1. INTRODUCTION

1.1 Following on from the success of the Starter Home Initiative and Key Worker Living programme, the Government has announced a further two years of funding for the Key Worker Living Programme starting from April 2006.
 
1.2  The Key Worker Living programme is designed to assist access to affordable housing for either rent or purchase by frontline key workers, particularly in the health, education and community safety sectors whose services are essential to local communities and who need to live within a reasonable ‘travelling to work’ distance of those communities. The initiative is targeted at those areas where there are clear recruitment and or retention difficulties, linked to the cost of housing. The schemes included in this programme are:

• Open Market HomeBuy
• New Build HomeBuy (Sale)
• Intermediate Rent

The principles of these three schemes as they apply to Key Workers can be found in the relevant chapters within this Guide except in relation to Intermediate Rent which is contained below.

1.3. The specific requirements in respect of the schemes funded as part of the Key  Worker Living programme (referred to as KWL) are identified below.

1.4 These procedures apply where registered social landlords (RSLs) are operating the scheme and claiming grant from the Housing Corporation. It is a condition of Social Housing Grant (SHG) payment under s18 (3) of the Housing Act 1996 that the RSL operating the scheme complies with these procedures. The Housing Corporation has no discretion to pay SHG in cases, which do not comply. The acceptance of an allocation under KWL is an undertaking to comply with these procedures.

1.5 All RSLs' applications for and claims for payment of SHG must be submitted via the Internet using the Corporation’s Investment Management System (IMS).  See www.housingcorp-online.org

1.6 The scheme submission must comply with the Funding Conditions as accepted by the RSLs Committee and confirmed on line by the RSLs security Administrator. Plus any further conditions issued by the Housing Corporation in year.  The RSL will not be able to make a submission of any kind into  IMS until this confirmation has been made. RSLs must retain a minute of the  Committee decision on file for Compliance Audit purposes. See GENERAL-1.

1.7 This section of the Guide sets out the conditions under which RSLs are required to administer the Key Worker Living schemes and is the basis on which the Housing Corporation will assess applications for SHG.

1.8 The HomeBuy Agents will deliver much of the programme working with and through RSLs and other developers in the locality -please refer to SALE-1 and OMHB-1 chapters for further information.

2 FUNDING CONDITIONS

2.1.  The Funding Conditions signed by RSLs' Chief Executive and Chair at the start of each financial year (see General- 1) will cover allocations made under KWL together, with the following additions.

2.2  The following general funding conditions apply to all KWL schemes but additional conditions may be imposed on individual schemes or groups of schemes:

• KWL grant is provided to facilitate the provision of homes for rent at sub-market levels or assist the purchase of an eligible property by an eligible applicant and cannot be used for any other purpose;
• A KWL allocation is separate from and additional to the home ownership programmes funded through the mainstream NAHP . RSLs may not combine NAHP allocations with funds from the KWL in the same scheme to provide a higher level of subsidy per unit. Units provided through mainstream NAHP may be provided on the same site as long as they are funded separately;
• Assistance through KWL cannot be combined with any other publicly funded home ownership schemes such as the Right to Buy;
• Where applications are received for a joint purchase of a property, at least one applicant must be a qualifying key worker. Two or more key workers may not combine separate applications for assistance through KWL where they are intending to purchase jointly. In these cases a single, joint application should be submitted and the joint household income taken into account in determining the appropriate level of assistance;
• RSLs cannot recycle SHG from the RCGF for use in KWL, either independently or in combination with KWL grant (Further clarification awaited).
• KWL grant cannot be used to assist eligible applicants to purchase stock already owned by an RSL. The only exception to this is where the stock has been provided without public subsidy or through stock transfer and has never been used as social housing. RSLs may develop for sale through the KWL new housing using their own resources on sites they already own;
• Where development or rehabilitation is involved, RSLs must ensure that all necessary planning consents are obtained, building control requirements are observed and that adequate insurance is in place during development and after purchase if the RSL retains an interest in the property;
• All surpluses and grant recoveries arising from KWL schemes must be ring fenced and used to provide additional homes for key workers to buy or rent (see sections on clawback and grant recycling). Further guidance will be issued on the calculation and use of surpluses;
• Schemes must be within the objects of the RSL. Where this is in doubt RSLs should take their own legal advice;
• No member, employee, agent or consultant of the RSL, or any partner organisation (unless the allocation is for a specific development) should have any interest in the proposed vendor, contractor, land or property to be acquired under KWL, including individual street properties. This includes any firm, partnership or organisation in which they or their families are involved. The Housing Corporation’s regulatory guidance GPN3 – Maintaining Standards of Probity identifies circumstances and procedures to be observed where relatives of officers or staff who are eligible can be offered properties to rent or purchase.

