April 2025

Applies to England

Our Judgement

	Grade/Judgement	Change	Date of assessment
Consumer	C2 Our judgement is that there are some weaknesses in the landlord delivering the outcomes of the consumer standards and improvement is needed.	First grading	April 2025
Governance	G2 Our judgement is that the landlord meets our governance requirements but needs to improve some aspects of its governance arrangements to support continued compliance.	Assessed and unchanged	April 2025
Viability	V2 Our judgement is that the landlord meets our viability requirements. It has the financial capacity to deal with a reasonable range of adverse scenarios but needs to manage material risks to ensure continued compliance.	Assessed and unchanged	April 2025

Reason for publication

We are publishing a regulatory judgement for St Mungo Community Housing Association (St Mungo) following an inspection completed in April 2025.

This regulatory judgement confirms a consumer grading of C2, a governance grading of G2 and a financial viability grading of V2.

Prior to this regulatory judgement, the governance and financial viability grades for St Mungo were last updated in December 2023 following a stability check, to confirm grades of G2 and V2. This is the first time we have issued a consumer grade in relation to this landlord.

Summary of the decision

From the evidence gained during the inspection, our judgement is that there are some weaknesses in St Mungo’s delivery of the outcomes of the consumer standards and further improvement is needed, specifically in relation to outcomes in the Safety and Quality Standard and Transparency, Influence and Accountability Standard. Based on this assessment, we have concluded a C2 grade for St Mungo.

Our judgement is that St Mungo meets our governance requirements but needs to improve some aspects of its governance arrangements to support continued compliance. Specifically, St Mungo needs to strengthen the quality of its performance reporting, the effectiveness of its risk management and internal controls assurance framework, and to improve data quality.  

Our judgement is that St Mungo meets our financial viability requirements and has the financial capacity to deal with a reasonable range of adverse scenarios. However, St Mungo has a weak financial profile and needs to manage material risks to ensure continued compliance, particularly in relation to investment in its stock. Based on this assessment, we have concluded a V2 grade for St Mungo.

How we reached our judgement

We carried out an inspection of St Mungo to assess how well it is delivering the outcomes of the consumer standards and meeting our governance and financial viability requirements, as part of our planned regulatory inspection programme. Through the inspection, we considered all four of the consumer standards: Neighbourhood and Community Standard, Safety and Quality Standard, Tenancy Standard, and the Transparency, Influence and Accountability Standard.

During the inspection we observed a board meeting and a meeting of the Client Services Committee. We also observed a meeting of the Client Advisory Board, attended by tenants, former tenants, and clients from St Mungo’s wider services, and met with this group. We held meetings with St Mungo, including with its non-executive directors, and reviewed a wide range of documents provided by St Mungo.

Our regulatory judgement is based on all the relevant information we obtained during the inspection as well as analysis of information received from St Mungo through its regulatory returns and other regulatory engagement activity.

Summary of findings 

Consumer – C2 – April 2025 

During the inspection, St Mungo provided evidence-based assurance that it understands its responsibilities to ensure the health and safety of tenants in its homes and takes action to gain appropriate levels of assurance. However, St Mungo needs to strengthen its assurance on compliance in homes owned and managed by third parties, and we have seen evidence that it is taking action on this. We found evidence of weaknesses in performance reporting, which St Mungo is addressing, and we will monitor progress in this area through our ongoing engagement.

We found evidence of weaknesses in St Mungo’s understanding of the condition of its homes at an individual property level. At the time of the inspection, an exercise was underway to refresh St Mungo’s stock condition data and increase the proportion of physical stock condition surveys. St Mungo was able to evidence delivery of this survey programme in line with set timescales and that there are plans in place to keep this information up to date. Through our ongoing engagement, St Mungo will be expected to evidence continued progress in this area to provide assurance that it has an accurate up to date understanding of the condition of its homes.

We found weaknesses in the provision of an effective, efficient and timely repairs and maintenance service. St Mungo is taking steps to resolve this, including making changes to its contractor arrangements and improving its underlying data as well as improvements to systems and processes. There is some evidence that this is improving outcomes for tenants, however we will continue to seek assurance from St Mungo that progress continues at an appropriate pace and scale.

In relation to the Neighbourhood and Community Standard, we gained assurance that St Mungo works in partnership with relevant organisations to deter and tackle anti-social behaviour, including hate incidents, in the neighbourhoods where it provides homes. St Mungo uses its scheme management arrangements to focus on prevention and build positive relationships that support community cohesion. The impact of this is demonstrated through tenant satisfaction levels and a reduction in the volume of cases over the last year.

St Mungo provided evidence that, in relation to the Tenancy Standard, its approach to lettings and allocations is transparent, and that measures are in place to ensure terms of tenancy are appropriate and meet the needs of tenants. There are a range of initiatives in place to support tenants to settle into, sustain and move on from the accommodation that St Mungo provides, through person centred wellbeing plans. We also gained assurance that St Mungo treats its tenants with fairness and respect, and that it has a range of processes in place to support this. St Mungo uses information on the diverse needs of its tenants, including care and support needs, to deliver tailored services that deliver equitable outcomes for tenants.

Our inspection found a positive culture of engagement, with a range of opportunities for tenants and former tenants to get involved at a local service level as well as the wider organisation. We saw evidence that St Mungo offers a range of opportunities to hear from its tenants and that its engagement is well supported by its staff, with evidence of adjustments being made to enable tenants to participate. St Mungo captures a wealth of tenant feedback at a local scheme level, however there is no formal method of escalation to ensure this feeds into strategic decision making regarding services to tenants. St Mungo is considering alternative approaches, and we will monitor progress in this area through our ongoing engagement.

