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Successful places
with homes and jobs
A NATIONAL
AGENCY
WORKING
LOCALLY
Affordable Housing
Update2011-15 Affordable Homes
Programme
Investment Partner Event
Akin Durowoju
6th October 2014
1. Policy and delivery context
2. HCA purpose and vision
3. Delivering our priorities
4. Programme delivery
Contents
Continued limits on public funding but
long term certainty and commitment
Emphasis on housing supply across all
tenures and on economic growth
Localism, innovation and tailored
solutions
Risk, diversification and complexity
Bedding in of key policy changes
1.1 Complex delivery landscape
1.2 Continued support for housing
Housing positioned alongside infrastructure
as driver of economic growth
Continued political focus on housing
Reflects government confidence in the
sector and in the HCA
New programmes and extra funding:
– £3.3bn for affordable housing up to 2018
– Extra £6bn for Help to Buy to 2020
– £525m Builders Finance Fund
– LIF Large Sites extended to 2020
– Increased focus on public land
– Housing Zones, Locally Led Garden Cities,
Estate Regeneration, Custom Build…..
2.1 HCA purpose and vision
Throughout a period of change, the HCA’s
core purpose and vision remains ….
To help create successful places with
homes and jobs
Working with people and places to help
deliver homes, economic growth and jobs
Delivering programmes of investment and
market interventions, making significant
contribution to overall supply of homes
Making best use of public land and
developing economic assets
Undertaking effective and proportionate
regulation of social housing providers
A national Agency working locally
– Aligning investment and support with local
need and aspiration
– Working with partners to deliver
Retaining a core focus on housing supply
– Mix of grant and recoverable investment
2013/14 another successful year
– Hit all targets (again)
– Includes supporting c54,000 new homes
(c50% of all homes built in the year)
In 2014/15 we will continue to support Government priorities
– Support delivery of c70,000 new homes
– Prepare for new programmes and growing public land role
2.2 Continued focus on delivery
Investment in affordable and specialist housing
remains a core part of HCA’s business:
– 29,000 completions in 2014/15, contributing to
Government’s overall 170,000 SR target
– 2015-18 AHP to contribute to 165,000 new
affordable homes by 2018
– New programmes including Hostels, Platform for
Life, Affordable Rent to Buy, Care and Support
Specialised Housing
– Continued support for local authorities to bring
remaining stock up to Decent Homes Standard
3.1 HCA priorities:Delivering and maintaining affordable housing
On course to meet housing delivery targets for
2014-15
Delivery to end of Q2 was slow
Too much slippage affecting partner
performance
Impact of procurement arrangements on delivery
Forecast starts still in bulk
Too many completions in Q3 and Q4
Resource implications to process claims
Bring forward claims and process early
March 2015 is the deadline
3.2 HCA priorities:2011-15 AHP delivery
-
5,000
10,000
15,000
20,000
25,000
0
20,000
40,000
60,000
80,000
100,000
120,000
Apr-14 May-14 Jun-14 Jul-14 Aug-14 Sep-14 Oct-14 Nov-14 Dec-14 Jan-15 Feb-15 Mar-15
SOY Forecast Spend YTD Actuals Spend (as of 10/09)
Cummulative SOY Forecast Cummulative YTD Actuals
East & South East All affordable programmes (AHP, NAHP and AHGP)
Expenditure (£000)
4.1 Programme Delivery – Expenditure
• Includes AHP 11–15, NAHP and AHGP
• YTD Actuals as of 10/09/14
-
100
200
300
400
500
600
700
800
0
500
1,000
1,500
2,000
2,500
3,000
Apr-14 May-14 Jun-14 Jul-14 Aug-14 Sep-14 Oct-14 Nov-14 Dec-14 Jan-15 Feb-15 Mar-15