2.3  Where RSLs are working with a partner to administer KWL, whether another RSL or other body such as a developer, they must have a formal  written agreement setting out the responsibilities of each partner.

3 SCHEME PROCESSING

3.1  KWL schemes will be processed via the internet using the Corporation’s Investment Management Systems (IMS) which also contains IMS guidance.

Allocations

3.2  RSLs will be notified in writing of accepted bids and any related conditions. Where RSLs' Chief Executive and Chair have not already signed, for the current financial year, Funding Conditions for the Investment region to which the allocation applies they will be required to do so. Grant cannot be claimed unless the local office of the Corporation has a signed set of funding conditions in place. The funding conditions must set out:

• Grant allocation and key worker categories eligible for assistance in each financial year; and
• Financial information:
   - Total IMR requirement by financial year and in total;
   - Total administration cost by financial year and in total;
   - Total SHG payable;
   - Additional contribution from RSL (if any);
   - Additional contribution from employer/other (if any).
   

3.3  Once the allocation is accepted RSLs will enter the relevant information into IMS. RSLs will be notified via the Corporation’s website at www.housingcorp.gov.uk when their allocations can be viewed in IMS and grant claims submitted. All allocations agreed under the KWL programme must be used to house a qualifying key worker as defined in Annex B. 
 
Delivery Plans
 
3.4 Investment regions will require RSLs with significant KWL scheme allocations  to draw up and agree delivery plans specifying the funding to be spent in each zone on each key worker group.
 
Variations
 
3.5  Allocations, delivery plans and other key assumptions can only be varied in agreement with the Corporation and where there is a significant agreed change, an amendment will be made. RSLs have no discretion to vary the tenure of schemes for which the allocation has been given without reference to the Corporation, nor can total grant be increased because of higher than expected costs. Partnering RSLs will be expected to report on progress to their lead investment regions at the regular quarterly review meetings. 
 
3.6 Where RSLs fail to deliver within the agreed cost limits, to the agreed timetable or there is insufficient demand from priority key workers, the Corporation may transfer the allocation to another RSL. The Corporation reserves the right to amend or transfer an allocation at any point before the final grant claim has been paid.
 
Grant Payments
 
3.7 The total amount of grant payable to the HomeBuy Agent for Open Market HomeBuy will be the grant to the key worker plus the agreed admin. fee. The Corporation must agree changes in the allocation of funding between financial years. Grant will not be paid until a key worker completes the purchase of a property acquired through Open Market HomeBuy. 
  
3.7.1 On New Build HomeBuy and Intermediate Rent schemes grant payment is in four tranches, acquisition, start on site, final and the last 10% on occupancy if via Traditional/specialist route; and three tranches, at start on site, final and the last 10% on occupancy if via the partnering route.   
 
3.8 SHG must not be claimed by the RSL in advance of need. The total grant claimed cannot exceed the allocation.
 
3.9  At the point of claiming SHG RSLs must confirm that the submission is accurate and complies with the Funding Conditions, as signed by their by the Chief Executive and Chair at the beginning of the financial year, subject to the amendments and additional conditions contained in the KWL Procedures, plus any further conditions issued by the Housing Corporation in the year. If RSLs are not able to make this confirmation on screen the submission will not be able to proceed. 
 
3.10 RSLs must be able to confirm acceptance of all certifications that appear when the scheme has been submitted
 
3.11 Payment will be made direct to RSLs after a relevant milestone has occurred i.e. acquisition, start on site, practical completion or occupancy. There needs to at least ten working days between receipt of the application and the payment date. Where the Corporation receives the submission less than ten working days before the payment date, SHG will not be paid on the payment date but will be paid ten working days after receipt of the submission. The Corporation will not pay simple interest to compensate for late payments where the submission is not received within this timetable.
 
3.12 SHG can only be paid in respect of a complete submission that includes all the   monitoring information.
 
3.13 Payment of grant is dependent on available cash within an [RSL’s] cash planning target and the Housing Corporation’s regional cash limit. 

