On June 15, 2015, HUD published a revised Rental Assistance Demonstration (RAD) Notice, PIH 2012-32, REV-2. This Notice allows Moderate Rehabilitation (Mod Rehab) Single Room Occupancy (SRO) projects that were funded under the McKinney-Vento Homeless Assistance Act to convert to either Project-Based Vouchers or Project-Based Rental Assistance under RAD. This will be of immediate interest to SRO owners/sponsors, Public Housing Agencies (PHAs), and Continuums of Care (CoCs) involved with SRO projects.
The Notice has been revised primarily to: (1) incorporate changes authorized by the FY 2015 Appropriations bill (e.g., increasing the cap on public housing conversions from 60,000 to 185,000 units), (2) include lessons learned from the previous two years with respect to gaps in policy and better management of transactions, and (3) clarify questions on the Notice that HUD was frequently getting from stakeholders.
The Notice is effective immediately. However, HUD is seeking comment on (1) the prioritization of high investment public housing applications and (2) the processing of Mod Rehab conversions through the Second Component. These two provisions will be effective in 30 days following publication unless, upon review of any public comments, HUD determines that any adverse comment leads to reconsideration. In that instance, HUD will notify the public in a new revision immediately upon the expiration of the comment period.
View Notice PIH 2012-32, REV-2.
Some of the key revisions include:
- Extending the time period for submission of multi-phase public housing applications to July 1, 2018.
- Eliminating all pre-Financing Plan milestones and better aligning the RAD submission requirements for tax credit transactions with those of the tax credit issuing bodies.
- Identifying the specific HUD nondiscrimination and equal opportunity requirements that are applicable under different conversion plans.
- Allowing Mod Rehab SRO projects that were funded under the McKinney-Vento Homeless Assistance Act to convert under RAD.
- Establishing residents’ right to remain or return to the property in all Mod Rehab, Rent Supplement (Rent Supp), and Rental Assistance Payments (RAP) conversions.
- Ensuring that Davis-Bacon wages apply to all rehabilitation/construction work.
To help PHAs and their stakeholders learn of the changes, HUD will host a Mod Rehab/SRO webinar this Wednesday, June 17, 2015 at 11:45 AM EDT.
Register for the webinar.
Additionally, HUD will hold live Q/A sessions on Mod Rehab, Rent Supp, and RAP on Friday afternoon beginning June 19, 2015. The first Q/A session will take place on Friday, June 19, 2015 at 3 PM EDT. Dates and access information for later sessions will be sent by the CoC mailing list.
Register for the June 19th Live Q/A Session.