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9-12. COMPUTING ADJUSTED RENTS FOR COMPARABLE UNITS

HUD Section 8 Renewal Policy Guidebook · 2026 edition · updated 2026-07-29 · United States

This section provides guidance to RCS appraisers for deriving an adjusted rent for each comparable . RCS appraisers must review the instructions provided in this section and the lineby-line instructions provided in Appendix 9-1-1, before preparing the Rent Comparability Grid (Form HUD-92273-S8).

  • A. Analyze for differences between subject and comparable. To compute the adjusted rent, the RCS appraiser must:

    1. Compute an effective rent by adjusting the most recently charged rent for factors (e.g., rent concessions) listed in Part A of the Rent Comparability Grid .

    2. Determine which differences between the subject and the comparable unit would affect the amount of rent a typical applicant would be willing to pay in the subject’s market area.

    3. For each difference tenants would value, adjust the comparable’s rent by the amount tenants in the subject’s market area would typically pay for that difference. Adjustments must be displayed in dollar amounts.

  • B. Adjust the comparable to the subject. Determine what rent the comparable would obtain if the comparable were nearly identical to the subject. For example, if the comparable is:

    1. Inferior to the subject on a characteristic, the RCS appraiser must adjust the comparable upward. The RCS appraiser must enter the adjustment as a positive value to indicate that residents of the comparable would pay more if the comparable had the subject’s characteristic. For example, if the comparable unit size is 100 square feet smaller than the subject units, and the RCS appraiser estimates the value of incremental square feet to be $0.50 per square foot, $50 would be entered on Line 13 of the Rent Comparability Grid (Form HUD-92273S8).

    2. Superior to the subject on a characteristic, the RCS appraiser must adjust the comparable downward. The RCS appraiser must enter the adjustment as a negative value to indicate that residents of the comparable would pay less if the comparable had the subject’s characteristic. For example, if the comparable units include patios

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or balconies and the subject does not, and the RCS appraiser’s research shows that at a third project in this market that offers units both with and without balconies, units with balconies rent for $15 more, –$15 would be entered on Line 14 of the Rent Comparability Grid (Form HUD-92273-S8).

  • C. Provide narrative explanations. RCS appraisers must provide a concise but professionally complete explanation as to why each adjustment was made and how the dollar value was derived. The explanations must be clear and convincing to a person not familiar with the properties and market areas involved.

    1. Every line item adjustment on the Rent Comparability Grid requires two separate and distinct explanations in the narrative.
  • a. First, RCS appraisers must explain why the adjustment was made. Specifically, RCS appraisers are required to state the reasons that justify an adjustment and explain whether the adjustment would be on a total dollar amount basis (generally used for qualitative adjustment characteristics such as “neighborhood” or “location”) or on a dollar amount per the comparison unit (generally used for adjusting unit size differences).

Example: “Comparables A and B were each adjusted upward by $20 for not offering units with either a patio or balcony.”

  • b. Second, RCS appraisers must explain how the dollar value was derived. Specifically, RCS appraisers are required to explain the rationale for their adjustments. This could be supported through paired comparable analysis, interviews with management agents and leasing agents, or prior experience in the subject market. This second component (“how”) of the narrative is required for all adjustments where the amount of adjustment exceeds a nominal amount (a dollar amount or percent of unadjusted rent of the comparable, as defined in Appendix 9-1-1).

Example: “The subject and comparables C, D, and E offer either a balcony or a patio, while comparables A and B do not offer that feature in any of their units. The RCS appraiser recently appraised a project in this market that offered units both with and without balconies. Units with balconies commanded an average additional rent of approximately $20, which provides the basis for the upward adjustment to comparables A and B”.

  1. RCS appraisers shall not just reiterate the entries in the data column. It would be unacceptable for an RCS appraiser to state: “A negative adjustment was made to comparable A for location.” Instead, the RCS appraiser must outline the data and logic used to arrive at the adjustment amount.

Example: “Comparable A was adjusted downward to reflect its location in a more desirable neighborhood that consists primarily of single-family homes, has little crime, and has good access to shopping. The adjustment was estimated by comparing the rents at comparable A with those of comparable D, which is in the subject’s neighborhood but otherwise very similar to comparable A. The average value of the superior location was estimated to be $25.”