4 ELIGIBLE COSTS AND CALCULATION OF GRANT

4.1  Eligible costs are a proportion of the purchase price of the homes purchased and an administration charge to cover the cost of publicising and administering the scheme. Grant must be used to subsidise the purchase of homes by key workers and not, in the case of new developments or rehabilitation schemes, excess development costs for example where the cost of development exceeds the value of the property. KWL grant cannot be paid towards the incidental expenses of purchasers such as legal fees and removal expenses.
 
4.2 Feasibility studies, setting up costs and administration costs in excess of those covered by the administration charge, are ineligible for grant.

5 INTEREST ON DELAYED PAYMENT OF CLAIMS

5.1 The Corporation will compensate RSLs with an interest payment on the delayed payment of a SHG claim only for that part of the delay due solely to the Corporation - see SALE-4.
 

6 SUSPENSION AND RECOVERY OF GRANT

6.1 The Housing Corporation reserves the right to suspend grant payments if an RSL becomes subject to Housing Corporation supervision. Where grant payment has been suspended, the Corporation may also recover grant already paid - see REC-4 para 5 etc..
 

7 QUALIFYING CRITERIA FOR KEY WORKER LIVING

7.1 To qualify for housing under KWL at least one member of the household applying to participate in the scheme must be employed within a specified key worker group. There is no discretion to vary the terms of the allocation in this respect. For participation in any HomeBuy scheme, an offer of employment is not sufficient.   For intermediate rent schemes, where the applicant is moving into an area to take up an offer of employment, they may be assisted up to 3 months before the date employment is due to commence on condition that they take up employment on the agreed date.  Where available, the key worker should be required to provide a copy of their signed contract of employment.

7.2 Key workers eligible for assistance must fall within the key worker groups specified in the grant offer letter. The following key worker groups are eligible for assistance under this programme:

• Clinical staff employed by the NHS (excluding doctors and dentists).
• Teachers, including FE teachers and Early Years/nursery teachers
• Police officers and community support officers in forces listed in Annex B (frontline police staff (civilians) may also be eligible in some areas - see Annex B)
• Prison officers and some Prison Service staff in prisons listed in Annex B
• Probation Officers, Senior Probation Officers, Probation Service Officers and, for intermediate rent only, Trainee Probation Officers
• LA/LEA/NHS Social workers
• LA Therapists (including Occupational Therapists and Speech and Language Therapists)
• LA Educational Psychologists
• LA/LEA/NHS nursery nurses
• LA Planners
• LA clinical staff
• Uniformed staff, below principal level, in Fire and Rescue Services.
• Connexions Personal Advisors
• Armed Forces personnel and some civilian MoD personnel (clinical staff, MoD police officers and uniformed staff in the Fire and Defence Service

Within these broad groups, detailed criteria will be applied to determine eligibility, as set out in Annex B. This list may be subject to change over time. Scheme providers will be notified formally in writing of any amendments.

7.3  Assistance through the scheme can only be given to those who could not otherwise buy or are unable/have difficulty renting a home at market rent that is suitable for their households needs and within a reasonable ‘travel to work’ area of  their employment. The definition of ‘travel to work’ area will depend on the  locality, the type of employment and the transport links.

7.4 Where someone is looking to exercise an opportunity to purchase an alternative property to the one they currently own on a like for like basis, whether or not it was purchased with government assistance, this is only permissible in specific circumstances (see eOMHB-3 para 1.3 ). There is no scope for the purchase of a more expensive home in a different area under this scheme, where current housing needs are met in the existing property.

7.5 For those looking to buy a home through one of the home ownership options, the total household income, capital and savings must be taken into account and while there is no set minimum income, RSLs are required to be mindful of the purchasers ability to afford and sustain home ownership  in the long term.  Applicants must not be in mortgage or rent arrears or in breach of their current tenancy agreement at the time of the application.  Where a tenant is or has been in arrears for a short period due to a sudden change in circumstances or an administrative delay or error in recording the rent paid to a public sector landlord, the RSL may use their discretion to allow the case to proceed where it is satisfied the rent is being paid and the applicant has sufficient income to support a mortgage.  In the case of private sector tenants, the RSL must be satisfied that the tenant has not had a history of rent arrears. As a guide RSLs are expected, but not limited, to use 3 x joint income and 3.5 x single income to determine the potential purchasers' mortgage potential.  Purchasers should be expected to maximise their borrowings without over extending themselves financially. RSLs should ensure a rigorous affordability check is carried out which includes looking at savings and outgoings, to assess the sustainability of the purchase . The FSA's rules require lenders to take into account a borrower's ability to repay a loan and the sustainability of the particular loan being considered. Further guidance is available to lenders and mortgage intermediaries when assessing a borrower's ability to repay a loan, and can be found by accessing the FSA's website http://www.fsa.gov.uk.
 
