Using retained RTB receipts to buy temporary accomodation

My client is proposing to buy temporary accommodation for homeless families. The acquisition is to be financed by using 30% retained RTB receipts and the balance from General Fund borrowing. The argument is that these properties can be defined as Social Housing under Part 2 of Housing & Regeneration Act 2008. Has any other Authorities undertaken such acquisitions and if so how did they get on when the Pooling Return was audited?