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 180 days before the
expiration of the Section 8 contract; or at the 5-year RCS life cycle. 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.