SOY Forecast Starts YTD Actuals Starts (as of 10/09)
Cummulative SOY Forecast Cummulative YTD Actuals
East & South East All affordable programmes (AHP, NAHP and AHGP)
Starts (Units)
4.2 Programme Delivery – Starts
• Includes AHP 11–15, NAHP and AHGP
• YTD Actuals as of 10/09/14
-
500
1,000
1,500
2,000
2,500
3,000
0
2,000
4,000
6,000
8,000
10,000
12,000
Apr-14 May-14 Jun-14 Jul-14 Aug-14 Sep-14 Oct-14 Nov-14 Dec-14 Jan-15 Feb-15 Mar-15
SOY Forecast Completions YTD Actuals Completions (as of 10/09)
Cummulative SOY Forecast Cummulative YTD Actuals
East & South East All affordable programmes (AHP, NAHP and AHGP)
Completions (Units)
4.3 Programme Delivery – Completions
• Includes AHP 11–15, NAHP and AHGP
• YTD Actuals as of 10/09/14
0
10,000
20,000
30,000
40,000
50,000
Q3 2012-13 Q3 2013-14 Q3 2014-15 Q4 2012-13 Q4 2013-14 Q4 2014-15
SOY Forecast Spend Actual Spend
East & South East All affordable programmes (AHP, NAHP and AHGP)
Expenditure (£000)
4.4 Quarterly Profile - Expenditure
• Includes AHP 11–15, NAHP and AHGP
• YTD Actuals as of 10/09/14
0
1,000
2,000
3,000
Q3 2012-13 Q3 2013-14 Q3 2014-15 Q4 2012-13 Q4 2013-14 Q4 2014-15
SOY Forecast Starts Actual Starts
East & South East All affordable programmes (AHP, NAHP and AHGP)
Starts (Units)
4.5 Quarterly Profile – Starts
• Includes AHP 11–15, NAHP and AHGP
• YTD Actuals as of 10/09/14
0
1,000
2,000
3,000
4,000
5,000
6,000
Q3 2012-13 Q3 2013-14 Q3 2014-15 Q4 2012-13 Q4 2013-14 Q4 2014-15
SOY Forecast Completions Actual Completions
East & South East All affordable programmes (AHP, NAHP and AHGP)
Completions (Units)
0
1,000
2,000
3,000
4,000
5,000
6,000
Q3 2012-13 Q3 2013-14 Q3 2014-15 Q4 2012-13 Q4 2013-14 Q4 2014-15
SOY Forecast Completions Actual Completions
East & South East All affordable programmes (AHP, NAHP and AHGP)
Completions (Units)
4.6 Quarterly Profile - Completions
• Includes AHP 11–15, NAHP and AHGP
• YTD Actuals as of 10/09/14
0
10,000
20,000
30,000
40,000
50,000
60,000
2014-15 2015-16 2016-17 2017-18
Grant Allocation
East & South East AHP 2015-18 Programme - Bids Accepted
Grant Allocation (£000)
4.7 AHP 15-18 Allocations - Expenditure
• Includes Firm and Indicative schemes
• Bids Accepted as of 1st July 2014
Delivery! Delivery!! Delivery!!!
4.8 Conclusion
Successful places
with homes and
jobs
Successful places
with homes and jobs
A NATIONAL
AGENCY
WORKING
LOCALLY
2015-18 Affordable Homes
Programme
Welcome and Introduction
Contents
Initial bid round outcome & recap
The Grant Agreement
Continuous Market Engagement
Systems Update
Affordable Housing Programme
2015 -18 £2.9bn investment for affordable
housing over period 2015-18
announced in Spending Round
funding outside London - £1.7bn
Allocations announced 22 July
£886m allocated
43,800 homes – c. 37,700
funded; 6,100 – nil grant
160 investment partnerships
Over 75% on firm schemes
Affordable Homes Programme
2015-18: shape
Affordable Rent (and shared
ownership)
Programme can include:
– Hostel accommodation
– Travellers’ pitches
– Former empty properties brought
back into use as affordable housing
Supported, elderly and rural
housing
AHP 2015-18: themes -
construction
Driving efficient procurement and
construction innovation
Innovation and OSM
– Cross tenure but with AHP a place
to demonstrate potential:
especially for speed of delivery (at
right price)
– Different scales
– Different products
– Consumer acceptance
Share knowledge/experience (eg
Accord)
Continuum of funding and other
opportunities
CME for guarantees programme –
(grant) funding now almost all allocated
Announcement of initial 2015 AHP
allocations and move to CME = bridge
between programme periods
Reported interest in CME – fits with
progressing schemes – timing of bids?
