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HUD published “Notice of Proposed Information Collection: Comment Request; Section 8 Renewal Policy Guide” in the Federal Register.
HUD is currently soliciting public comment on to the Section 8 Renewal Guide. NAHMA is in the process of obtaining revised copies of the Section 8 Renewal Guide and the documents associated with the Guide. We will review these documents closely with our Regulatory Affairs and Senior Housing Committees and submit comments to HUD.
A copy of this notice may be found here: http://ww.gpo.gov/fdsys/pkg/FR-2012-08-08/pdf/2012-19326.pdf. Please note, the revised documents are not available at this website. NAHMA will also provide those revised documents to members once we obtain copies and request member feedback on the materials at that time.
In addition, you may recall that HUD made a number of revisions to the Section 8 Renewal Guide on May 24, 2012. The Guide revisions:
· End HUD’s policy of allowing properties to extend multi-year contracts;
o Properties must now renew their contract with a mandatory 20 year term, plus the remaining years left on the original contract;
· Eliminate Note 1 following Section 3-2 D;
· Require the use of current debt service in an Owner’s budget-based rent increase request for Option 4;
· Permit the rent adjustments in multi-year Option 4 contracts using a budget basis only if the proposed rents do not exceed comparable market rents;
· Provide for new procedures when rents in a Rent Comparability Study (RCS) are above 110 percent of small area Fair Market Rent (SAFMR) for metropolitan areas or Fair Market Rents (FMR) in non-metropolitan areas;
o Which must include a statement as to the percentage of properties in the market area whose rents exceed 110% of the SAFMR in metropolitan areas or 110% of the FMR in non-metropolitan areas and provide support data from the local market; and
· Remove language in Chapter 16 “Other Issues” that requires original debt service to be used in budget-based rent increase requests in Option 4 to make it consistent with the language in Chapter 6.
NAHMA has several concerns with the changes made to the Section 8 Renewal Guide, including but not limited to:
· The mandatory 20 year plus contract extension and extended use agreements may create a financial disincentive for property owners to refinance and/or renew their contracts;
· Holding budget based rent increases on Option 4 renewals to comparable market rents may cause hardships for some properties;
· The market already acts as a benchmark for RCSs; and
· The requirements that call for appraisers to include data in the RCSs are arbitrary and statistically flawed.
NAHMA will be addressing our concerns directly with Multifamily DAS Marie Head later this month. We have also signed on to an industry letter that was sent to DAS Head in opposition to the changes to the RCS appraisal guidelines in the updated Guide. A copy of that letter may be found here: http://www.nahma.org/member/New%20HUD%20Docs/Industry%20Letter%20on%20Section%208%20Renewal%20Guide%20RCS%20Changes%20062212.pdf
A copy of the page changes containing the revisions to the Section 8 Renewal Guide may be found here: http://www.nahma.org/member/New%20HUD%20Docs/12-G-1%20Consolidated%20Page%20Changes%204-24-12.pdf