7.6 The maximum household income level for KWL is £60k.  Scheme providers  have discretion to accept applications from those with marginally higher  incomes in exceptional circumstances.   All such decisions must be seen to be  fair to all applicants and transparent and fully documented for audit purposes.

7.7  RSLs must make reasonable checks to ensure that applicants meet the eligibility criteria for the scheme. This should include documentation such as confirmation of employment status and sight of current/ recent payslips. See Annex B.

7.8  It will be for individual RSLs to ensure that they comply with the Data Protection Act 1998. Personal data must be processed fairly and lawfully. In order to be eligible under the scheme all applicants must give their consent in writing for personal data about their employment status to be processed by the RSL, Housing Corporation, and Government Departments.  This will allow applicants eligibility status to be monitored whilst they are in receipt of assistance under the scheme. 

Tracking eligibility

7.9  The HomeBuy Agent (or the developing RSL in the case of New Build HomeBuy and Intermediate Rent schemes) must inform the employer (and the HomeBuy Agent) that a key worker is receiving assistance under the scheme. The employer will monitor the employment status of the key worker and notify the HomeBuy Agent/ RSL of any change in the eligibility status of the individual. Although HomeBuy Agents/ RSLs should also undertake annual checks of the employment status of beneficiaries, employers are required to keep the HomeBuy Agent/ RSL informed of any changes in the employees’ status. 

7.10 HomeBuy Agents are required to establish robust mechanisms whereby they are able to regularly review and confirm the qualifying employment status of key public sector workers and are able to implement speedy grant recovery procedures should clawback apply.

7.10.1 On an annual basis, at the end of the financial year, for each key worker household, the HBA/RSL should:

• check with the key worker's employer that the key worker remains in eligible employment;
• initiate clawback (or monitoring of the time period prior to clawback applying) where the key worker is found no longer to be eligible;
• confirm to the Corporation's regional investment team that this check has been carried out, and the numbers of households found no longer to be eligible.

7.10.2 Confirmation should be sent to the Corporation within the first quarter following, i.e. by the end of June.

7.11 The beneficiary is also obliged, under the terms of the legal charge (it will not be a condition of the lender’s mortgage), to notify the HomeBuy Agent of any change in employment within seven days of the change. This requirement will also apply to New Build HomeBuy and intermediate rent tenants and will be contained in the legal documentation/ tenancy agreement.

Continuing Eligibility on Change of Employment

7.12 Where a keyworker, who has secured a property through the KWL programme, is looking to change jobs they must seek written confirmation from the HomeBuy agent or their landlord RSL that if they take up the new position they will still be eligible and clawback will not be invoked - see below.  This will be determined by the Key Worker eligibility criteria listed in Annex B that may be amended from time to time by the Housing Corporation in conjunction with the DCLG. The eligibility will remain in place for six months from the date of written confirmation, even if the eligibility criteria change within those six months.

8 CLAWBACK

8.1 On sale or transfer of property, or within 2 years for OMHB or 5 years for NBHB of a key worker leaving a qualifying form of employment the Home Buy Agents’ equity loan must be repaid or outstanding share bought out. Changes in the sector specific eligibility criteria will not, on their own, trigger clawback.  Beneficiaries' eligibility status will be judged against the criteria prevailing at the time they were granted assistance under the scheme, unless they change employment or wish to exercise the portability option in which case their eligibility will be re-assessed against the current version of the sector specific eligibility criteria. All valuation fees are to be paid by the owner.

Exclusions

8.2 The clawback rules would not apply where a key worker left their employment because:

• they retired, provided that a minimum of five years continuous service has been undertaken since the qualifying key worker was granted assistance under the scheme;
• they were made redundant;
• they left with the employer's permission, for health reasons validated by a health professional (i.e. early retirement on health grounds, dismissal on health grounds);
• they died in service (when it would become a matter for probate).
  

In such cases, sale of the property or transfer of ownership only would trigger repayment.