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  1. For all adjustments exceeding a nominal amount (a dollar amount or percent of unadjusted rent of the comparable, as defined in Appendix 9-1-1), the RCS appraiser must present market data to support each conclusion. Section 9-12.C.1 above shows an example of the two-part explanation needed for adjustments exceeding the nominal amount. For minor adjustments (adjustments not exceeding the nominal amount), the RCS appraiser may provide a subjective evaluation of why the observed differences would affect rent.

, as defined in Appendix 9-1-1), the RCS appraiser must present market data to support each conclusion. Section 9-12.C.1 above shows an example of the two-part explanation needed for adjustments exceeding the nominal amount. For minor adjustments (adjustments not exceeding the nominal amount), the RCS appraiser may provide a subjective evaluation of why the observed differences would affect rent.

  • D. Pay attention to Special Issues. The RCS appraiser must pay special attention to the detailed guidance for all line items in the Rent Comparability Grid (Form HUD-92273S8) (see Appendix 9-1-1). In particular, there are a few line items that are discussed under “General Instructions” in Appendix 9-1-1 along with common errors associated with those line items. The RCS appraiser must pay special attention to the guidance before making adjustments for those respective line items.

  • E. Follow the Guiding Principles when Quantifying Adjustments.

    1. Not all differences between the subject and the comparable require an adjustment. An RCS appraiser must adjust only for differences that would affect how much rent a tenant is willing to pay. If a difference would appear to affect rental value and no adjustment is made, the RCS appraiser must explain why.

    2. An adjustment must reflect the local market. The RCS appraiser must make an adjustment based on what typical renters in the subject’s particular market area would pay. Additionally, tenants in different markets may value amenities and services differently, so the RCS appraiser must be aware of sometimes subtle differences in the value of some project features even within the same community.

Example: Central air conditioning may be less valued by tenants in a beachfront project, compared to tenants at another project, perhaps not far away, but within a location with much warmer summertime temperatures.

  1. Adjustments often vary by unit type. Even in the same market, renters may value the same service differently among unit types.

Example: A second bathroom may be more valuable in a 3-bedroom than in a 2- bedroom unit.

  1. An adjustment must reflect rental value, not construction cost or the cost of providing a service.

Example: In adjusting for differences such as an elevator, amortizing the cost of the elevator over its useful life is not what a market renter would do. Any adjustment should reflect only what residents would typically pay for the convenience of using the elevator rather than climbing stairs. It is thus imperative that the value of the adjustment be market-derived, from sources such as pairedcomparable analysis or direct interviews with project management personnel, rather than cost-based.

  1. Adjustments, whether positive or negative, must be applied consistently. For a given property feature, RCS appraisers must not make small negative adjustments to a comparable when it is the subject that lacks that respective feature, while

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making large positive adjustments to a comparable when it is the subject, rather than the comparable, that includes that same feature.

  1. Do not duplicate adjustments. RCS appraisers must be careful not to adjust for the same element in more than one place.

Example: If adjustments are made for “project appeal” (line 8) and “age” (line 7), the RCS appraiser must take care to ensure that the sum of those lines is not more than the value the tenant would place on all features covered by those line items.