Suited to how providers and local areas
operate – working up schemes in line with
business plans and meeting local priorities
£200m Rent to Buy loan fund –
prospectus now published
Not forget focus on delivery of current
programmes (in year end mode)
Grant Agreement
2015-18
Grant agreement briefing
How we got here
– 2011-15 FDA partner feedback
– Development of 2015-18 Heads of Terms
2015-18 grant agreement
– Fundamentals
– Key principles & obligations
– Contract management
– Contract types
– Getting into contract
2011-15 FDA feedback
“Pluses”
– Took a “Programme Approach”
– Facility to agree change
– Firm Schemes
– Positive HCA approach to contract management
– 140+ signed in first 8 months of programme
“Minuses”
– Agreed Payment Rate
– Attributed & non-attributed grant
– Programme Offer - sometimes lengthy progression to a “tangible” Firm Scheme
– Programme approach sometimes too “woolly”
– Insufficient “gradation” of default measures from “minor” to “nuclear”
– Required additional Sign-off of Funding Conditions
2015-18 Heads of Terms
Published early 2014
Responded to providers’ concerns
– 11-15 Agreed Payment Rate
• 15-18 Firm scheme grant
– 11-15 Attributed & non-attributed grant
• 15-18 Firm scheme grant
– 11-15 Programme Offer - sometimes lengthy progression to a tangible
Firm Scheme
• 15-18 Indicative schemes have transition date
– 11-15 Insufficient “gradation” of default measures from “minor” to
“nuclear”
• 15-18 four categories
– Funding Conditions all within contract
– Balanced, standard form contract
2015-18 grant agreement
Fundamentals
– All 15-18 Affordable Homes Programme delivered through the grant
agreement; and
– Required to offer properties at an Affordable Rent (new supply and
conversions to Affordable Rent)
– Does not impact Provider wider asset management strategies
– Requires Investment Partner status to receive grant
– Offers simplicity over 11-15 FDA and greater clarity on delivery for
Provider and HCA
Four standard forms
– Registered Provider (former RSL)
– RP (former RSL)-led consortium
– New RP (from April 2010)
– Private (unregistered) house builder (grant at completion)
First contracts issued
– First signed and completed September
2015-18 grant agreement
Key principles
– Approved Bid
– Indicative Schemes
– Firm Schemes
– Changes to Firm Schemes (inc substitution & addition)
– Delivery Obligations
– Grant claim
– Review Monitoring & Reporting
– Approach to default, withholding and repayment of grant
Approved Bid
Input by Provider to IMS
– New Schemes
– Indicative schemes (if applicable)
– Three years (but can be added to)
– Costs, contributions, conversion capacity, timings and grant required
– Allocated Grant (max required for Approved Bid)
– Approved by HCA at bid stage
– Forms grant agreement Schedule 1
Approved Bid can be:
– Varied
– Amended
– Substituted
– All via IMS
Indicative Schemes
Can be in original Approved Bid or subsequently submitted by Provider
to IMS and approved by HCA
Each Indicative Scheme has:
– Transition Date by which it will become a Firm Scheme
– Transition Longstop Date applies of 31 May 2016 circa half-way into
programme period
Provider to use reasonable endeavours:
– To bring forward as a Firm Scheme by Transition Date
If delayed:
– Provider can propose alternatives up to 40 days before TD
All Indicative Schemes must be Firm Schemes by Transition Longstop
Firm Schemes
Each New Scheme input to IMS ready for HCA acceptance as Firm
Scheme not less than five days before Start on Site
Provider warrants:
– Is deliverable to timetable
– It has secure legal interest in site
– Has all consents in place
– All recorded in Firm scheme details
HCA can only pay grant on Firm Schemes
– Two tranches and HCA can vary proportions
– Firm Schemes cannot complete after 31st March 2018
Changes to Firm Schemes
Provider can propose changes at any time
– Always via IMS
Pre-start change
– HCA can accept or reject and may recalculate grant as required
– Provider has option not to proceed, revert to original or withdraw
Post-start change
– HCA can accept or reject and may recalculate grant as required
– Provider has option not to proceed, revert to original or withdraw
– If withdrawing scheme Provider repays first tranche grant
Firm Scheme substitution & addition
If a scheme becomes undeliverable Provider can propose via IMS a
Substitute Scheme
HCA will review proposal
– VFM
– Consistent with Approved Bid
– Provider’s performance on other Firm Schemes
– Can be delivered by 31 March 2018, or earlier
– Local Authority support
If accepted, it becomes a Firm Scheme
HCA will also consider Additional Schemes: CME
– Same basis as Substitutes
HCA cannot approve Substitute or Additional if no available funding
Delivery & operational obligations
For each Firm Scheme
– Procure works and deliver to timetable
– Market and dispose or let homes asap after practical completion
– Use reasonable endeavours to deliver commitments on: procurement
