NAHMA HUD Update: Published RAD Blast! RAD Supplemental Notice Takes Effect (FR Notice Posted)

August 21, 2023

Dear NAHMA Members –

Please see the below RADBlast on changes implemented from the recent RAD Supplement Notice (attached).
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In this Issue of the RADBlast!:

·       HUD Published a Notice in the Federal Register

·       RAD Supplemental Notice Webinar - Recording Posted

·       Spotlight on 202 PRAC Preservation Rent Increase


 

Today, HUD published a Notice in the Federal Register effectuating the changes in the RAD Supplemental Notice (H-2023-08/PIH-2023-19).  As a reminder, certain sections of the Notice are effective immediately while others have a grace period.  Please see the summary below:

Supplemental Notice Section

Effective Date

RAD for PRAC Rent Setting

Immediately - 8/21/2023

Faircloth-To-RAD

Immediately - 8/21/2023

RAD/Section 18 Blends

Immediately - 8/21/2023

Housing Quality Standards

10 days after Federal Register Publication - 8/31/2023

Zero-HAP Residents

10 days after Federal Register Publication - 8/31/2023 See 90-day notice requirement for families paying above Zero-HAP Rent Cap

Radon Policies

Applies to Financing Plans or Conversion Plans submitted 14 days after Federal Register Publication - 9/4/2023

Energy Efficiency and Climate Resiliency

Applies to Financing Plans submitted 30 days following Federal Register Publication - 9/20/2023

Resident Engagement

30 days following Federal Register Publication - 9/20/2023. If a transaction has progressed beyond the point that changes apply, transaction will be held to the previous provisions of the RAD Notice.

 

RAD Supplemental Notice Webinar - Recording Posted

A recording of the live webinar “Overview RAD Supplemental Notice” held on August 9, 2023 and accompanying slides and webinar Q&A have been posted on www.hud.gov/rad under “RAD What’s New” and on the RAD Resource Desk RAD for PHAs Training page at www.radresource.net/webinars.cfm.

 

Spotlight on 202 PRAC Preservation Rent Increase

Owners of converting Section 202 PRACs may be eligible to increase the post-conversion Section 8 contract rent by up to either $250 per unit per month or $100 per unit per month, depending on the level of rehab or construction, to be effective upon conversion, provided the work to be performed as part of the RAD Conversion Plan will enhance climate resilience, energy and water efficiency, or appropriate design for elderly residents to age-in-place.

 

Beginning tomorrow, converting Section 202 PRAC project owners can formally submit a request for an increase to contract rents by completing the Preservation Rent Increase request in the project conversion application on the RAD Resource Desk.

For PRAC owners who are contemplating a RAD conversion, HUD has created a “RAD for PRAC: Preservation Rent Increase Eligibility Tool” to determine whether the project will meet the 60% or 30% of Housing Construction Cost (HCC) threshold based on anticipated rehab or construction costs. In addition, “RAD for PRAC: Preservation Rent Increase FAQs” have also been posted. To access these tools, navigate to the RAD Multifamily Document Library on the RAD Resource Desk at the following URL. The documents can be found under the Determining Rents section. https://www.radresource.net/mf_library.cfm

Owners interested in receiving a rent increase comfort letter from HUD can make an initial request for the rent increase up to six months prior to submission of the full Conversion Plan. HUD will make a preliminary determination of eligibility and of the projected per unit rent increase amount.  The Owner will make the final request when the complete Conversion Plan is submitted. Owners can make the initial request by completing the “Preservation Rent Increase” section of the conversion application on the RAD Resource Desk.

Thank you,
The RAD Team