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Contents — HUD Section 8 Renewal Policy Guidebook
HUD Section 8 Renewal Policy Guidebook
  1. U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
  2. SPECIAL ATTENTION OF
  3. TRANSMITTAL
  4. A. Purpose
  5. Explanation of Changes
  6. Section 8 Renewal Policy Guidebook
  7. Office of Multifamily Housing
  8. Table of Contents
  9. Chapter One
  10. Introduction
  11. Chapter 1: Introduction
  12. Chapter 2: Section 8 Renewals
  13. Chapter 3: Option One: Mark-Up-To-Market
  14. Chapter 4: Option Two: Contract Renewals For Other Projects wi…
  15. Chapter 5: Option Three: Referral to Recap
  16. Chapter 6: Option Four: Renewal of Projects Exempt from or not…
  17. Chapter 7: Option Five: Renewal of Portfolio Reengineering Dem…
  18. Chapter 8: Option Six: Opt-Outs
  19. Chapter 9: Rent Comparability Studies
  20. Chapter 10: Residual Receipts
  21. Chapter 11: Tenant Issues
  22. Chapter 12: Physical Condition of the Project
  23. Chapter 13: HUD’s Refusal to Renew Section 8 Contracts
  24. Chapter 14: Rural Housing Service (RHS) Section 515/8
  25. Chapter 15: Section 8 Preservation Efforts
  26. — Chapter 16: “Old Regulation” State Housing Finance Agency Pr…
  27. 1-2. LEGISLATIVE HISTORY
  28. 1-3. RULEMAKING
  29. 1-4. ADMINISTRATIVE POLICY
  30. 1-5. APPLICABILITY
  31. 1-6. PAPERWORK REDUCTION ACT
  32. Chapter Two
  33. Section 8 Renewals
  34. 2-1. INTRODUCTION
  35. 2-2. OWNER OPTIONS
  36. 2-3. TYPES OF RENEWALS
  37. 2-4. EARLY TERMINATION OF A CONTRACT
  38. 2-5. RENT COMPARABILITY STUDY (RCS)
  39. Note: The AE/CA shall not lower the comparable market rents in…
  40. Note: A RCS is not required at any subsequent renewal of an EL…
  41. 2-6. CONTRACTS
  42. 2-8. SHORT-TERM CONTRACT RENEWALS
  43. 2-10. COMBINING CONTRACTS
  44. 2-11. REQUEST FOR A CONTRACT EXTENSION
  45. 2-12. DISTRIBUTIONS
  46. Note: The conditions listed above for receiving access to incr…
  47. 2-13. RENT ADJUSTMENTS
  48. 2-14. OPERATING COST ADJUSTMENT FACTOR (OCAF)
  49. 2-15. BUDGET-BASED RENT ADJUSTMENT REQUESTS
  50. 2-16. INCREASES IN DEPOSITS TO THE RESERVE FOR REPLACEMENT
  51. 2-17. PROCESSING INSTRUCTIONS
  52. Note: If the project has a budget approved by the AE/CA less t…
  53. Note: HUD does not accept the RHS utility analysis. The owner …
  54. 2-18. WAIVERS
  55. 2-19. DUNS NUMBER
  56. Chapter Three
  57. 3-1. OVERVIEW
  58. 3-3. OPTION ONE-A ENTITLEMENT MARK-UP-TO-MARKET ELIGIBILITY
  59. Note: Nonprofit controlled for profit entities as described in…
  60. 3-4. 150 PERCENT RENT CAP FOR OPTION ONE-A
  61. 3-5. EXCEEDING THE 150 PERCENT OF FMR CAP
  62. 3-6. OPTION ONE-B DISCRETIONARY MUTM ELIGIBILITY
  63. Note: Non-profit owned projects that meet one of the three cri…
  64. 3-7. RENEWAL REQUESTS
  65. 3-8. PROCESSING INSTRUCTIONS
  66. 3-9. ANNUAL RENT ADJUSTMENTS DURING A MULTIYEAR CONTRACT
  67. Chapter Four
  68. 4-1. ELIGIBILITY
  69. Note: Projects currently renewed under either Option Two or Op…
  70. 4-2. CONTRACT RENEWAL
  71. 4-3. ANNUAL RENT ADJUSTMENTS DURING A MULTIYEAR CONTRACT
  72. 4-4. PROCESSING INSTRUCTIONS
  73. Chapter Five
  74. Note: WAIVERS TO CHAPTER FIVE WILL BE IN ACCORDANCE WITH RECAP…
  75. Note: Risk Sharing Projects do not meet the definition of “eli…
