HUD Publishes Revised RAD Notice - June 16, 2015
On Monday, June 15, 2015, HUD published a revised RAD Notice, PIH 2012-32, REV-2.
The Notice has been revised primarily to: (1) incorporate changes authorized by the FY 15 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.
A copy of the Revised Notice may be obtained at www.hud.gov/rad. Comments and questions on the Notice may be submitted to RAD@hud.gov.
Comments are sought on (1) the prioritization of high-investment public housing transactions and (2) the processing of all Mod Rehab conversions under 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.
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.
- Clarifying when non-dwelling property and land can be removed/released from the public housing program in conjunction with the conversion.
- Allowing a portion of the savings in public housing utility allowances to be captured in contract rents for project-based rental assistance (PBRA) conversions.
- Allowing Mod Rehab Single Room Occupancy (SRO) projects that were funded under the McKinney-Vento Homeless Assistance Act to convert under RAD.
- Providing an option for owners of Rent Supp and RAP projects to convert to a 20-year PBRA contract.
- Establishing residents’ right to remain or return to the property in all Mod Rehab, Rent Supp and 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 webinars on Wednesday, June 17, at the following times (listed along with the registration link):
- Rent Supp and RAP 10:30 AM EDT (https://attendee.gotowebinar.com/register/7569135169553399554)
- Mod Rehab/SROs 11:45 AM EDT (https://attendee.gotowebinar.com/register/8904421672744456706)
- Public Housing 2:00 PM EDT(https://attendee.gotowebinar.com/register/1614701362031471618)
Additionally, HUD will hold live Q/A sessions on Friday afternoon beginning June 19. Access to the June 19 sessions is provided below. Dates and access information for later sessions will be sent by RADBlast.
- June 19 Live Q/A Session on Public Housing 2:00 PM EDT http://www.atconference.com/events/registration.aspx?ID=f9f9c936-a142-487d-888f-d7b7f6e326b0.
- June 19 Live Q/A Session on Mod Rehab, Rent Supp and RAP 3:00 PM EDT http://www.atconference.com/events/registration.aspx?ID=730fbfcd-1afd-4d82-94da-d0c2ff2927de