Comments Sought on NRAS Amendments and New Government Report into Social Impact Investment

Your Chance to Have Your Say on Amendments to the National Rental Affordability Scheme (2 December 2016)


The Department of Social Services is seeking submissions on improvements to the administration of the National Rental Affordability Scheme and its regulatory framework. Submissions are due by 21 December 2016.

In particular the Department seeks comment on the following list of suggested topics:

general reforms to the NRAS process: simplifying the administration of NRAS and clarifying definitions in the NRAS Regulations;

strengthening documentary requirements: regulating the requirement for approved participants to lodge supporting information with Statements of Compliance;

introducing discretion to correct errors: flexibility to allow for incentives to be issued where it is in the interest of the Scheme;

improved transparency for investors: considering possible avenues to keep private investors informed;

major non-compliance: expanding the circumstances in which a revocation of allocation can occur; and

substitution of dwellings: inserting substitution rules in the NRAS Regulations to provide a clearer understanding of how to effectively substitute NRAS dwellings.

The Department indicates that information gained from this four-week consultation process will help to inform amendments to the National Rental Affordability Scheme Regulations 2008.

Please contact Mark Fowler if you would like assistance with the drafting of submissions.

Department of Social Services Report on Social Impact Investing Publically Released 

The recently released Department’s report for the Prime Minister’s Community Business Partnership provides a comprehensive summary of the evidence available on various forms of social impact investment and is designed to be a useful reference for government, philanthropy and charitable sectors. The report is available here.

Overall, the report finds that, whilst more mature evidence is required in the rapidly developing field of social impact investing, existing funds show positive short term results. These are particularly evident in relation to areas where there is significant unmet need such as affordable housing, home and community care and early childhood education.

Social and Affordable Housing

In regard to Social and Affordable Housing, the report notes that social impact investment could be effectively harnessed in Australia to increase the supply of affordable and social housing, provided certain structural barriers are addressed. It notes the following potential approaches:

-Increased availability of capital (via intermediary funds) for community-led housing developments, as well as for capability building to enable smaller organisations to access capital, define and measure short and longer term outcomes.

-Facilitate greater direct institutional investment in affordable housing projects via legal and regulatory change; for example, by enabling a market for housing bonds which medium to large social enterprises can issue to access finance.

-Social impact investment has the potential to promote innovation across agency boundaries, for example addressing complex needs across housing, employment and education, rather than a single intervention in isolation.

This is a timely report, as the State and Federal treasurers are meeting today to discuss ways to provide community housing through the use of bond markets. See the article by Phillip Coorey in the Australian Financial Review, Friday 2 December here. For those without access, a copy of the article can be requested from Bree Davidson of our office (