  76. 5-2. BINDING COMMITMENT
  77. 5-3. ENTRY INTO RECAP
  78. Note: In cases where a CA makes the determination that contrac…
  79. 5-4. CONTRACT RENEWALS — RENT OR DEBT RESTRUCTURING
  80. 5-5. SUBSEQUENT RENEWALS
  81. 5-6. “WATCH LIST” MTM PROJECTS
  82. 5-7. GENERAL INFORMATION
  83. Chapter Six
  84. 6-1. ELIGIBILITY
  85. Note: State and local government financed projects that are no…
  86. Note: In cases where referral to Recap is necessary, CAs must …
  87. Note: Section 202 and 811 Capital Advance projects are not eli…
  88. Note: Projects financed under the risk-sharing loan programs u…
  89. 6-2. RENEWALS
  90. Reminder: For projects (including 202 projects) that are being…
  91. 6-3. RENT ADJUSTMENTS FOR MULTI-YEAR CONTRACTS
  92. 6-4. SECTION 202 REFINANCINGS
  93. Chapter Seven
  94. 7-1. ELIGIBILITY
  95. Portfolio Reengineering Demonstration Program Projects
  96. 7-2. RENEWAL OF PORTFOLIO REENGINEERING DEMONSTRATION PROJECTS
  97. FIVE
  98. Note: Owners can request that the existing Demo Program Use Ag…
  99. 7-4. PROCESSING INSTRUCTIONS FOR DEMONSTRATION PROJECTS
  100. 7-5. PRESERVATION PROJECTS (LIHPRHA AND ELIHPA)
  101. 7-6. OWNER’S SUBMISSION FOR PRESERVATION PROJECTS
  102. Note: Owners can request that the existing Preservation Use Ag…
  103. 7-7. PROCESSING INSTRUCTIONS FOR PRESERVATION PROJECTS
  104. 7-8. PROJECT SPECIFIC RENTS (PSRS)
  105. Chapter Eight
  106. 8-1. OVERVIEW
  107. 8-2. OWNER REQUIREMENTS FOR TENANT NOTIFICATION
  108. 8-3. PROCESSING INSTRUCTIONS
  109. Note: If proper notification was not provided, the owner must …
  110. Chapter Nine
  111. 9-1. BACKGROUND
  112. 9-2. APPLICABILITY OF CHAPTER NINE
  113. 9-3. ROAD MAP TO CHAPTER NINE
  114. 9-4. ALTERNATIVES TO RENT COMPARABILITY STUDY
  115. 9-6. METHOD TWO: COMPARING PROPOSED SECTION 8 RENTS WITH RENTS…
  116. 9-7. PREPARING A RENT COMPARABILITY STUDY
  117. 9-8. APPRAISER QUALIFICATIONS
  118. 9-9. ANALYZING THE SUBJECT PROJECT
  119. Note: Appraisers should not take into consideration demographi…
  120. Note: Government boundaries like state or county lines often d…
  121. 9-10. SELECTING COMPARABLE UNITS
  122. 9-11. COLLECTING AND DOCUMENTING DATA ON COMPARABLE UNITS
  123. 9-12. COMPUTING ADJUSTED RENTS FOR COMPARABLE UNITS
  124. 9-13. DERIVING ESTIMATED MARKET RENTS
  125. 9-14. PROCEDURE FOR MANDATORY MARKET RENT THRESHOLD
  126. Example Project in ZIP code 76469
  127. 9-15. HUD REVIEW OF RENT COMPARABILITY STUDY
  128. 9-16. INITIAL AND SUBSTANTIVE REVIEW OF OWNER’S RCS
  129. 9-17. COMMUNICATING RESULTS OF HUD/CA REVIEWS
  130. 9-18. OWNER APPEALS
  131. 9-19. IMPOSING SANCTIONS ON APPRAISERS
  132. APPENDICES
  133. - Instructions for Completing the HUD Form 92273 S8
  134. Part A: Rents Charged (lines 1 through 5)
  135. Part B. Design, Location, Condition (lines 6 through 10)
  136. Part C. Unit Equipment/Amenities (lines 11 through 23)
  137. Part D. Site Equipment/Amenities (lines 24 through 32)
  138. Part E. Utilities (lines 33 through 39)
  139. Part F. Adjustments Recap (lines 40 through 43)
  140. Part G. Adjusted Rents (lines 44 through 45)
  141. Required Contents of a Rent Comparability Study
  142. Comparable Project Profile

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