9-15. HUD REVIEW OF RENT COMPARABILITY STUDY

This Section provides guidance to HUD/CAs on how to review an Owner’s RCS prepared and submitted in accordance with Sections 9-7 through 9-14. When referring to a particular staff position, this Section uses titles typically used at HUD. CAs should translate those to their own position titles.

This Section also defines categories of reviewers. Initial reviewers are HUD/CA staff. Substantive reviewers are required to be state-certified appraisers for all reviews conducted by CAs, or HUD appraisers for those completed by HUD’s Multifamily Regional Centers and Satellite Offices (such substantive reviewers are also referred to as RCS review appraisers). For instance, where HUD’s staffing does not permit the availability of a HUD appraiser, a nonappraiser HUD staff person can complete the substantive review, subject to the minimum requirements and process outlined below.

• A. Minimum qualifications for reviewers. Each RCS must be reviewed by staff members who possess the requisite knowledge needed for the level of review being performed. Section 9-16 provides guidance on the level of reviews.

  1. Initial Screening. An initial review for timeliness and completeness shall be completed by a HUD/CA initial reviewer using the checklist provided under Appendix 9-5. While completing this review, the HUD/CA initial reviewer must adhere to the policies and timeframes set forth in this Chapter’s guidance. The HUD/CA initial reviewer must also have read this Chapter and Appendices within the preceding 12 months of performing their first initial screening review.

  2. Substantive Review. All substantive reviews conducted by CAs must be completed by a state-certified general appraiser. Substantive reviews completed by HUD staff should ideally be completed by HUD appraisers. However, a non-appraiser

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substantive reviewer from HUD staff may complete the substantive review if they meet the following minimum qualifications:

  - a. Have a minimum of two years’ direct multifamily experience. Besides direct experience in HUD multifamily review, other acceptable qualifying experience would be two years’ employment in multifamily project management or leasing, multifamily loan or acquisition underwriting, or multifamily development. This background is necessary to effectively review the RCS facts, reasoning, and conclusions; and 

  - b. Have read this Chapter and Appendices within the preceding 12 months of performing their first substantive review. 

• B. Process for approving non-appraiser substantive reviewers. The Regional Center Director must authorize all non-appraiser substantive reviewers performing substantive reviews on RCSs within their region.

• C. Timing requirements. An initial screening review using the checklist in Appendix 9-5 must be completed within 10 calendar days of the date of receipt of an RCS from the Owner. The HUD/CA initial reviewer may contact the RCS appraiser directly unless the Owner has specifically objected to that in the Owner’s cover letter (as required under Section 9-7). The HUD/CA initial reviewer must follow up with the Owner or RCS appraiser, by email or other form of written correspondence, if:

  1. The Owner’s submission is incomplete. The RCS appraiser or the Owner must submit the missing items within 10 calendar days of the HUD/CA initial reviewer’s request. If the materials are not submitted, the renewal process is considered abandoned and the Owner must make a complete submission to initiate the process again. The Owner may request an extension to this deadline in writing, and HUD shall grant it for good cause.

  2. More than 90 calendar days elapsed between the RCS appraiser’s transmittal letter and the date the Owner first submitted the RCS to either HUD or the CA. Under this scenario, the HUD/CA initial reviewer must return the RCS and ask the Owner to have the RCS appraiser update the data to comply with Section 9-8.

• D. Recordkeeping. All categories of reviewers must retain the RCS submission, subsequent correspondence with the Owner, and all materials and documentation for 3 years from the date of the Owner’s RCS submission. This retention requirement applies equally to RCS materials that were deemed inadequate and/or incomplete.