8.3 Repayment would also not be required if they took a career break of up to 12 months with their employer's permission. This period could be extended to a maximum of three years, at the employer's discretion in exceptional circumstances, with an assumption that this would be for family reasons. Further extensions beyond the three years will trigger the clawback requirements. There may be other special circumstances where it would be appropriate to defer repayment until a later date on sale of the property or transfer of ownership.  All exceptional cases should be presented to the Corporation who will decide whether this approach is merited.

Divorce

8.4 Where a court is considering the terms of the property settlement they will serve the HomeBuy Agent (as one of the mortgagees) with an application form indicating the intention to proceed for ancillary relief, i.e. a property transfer order.  The HomeBuy Agent should ask to see the financial statement, setting out the applicant's financial situation and agree with the Corporation whether it is appropriate to defer or waive the clawback, should the court decide that immediate sale of the property would not be advisable. As a general rule clawback should be applied as usual if there are: a) no children; or b) there are children, but both parties can be adequately housed from the proceeds of the sale. Waiver or deferral clawback would normally only be considered if there are children under the age of 18 or in full time education, where re-housing would be difficult, or other extenuating circumstances apply.

Change of employment

8.5 Repayment of an equity loan will not be required as long as the new post qualifies as eligible employment under the scheme as set out in Annex B. The only exceptions to this rule are:

• If eligible police force employees (including British Transport Police and the Civil Nuclear Constabulary) wish to make a permanent transfer to another police force, or any other eligible employment, it will be up to the exporting police force to decide whether to invoke clawback or allow the key worker to retain the loan.
• London Challenge Teachers purchasing homes with equity loans in excess of £50,001 will be required to remain as a teacher and be employed within the Greater London area, i.e. in a London Borough or the City of London
• If eligible fire and rescue service employees wish to make a permanent transfer to another fire and rescue service, or any other eligible employment, it will be up to the exporting service to decide whether to invoke clawback or allow the key worker to retain the loan.

Recovering the equity loan

8.6 The clawback provisions take effect from the date that the beneficiary leaves eligible employment.  Thus, the loan must be repaid two/five years from the date the key worker leaves eligible employment, not two/ five  years from the date that notification is received.  If the beneficiary returns to eligible employment within the two/ five -year period the clawback provisions no longer apply. 

8.7 The HomeBuy Agent should write to the beneficiary and set out the next steps as soon as notification from the employer/employee is received. This letter should make it clear to the beneficiary that, in cases of hardship, they can make a case for deferral or waiver of clawback.  The Corporation will adjudicate on all such cases. 

8.8 The HomeBuy Agent will be expected to use all reasonable endeavours to recover debts.  As they have a charge on the property the HomeBuy Agent can initiate legal action to ensure repayment. The lender must be informed of the intention to initiate legal action, as the property may need to be sold to recover the debt.      

TYPES OF ASSISTANCE

9.1  An allocation made under KWL does not imply Corporation endorsement of the type of assistance or any conditions attaching to it. It is the responsibility of the RSL, taking legal advice if necessary, to ensure that the type of assistance and all other aspects of its administration of the scheme, complies with all relevant legislation, is mortgageable, within its vires and that it has taken account of any tax implications both for the RSL itself, applicants and the applicants’ employers.

9.2 The amount of subsidy should be the minimum required to assist the key  worker household into home ownership or to trade up to a property  suitable for their needs, taking into account total household income and  house prices of suitable properties. However, where the full level of  subsidy is needed in an individual case, this should be awarded.  RSLs should  not regard the average subsidy given in the allocation as an automatic  entitlement.

10 TAXATION

10.1  Guidance on tax and National Insurance contributions arising from the assistance provided to key workers under KWL is set out in the attached Annex C.  If RSLs require further guidance they must contact HM Revenue and Customs.

11. RECYCLING OF GRANT

11.1  For general guidance in respect of grant recovery please refer to the REC chapter. Where KWL assistance is repayable by the purchaser on disposal, leaving the qualifying form of employment, or other event, details must be shown separately in the HomeBuy Agent's accounts - see REC-4 para 5.11 etc.  Although HomeBuy Agents can recycle grant for further KWL, where allocations are held for more than one region, the grant must remain within the same region. Any non-HomeBuy Agent receipts should be repaid to the Corporation who will allocate them for the provision of additional homes through the programme. HBA's should notify the Corporation's regional investment team who will arrange for an invoice to be issued. Further guidance will be issued on accounting for and the permitted uses of recycled KWL grant.