efficiencies, employment & skills & construction innovation statements
– Comply with Regulator’s Tenancy Standard
– Tell HCA: start on site achieved and any event or circumstance that
may have material adverse effect on scheme
For the Approved Bid
– Complete the Permitted Conversions
– Not convert/dispose of more homes beyond the number required to
create the Conversion Capacity
– Note: does not impact Provider wider asset management strategies
Grant claim procedure
Grant claim via IMS after achieving start on site
– Provider repeats Firm Scheme reps & warranties
– Start on site achieved
– Retains status as Registered Provider and Investment Partner
– No Withholding Event occurred e.g. a consent has been withdrawn or a
Prohibited Act
Grant claim via IMS after practical completion
– Similar approach to start on site claim
HCA shall pay First & Second Tranche grant within 15 days of receipt of
satisfactory application
HCA cannot pay before start on site or practical completion
HCA cannot pay if practical completion not reached by 31st March 2018
Note: unregistered e.g. house builders all grant at completion
Review Monitoring & Reporting
Requirement for timely IMS updates
Quarterly Contract Review Meetings
Key component of delivery management
Provider sends Officer’s Certificate to Agency (via IMS) within 5
days of Quarter end
Within 10 days of receipt HCA and Provider hold Review Meeting
Meeting is a look back and forward at delivery
May result in agreeing Scheme and or Approved Bid changes
– But changes can be agreed at any time
Approach to default
Key principle to allow Providers ample opportunity for remedy
Default and termination is “back-stop” for Providers that
consistently fail to deliver
15-18 clearer “grading” of default: means focus is on
proportionate actions for Provider and HCA to resolve matters
Opportunities for remedy exhausted before further sanctions
applied (last resort) for any default
Approach to default
Scheme default
– Usually capable of remedy and always scheme-specific
Specified Default
– Capable of remedy and applying to Approved Bid level obligations e.g.
reporting or other operational obligations
Bid default
– HCA determines (acting reasonably) proper progress not made
Fundamental Default
– Less likely they can be remedied e.g. Prohibited Act
Withholding of grant
11-15 contract seen as “blunt instrument”
15-18 approach to default applies i.e. clear “grading” of measures
– Grant withholding events GW1-3 operate at Approved Bid level
– GW1: usually capable of remedy e.g. problem with reporting or repayment
– GW2: more serious e.g. loss of Investment Partner status but still opportunity
to remedy
– GW3: serious e.g. prohibited act
– Scheme withholding events SW1-3 are scheme-specific
– SW1: failure to deliver scheme in accordance with scheme details
– SW2: e.g. material breach, consents withdrawn, in delivering scheme and
steps taken have not provided remedy
– SW3: failure to deliver scheme to timetable
Repayment of grant
Future grant recovery through “Recovery Determination”
– Triggered by “Relevant Events” e.g. disposal “outside sector”
Adjustments to grant
– Delivery not in accordance with scheme details means HCA can recalculate grant
– Provider has opportunity to consider and option to withdraw the scheme
– Results of post-completion compliance audit may result in repayment of balancing
amount
Repayment upon termination (extremely rare event)
– But can allow some schemes to continue – distinction between “Scheme
Termination” and “Total Termination” events
– “Grading” of Fundamental “A” Default - e.g. prohibited act means all grant repaid
– Fundamental “B” Default e.g. serious but allows grant to be left in completed
schemes
Consortia
Same approach as 11-15
Liabilities depend on role in consortium
Liabilities of Lead Partner dependent vary if
– A developer for members;
– A manager/co-ordinator
Consortium members have opportunity to remedy default by others
– But not contractually liable for failures of others
Add and release members via simple deed
First agreements issued October 2014
Standard conditions
Standard obligations in line with Govt. policy including:
– Open Book
– Transparency
– State Aid
– Data Protection
Getting into contract
Via Contract Manager
– Issue contract to Providers
– Agree Schedule 1 Approved Bid
– Issue documents for signing
Completed contract allows
– Firm scheme approvals
– Re-let conversions to Affordable Rent
2015-18 contracts this year for Providers with starts this year
– “Ex-RSL” “standalone”
– Ex-RSL consortia
– “New” RPs
– House builders
Questions
Continuous Market Engagement
2015-18
AHP CME Bidding
requirements
Opened for bids via CME from October 2014
Bidding online via IMS
15-18 AHP Prospectus and Design addendum continue
to apply
In additional to the priorities outlined in the Prospectus
we are keen to see schemes for:
– Advanced housing manufacture (OSM)
– Rural housing
Who can bid?
