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Rent Comparability Study (RCS)  

The HUD Section 8 Contract Renewal Policy Guide (Guide), requires a Rent Comparability Study (RCS) if Owner/Agent (O/A) request renewal of a Section 8 Contract under;

1.     Option One – A & B, Entitlement Mark-Up-To-Market (MU2M) Eligibility

2.     Option Two, Contract Renewals for Other Projects with Current Rents At or Below Comparable Market Rents

3.     Option Three  Referral to HUD Office of Recapitalization (Recap)

O/A must submit a request for Section 8 Contract renewal to HUD or Section 8 Contract Administrator no earlier than 120 days before the expiration of the Section 8 contract. O/A should not submit their request no earlier than 180 days before the Section 8 Contract expires.

 

If a RCS is required to submit under the Guide, O/A must submit their request for Section 8 Contract renewal along with the other information required in the Guide. If a RCS is required to be submitted, HUD recommends the Section 8 Contract renewal request be submitted 180 days before the contract expires, because HUD may commission an Independent RCS when processing a request for renewal of a Section 8 Contract.

Caution: After an O/A commissions a RCS, which cost thousands of dollars, and O/A compares RCS Market Rent Potential to currently approved Section 8 Contract Rent Potential it may be discovered the RCS Market Rate Rent Potential is less than current Potential.  In this case, a complete RCS would NOT qualify to be used for a request for increase in rents when renewing a Section 8 Contract.

What is the O/A alternative; DO NOT commission a complete RCS, but requests the Appraiser to provide LIMITED RCS GRIDS. After an O/A reviews RCS GRIDS with their Appraisers make a determination if a complete RCS is feasible.

Also, there is a HUD qualifying analyses of Owners’ RCS Grids Market Rents that may trigger a HUD commissioned Independent RCS. It is important O/A use the suggested LIMITED RCS GRIDS procedure. I suggest discussing this proactive pre-review with LIMITED RCS GRIDS with your Appraiser. When assisting preparation of renewal proposals for clients, I found that in some cases O/A did NOT do their due diligent ahead of time before accepting a complete RCS for submission of a request for renewal of their Section 8 Contracts which resulted in HUD reduced their current rents substantially.