12 MONITORING AND EVALUATION

12.1 RSLs, which receive an allocation for KWL, will be required to collaborate in research commissioned by DCLG/Housing Corporation into the impact, effectiveness and value for money of KWL. They will also be required to participate in CORE and complete CORE Sales logs.

12.2 RSLs will be required to provide both the DCLG and Housing Corporation with the required monitoring data as required, which may be subject to change during the life of the programme.

12.3 In addition to the information supplied via the Corporation's IMS, HomeBuy Agents will be required to provide further information direct to DCLG and the Housing Corporation, for example information as required in the HomeBuy Agents' Contract, and other information as the DCLG and Corporation may require from time to time. RSLs will need to provide HomeBuy agents with the necessary information.

13 COMPLIANCE AUDIT

13.1  KWL schemes will be subject to Compliance Monitoring and Compliance Audit as per guidance at GENERAL-2 and GENERAL-9. RSLs must retain all relevant documentation on file for a period of six years after receipt of funding including the following for KWL schemes:

• copies of all promotional literature and information booklets;
• copies of all leases, covenants and legal charges;
• copies of all correspondence with employers and sponsoring local authorities;
• Solicitor's correspondence confirming dates of purchase completions and purchase prices;
• copies of desk instructions for RSL staff responsible for prioritising applicants;
• details of purchasers who have benefited from the scheme in terms of occupation, household income etc.;
• similar details for rejected applicants;
• ethnic origin of applicants and purchasers;
• the RSLs assessment of accepted and rejected applications;
• details of grant repaid by purchasers on disposal or other event and the treatment of this by the RSL;
• details of any surpluses arising from KWL and the treatment of this by the RSL;
• details of tenants who cease to be entitled and the treatment of this by the RSL.

14 GUIDANCE FOR APPLICANTS

14.1  Guidance at Annex B should be referred to together with any guidance produced locally by key worker employers. RSLs should also produce guidance for applicants which could include, for example, their detailed interpretation of 'travel to work' rules and, for first-time buyers, an indication of outgoings and how these are likely to increase to ensure sustainable home ownership, implications of the clawback requirements.

14.2  When making equity loans HomeBuy Agents must ensure that promotional material complies with the requirements of the Consumer Credit Act 1974.

15 SELECTION OF APPLICANTS

15.1  RSLs must have clear written procedures for communicating with and selecting applicants. Applicants must complete the HomeBuy Agents  application form and have their eligibility assessed by the HomeBuy Agent.   HomeBuy Agents and RSLs should  ensure that the arrangements they make  for administering the scheme provide protection for the public funds involved  and facilitate effective programme delivery. Applicants must be selected in accordance with the priorities and criteria set out in the guidance to applicants. RSLs must avoid any conflict of interest for staff involved in selecting  applicants.

15.2 The criteria must be clear to applicants and sufficient for RSLs to demonstrate at audit that those selected to purchase under the scheme met the priorities identified in Annex B. The guidance should include:

• Eligible occupations and employers;
• Upper household income limits;
• Qualifying criteria as set out for each sector;
• Criteria used to prioritise applications. These may simply be date of application for those who meet the criteria or may be more specific, for example those whose specialisms are in particularly short supply. The criteria to be used must take account of the advice received from DCLG;
• The types of properties to be purchased, whether on a development or open market. If open market, an indication of acceptable size, values, locality and condition and any ineligible properties;
• Any tax implications arising from the assistance offered;
• Any resale covenants and other conditions and arrangements for repayment on resale and/or leaving qualifying form of employment;
• Information regarding the tenancy used for rented properties and indicative rent levels, together with the implications on leaving qualifying form of employment;
• Applicants should be required to certify that the information they have provided is complete and accurate and that they will not purchase more than one property through any schemes benefiting from public subsidy. They also need to certify that the property is their only home.

15.3  As set out in Annex C on Tax issues, in order to minimise the tax implications  of KWL assistance employers must not nominate or prioritise applications from individual key workers, either formally or informally. Employers may indicate their general priorities for types of staff to be assisted under the scheme and these priorities may be included in the RSLs selection criteria. However, decisions on individual applications should be determined entirely by RSLs without further reference to or advice from employers, apart from any checks required from employers in order to validate information provided on application forms submitted by key workers.

16 ANNEXES

16.1 Annexes referred to above are produced at the end of this chapter.