15-18 AHP CME is open to all Investment Partners and
those who intend to qualify, including
– Registered Providers
– Local authorities (HRA borrowing/free resources) and their
ALMOs
– House builders and private sector developers working with
RPs
– Community groups, Community Land Trusts, Co-ops,
Almshouses etc.
Partners can develop in their own right or as part of a
consortium
New providers are encouraged to join existing
development partner consortia
First time bidders
If you are a new partner you can apply for IMS access by
contacting the HCA IT Service desk at
[email protected] or telephone 01908-353604
First time bidders that are not already qualified will need
to become a qualified HCA Investment Partner before we
can pay grant
Note that there is no requirement to qualify in advance of
submitting a bid
Guidance for bidding, including for the submission of
supporting statements, and for qualifying as an
Investment Partner is available on our website
Partners with 15-18 allocations
CME offer lines can be added to existing 15-18 AHP
offers
Offer level information, including supporting statements
should also be updated
Updated information on conversions and disposals will
be collected quarterly as part of the quarterly contract
review
No requirement to submit a revised FFR
Regulation
Any provider who intends to be the landlord of completed
properties delivered through the AHP must be a
Registered Provider
Details on how to register are on our website
Note that there is no requirement to register in advance
of submitting a bid, but we will want to understand the
arrangements for carrying out the landlord function for
completed grant funded affordable housing at the time of
bidding
Unregistered providers are advised to start discussions
with the regulator about registration as early as possible
Accelerated starts on site
To ensure a smooth transition between programmes
providers who have 15-18 allocations for schemes that
can start in 14/15 are encouraged to do so and discuss
with OA the budget requirements
Once in contract for the 15-18 AHP, and budget
confirmed accelerated starts should be claimed through
a cut-down version of 11-15 IMS scheme processing
Guidance is available on the website
It may be a cut-down process on IMS, but all contractual
requirements for claiming a start on site milestone still
apply!
Housing Standards Review:
HCA Design and Quality standards
Prospectus for new affordable homes programme published January 2014
HSR Ministerial announcement 13 March
Prospectus addendum published 27 March
2007 Design and Quality standards and compliance regime remain in place for the 2011-15 AHP.
Land disposals, standards determined locally
2nd HSR technical consultation published Friday 12 September through a further WMS; closes on 7 November 2014
What does this mean for the HCA?
The HCA will no longer require specific design and sustainability standards as a condition of funding.
Standards will be applied through the Building Regulations (for energy, security and waste) with optional requirements being introduced in the Building Regulations for the first time (accessibility and water efficiency).
HCA will monitor partners’ performance on space, internal and external layouts through IMS data returns.
What does this mean for HCA Partners?
Responsibility for the application of optional standards in the Building Regulations will pass to Local Authorities with compliance passing to Building Control.
Responsibility for the Nationally Described Space Standard will pass to Local Authorities.
With effect from the time that the Deregulation Bill is passed (expected early 2015), Local Authorities will not be able to require higher energy requirements than the Building Regulations through the Code for Sustainable Homes (which will be wound down). From the time of the Statement of Policy new plan policies should not refer to the CSH.
Housing Standards Review
Next steps
HCA opened for CME – October 2014
Make contact with the local HCA team to discuss your
proposals for CME and accelerated starts
Register for IMS access (if required)
Read the prospectus and design addendum & Level 1
space standard
Make contact with the Social Housing Regulator’s
registration team (if appropriate)
Any questions to [email protected] or contact
your local HCA team
IMS Help is available through the IT Service desk at
[email protected] or 01908-353604
Questions
Investment Management System
Update
IMS Update
Accelerated Starts
Continuous Market Engagement
AHP 2015/18 - Profiles and Schemes
– Key changes
– Process flow
– Functions under each phase of delivery
2015-18 AHP - Accelerated Starts
IMS was updated in September
Interim solution to pay the Start on Site tranche for allocations in the 11/15
programme period
Process remains the same – Offer, Profile, Schemes
All accelerated starts submitted through this route must
– start before the end of December 2014
– forecast completion between April 2015 the end of March 2018.
