Revised Rental Assistance Demonstration Notice Aims at Facilitating Financing

On July 2, 2013 HUD issued PIH Notice 2012-32 REV-1 containing a number of changes to the eligibility and selection criteria for Public Housing Agencies (PHAs) seeking to participate in the Rental Assistance Demonstration (RAD).The FY12 Appropriations Act allows HUD to convert public housing Capital and Operating Fund assistance for up to 60,000 units of public and Moderate Rehabilitation (Mod Rehab) housing to long-term, renewable, project-based Section 8 rental assistance (PBRA) or to project-based vouchers (PBVs). RAD also allows Mod Rehab, Rent Supplement (Rent Supp), and Rental Assistance Program (RAP) to convert an unlimited number of Tenant Protection Vouchers (TPVs) to PBVs, subject to the availability of TPVs. The original notice was issued on July 26, 2012 (see Memo, 7/26/2012).The changes all pertain to the public housing and Mod Rehab programs. The primary changes include:

  • Discussion of information that must be included in a PHA’s Significant Amendment to its PHA Plan is moved from the body of the notice to a new Attachment 1D, which clarifies the required information, calls for additional information, and provides a sample Significant Amendment.
  • A new Attachment 1E regarding an Addendum to the House Rules for a RAD development, specifying additional voucher termination notice requirements and resident grievance procedural rights.
  • Eliminating the 1,000-unit limit on the number of public housing units that a PHA can convert.
  • Allowing contract rents for applications submitted before the end of calendar year 2013 to be set at FY12 rent levels, establishing predictable rent levels to assure potential lenders.
  • Allowing PHAs to apply for a set of projects, as long as individual RAD applications for at least 50% of the projects in a set are submitted up front, with the remainder of the individual applications submitted within a year.
  • Allowing PHAs to apply for a project with multiple, distinct development phases over time, locking in the contract rent for the entire project at the time of the application.
  • Allowing PHAs to submit applications for two or more projects and adjust the Capital and Operating fund subsidies (and contract rents) of each in order to create uniform contract rents and subsidy amounts across projects, thereby facilitating financing.
  • Allowing financially-stressed HOPE VI projects to convert to RAD regardless of how long the project has been in service.
  • Allowing PHAs to apply for both RAD conversion authority and a Choice Neighborhoods Implementation grant.

Comments regarding some of the changes are due August 1, 2013. View PIH Notice 2012-32 REV-1 at: http://1.usa.gov/12NmsKtView a version of the notice showing actual changes in red at: http://1.usa.gov/12tFw1f