We have assurance that St Mungo is making improvements to ensure complaints are addressed fairly, effectively and promptly, and that it uses this information to drive service improvements and outcomes for tenants. Further progress is needed to understand reasons for the high volume of complaints, and to improve the quality and timeliness of responses to tenants.

Governance – G2 – April 2025

Based on the evidence gained from the inspection, there is assurance that St Mungo’s governance arrangements are meeting the requirements of the Governance and Financial Viability Standard. However, St Mungo needs to take action to improve some aspects of its governance arrangements.

St Mungo was downgraded to G2 in December 2021 following an In-Depth Assessment. Weaknesses were identified in its assets and liabilities information, its controls and assurance on Rent Standard compliance, and in the quality of strategic performance reporting.

Through the inspection and our previous engagement, we were able to see evidence of improvement in two of these areas. Performance reporting continues to be an area for improvement. While we gained assurance that St Mungo is taking action to improve data quality and strengthen its focus on landlord services, progress on this has been slow. St Mungo needs to improve the clarity and consistency of its performance information to enable the board to have effective oversight of its landlord obligations and provide effective challenge of performance against strategic targets and key areas of risk. St Mungo is updating and expanding its performance monitoring and reporting framework and we will monitor progress to gain assurance this delivers the required improvement. 

St Mungo needs to improve aspects of its risk and control framework to ensure it is appropriate and robust. We found evidence that St Mungo is effective at identifying risk and that the risk management framework is aligned to strategic risks. However, improvement is required to the assurance framework and quality of reporting to strengthen strategic oversight of risk. St Mungo is taking action to improve its risk and control framework, and we will seek assurance that it is, at an appropriate pace, delivering sufficient improvement in how its arrangements operate in practice.

St Mungo also needs to strengthen its stress testing, in particular, regarding testing variables to the point at which they could lead to failure of the business, and improvements in planning and modelling mitigation strategies.  

During the inspection, St Mungo demonstrated that it reviews its corporate structure according to changes in its strategy, including how it contributes to the delivery of its purpose and objectives. St Mungo was able to provide evidence that it has established clear roles, responsibilities and accountabilities within its leadership and governance structure. It has recently reviewed its committee structure and scheme of delegations and is strengthening the way in which information is shared between board and committees. There is a structured approach to developing and appraising the skills, experience and knowledge of board members to support succession planning.

The most recent external governance effectiveness review was carried out in 2022. This will need to be refreshed in due course so that the board is able to gain assurance on the effectiveness of its governance, and the impact of changes made to performance reporting and risk management. It is important that St Mungo’s governance continues to develop and that it functions effectively to deliver all remaining improvements.

Viability – V2 – April 2025

Based on the evidence gained through the inspection we have concluded that there is appropriate assurance that St Mungo’s financial plans are consistent with, and support, its financial strategy. St Mungo has appropriately evidenced that it has an adequately funded business plan based on reasonable assumptions. St Mungo has no funder covenants and has access to a sufficient level of cash reserves.

St Mungo has increased investment in its existing homes and will need to manage risks associated with them including any additional expenditure arising from its survey programme, ongoing fire safety requirements, and future costs for energy efficiency of its homes. This has the potential to put greater pressure on its financial position. St Mungo’s business plan includes efficiency savings through its transformation programme, which if not achieved could also impact on its financial stability. The business plan and nature of St Mungo’s work is inherently low margin which reduces its ability to absorb adverse shocks. St Mungo has the capacity to respond to a reasonable range of adverse scenarios, but it will need to manage these material risks.

Background to the judgement

About the landlord

St Mungo is a housing association and homelessness charity based in London. It operates in 21 local authority areas across London, the south east, and the south west of England, and runs more than 160 services. St Mungo manages 2,336 social homes and a range of other properties, of which it owns 1,605 units (on a freehold or leasehold basis). Most of its homes are supported housing. In 2023/24 St Mungo supported around 24,000 people and provided housing and support to around 2,300 people on any given night.

St Mungo generated a turnover of £123.7m in the year ended 31 March 2024 and employed 1,535 full-time equivalent staff.

Our role and regulatory approach

We regulate for a viable, efficient, and well governed social housing sector able to deliver quality homes and services for current and future tenants.

We regulate at the landlord level to drive improvement in how landlords operate. By landlord we mean a registered provider of social housing. These can either be local authorities, or private registered providers (other organisations registered with us such as non-profit housing associations, co-operatives, or profit-making organisations).

We set standards which state outcomes that landlords must deliver. The outcomes of our standards include both the required outcomes and specific expectations we set. Where we find there are significant failures in landlords which we consider to be material to the landlord’s delivery of those outcomes, we hold them to account. Ultimately this provides protection for tenants’ homes and services and achieves better outcomes for current and future tenants. It also contributes to a sustainable sector which can attract strong investment.

We have a different role for regulating local authorities than for other landlords. This is because we have a narrower role for local authorities and the Governance and Financial Viability Standard, and Value for Money Standard do not apply. Further detail on which standards apply to different landlords can be found on our standards page.

We assess the performance of landlords through inspections and by reviewing data that landlords are required to submit to us. In Depth Assessments (IDAs) were one of our previous assessment processes, which are now replaced by our new inspections programme from 1 April 2024. We also respond where there is an issue or a potential issue that may be material to a landlord’s delivery of the outcomes of our standards. We publish regulatory judgements that describe our view of landlords’ performance with our standards. We also publish grades for landlords with more than 1,000 social housing homes.

The Housing Ombudsman deals with individual complaints. When individual complaints are referred to us, we investigate if we consider that the issue may be material to a landlord’s delivery of the outcomes of our standards.

For more information about our approach to regulation, please see Regulating the standards.

Further information

• Regulating the standards

• Regulatory standards for landlords