Once the facility for processing schemes from 15/18 allocations is
developed we will need to move any interim payments to the new 15/18
schemes
Schemes under accelerated starts must NEVER be progressed to
completion as 11/15 Schemes
System Guidance available on line
Accelerated Starts
New Offer type called “AHP 2015-18 Accelerated Starts”
Accelerated Starts
New Offer line must be linked to the 15/18 Offer lines
Accelerated Starts
Simplified Capital Details
screen
Accelerated Starts
No HQI scores required
Continuous Market Engagement
IMS opened for CME in October 2014
All new Offer lines (under new and existing Offers) to be marked as
CME through “Offer Line Source” indicator
Same process as 15/18 bids
Same data entry, but with additional questions on demolitions
Supporting Statements are versioned so able to submit a version 2 (if
the offer is already accepted)
Any un-submitted AHP 15-18 Offer Lines converted to CME Offer Lines
System guidance will be made available
CME – Line Source
‘Offer Line Source’
description added to
filter and on Offer Lines
CME – Demolition Data
Offer Line
Products tab,
Firm schemes
Processing
routes
Acquisition
and Works
Package
Deal
Works Only
AHP 15/18 - Key changes
AHP will be delivered through a combination of both
– Profiles – current design (Centura)
– Schemes – new design (.Net)
Processing will follow the same basic method of data entry required
to meet each milestone.
However the biggest change is that scheme data maintained in one
place i.e. Profiles, and no longer in Schemes.
Benefits
– Data can be updated on an on-going basis
– If there are no variations it is a simple submission and approval
– Updates will be versioned, showing a clear progression of data
– Reduce confusion between different sections of the system
Overview process1. Scheme Profile Line
- Acquisition & Planning Milestones- Organisations
- Capital Contributions & Costs- Unit & Unit Mix
- Equalities and Quality - Business Rule Validations
Underpinned by versioningProvider Submission
2. Create Scheme
3. SOS Achievement and Payment
4. Update data in Profiles
5. PC Achievement and Payment
Funder Approval
Provider Submission Funder Approval
Provider Submission Funder Approval
Data maintained in Profiles anytime
Profiles
Schemes
Delivery Phases
Phase 2/3 will enable
– Start on Site Payments
– Pre-requisite data – including Scheme Profile lines, Planning,
Acquisition and Start on Site Milestones
Aim to be deliver December 2014
Phase 4 will enable
– Practical Completion Payments
– Pre-requisite data – including full scheme data, Completion
Milestone
– Post completion data
To be delivered in early 2015
Phase 2/3 - Profile changes
Profiles will be updated to include all data entered at bids stage
– For Firm Schemes this will generate a scheme profile
– Profiles for Indicative Offer Lines will allow scheduling out of firm
schemes including entry of all firm scheme detail
– New data fields on Modern Methods of Construction and
Equalities in firm schemes
‘Request to Change Approved Bid’ will replace Programme Change
Notifications and are identified as Material and Non-material
Acquisition and Planning Milestone achievement
Phase 2/3 - Scheme Changes
Create new scheme either directly from Scheme Profile Line or main
menu
Required data for create scheme:
– Modern Methods of Construction data must be present
– Equalities data must be present
– Acquisition and Planning Milestones must have been achieved
– Forecast Dates must not be lapsed
Data will no longer be copied across from Profiles
New Summary ‘Profile Information’ task
NOTE - Once a scheme is started the forecast dates cannot be
changed until Phase 4 is delivered
AHP Scheme Design
AHP Scheme Design
Phase 4 – Profile Changes
Profiles
Additional data capture required for Scheme completion
– Quality data (scheme level and at unit level)
– detailed Cost breakdown and Revenue Detail
Versioning to support changes to firm scheme data (revised
approvals)
Schemes
Practical Completion milestone achievement and approval
Practical Completion payment
Initial Sales
Update Scheme Forecasts
Questions
Keeping in touch
homesandcommunities.co.uk
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