9-17. COMMUNICATING RESULTS OF HUD/CA REVIEWS
HUD Section 8 Renewal Policy Guidebook · 2026 edition · updated 2026-07-29 · United States
The HUD/CA must convey the results of the substantive review of the Owner’s RCS to the Owner within 30 calendar days after receiving a complete RCS package from the Owner.
A. Approval. If the HUD/ CA substantive reviewer agrees with the RCS appraiser’s market rent conclusions, they must document that agreement on the reviewer’s certification (Appendix 9-5-5) and notify the HUD AE/CA that the market rents in the RCS are acceptable for use in further processing of the renewal.
B. Questions and/or Clarifications. If aspects of the RCS are unclear or unsupported, the HUD/CA substantive reviewer must ask the RCS appraiser for additional information or explanation, if the Owner’s cover letter permits the HUD/CA reviewer to reach the RCS appraiser directly. If the issues have a minimal effect on valuation and the HUD/CA reviewer expects easy resolution, the substantive reviewer may call the RCS appraiser. If concerns are many, more significant, or complicated, the HUD/CA reviewer must send the RCS appraiser an email/fax/hard copy of a letter stating the concerns highlighted in the Reviewer’s Issues Memo (sample provided in Appendix 9-5-6) and give the RCS appraiser up to 10 calendar days to respond. (The HUD/CA reviewer must copy the
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Owner on any written correspondence.) The RCS appraiser must send the requested information to the HUD/CA reviewer and copy the Owner.
Within 10 calendar days after final information was due from the Owner or RCS appraiser, the HUD/CA reviewer must either: accept the study and proceed as described in Section 9-17.A, above; submit a request for additional information or clarification from the RCS appraiser, which will be evaluated pursuant to this paragraph; or draft a Decision Letter to the Owner.
C. Decision Letter. If the RCS appraiser’s response does not resolve the substantive reviewer’s concerns, the substantive reviewer will draft a Decision Letter challenging the RCS. If the substantive reviewer is a non-appraiser, an RCS review appraiser must also be engaged to review the subject’s RCS prior to issuance of such a letter. If the RCS review appraiser also concludes that the rejection is warranted, then the substantive reviewer may issue the Decision Letter that either tells the Owner the study must be redone and resubmitted or challenges the study’s rent conclusions and suggests an alternate rent. Any alternate rents must be developed by a RCS review appraiser and be consistent with this Chapter’s procedures and USPAP. The Decision Letter must tell the Owner how the RCS review appraiser arrived at the suggested market rent. The Decision Letter must also:
Be signed by the Regional Office Director or designee;
Clearly state the reasons the RCS is challenged or that alternate rents are offered;
List the Owner’s options; and
Provide a firm deadline for the Owner to respond.
- D. Owner’s Response. The Owner has 10 calendar days after the date of the Decision Letter to advise HUD in writing of their choice to accept HUD’s alternate rents, submit a new study, or appeal HUD’s decision.
If the Owner chooses to appeal or resubmit their RCS, HUD/CA may, upon the Owner’s request, prepare a short-term renewal at the then-current rents to allow time for processing the appeal. Any rent increases because of the appeal will be retroactive to the date of execution of the short-term renewal contract. Submission of a new study restarts the processing timeline. If the Owner chooses to appeal, the Owner may submit one revised version of the study with the materials supporting the appeal. Further revisions of the study will not be considered.
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Ask AI about this code▸ Contents — HUD Section 8 Renewal Policy Guidebook
- U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
- SPECIAL ATTENTION OF
- TRANSMITTAL
- A. Purpose
- Explanation of Changes
- Section 8 Renewal Policy Guidebook
- Office of Multifamily Housing
- Table of Contents
- Chapter One
- Introduction
- Chapter 1: Introduction
- Chapter 2: Section 8 Renewals
- Chapter 3: Option One: Mark-Up-To-Market
- Chapter 4: Option Two: Contract Renewals For Other Projects wi…
- Chapter 5: Option Three: Referral to Recap
- Chapter 6: Option Four: Renewal of Projects Exempt from or not…
- Chapter 7: Option Five: Renewal of Portfolio Reengineering Dem…
- Chapter 8: Option Six: Opt-Outs
- Chapter 9: Rent Comparability Studies
- Chapter 10: Residual Receipts
- Chapter 11: Tenant Issues
- Chapter 12: Physical Condition of the Project
- Chapter 13: HUD’s Refusal to Renew Section 8 Contracts
- Chapter 14: Rural Housing Service (RHS) Section 515/8
- Chapter 15: Section 8 Preservation Efforts
- — Chapter 16: “Old Regulation” State Housing Finance Agency Pr…
- 1-2. LEGISLATIVE HISTORY
- 1-3. RULEMAKING
- 1-4. ADMINISTRATIVE POLICY
- 1-5. APPLICABILITY
- 1-6. PAPERWORK REDUCTION ACT
- Chapter Two
- Section 8 Renewals
- 2-1. INTRODUCTION
- 2-2. OWNER OPTIONS
- 2-3. TYPES OF RENEWALS
- 2-4. EARLY TERMINATION OF A CONTRACT
- 2-5. RENT COMPARABILITY STUDY (RCS)
- Note: The AE/CA shall not lower the comparable market rents in…
- Note: A RCS is not required at any subsequent renewal of an EL…
- 2-6. CONTRACTS
- 2-8. SHORT-TERM CONTRACT RENEWALS
- 2-10. COMBINING CONTRACTS
- 2-11. REQUEST FOR A CONTRACT EXTENSION
- 2-12. DISTRIBUTIONS
- Note: The conditions listed above for receiving access to incr…
- 2-13. RENT ADJUSTMENTS
- 2-14. OPERATING COST ADJUSTMENT FACTOR (OCAF)
- 2-15. BUDGET-BASED RENT ADJUSTMENT REQUESTS
- 2-16. INCREASES IN DEPOSITS TO THE RESERVE FOR REPLACEMENT
- 2-17. PROCESSING INSTRUCTIONS
- Note: If the project has a budget approved by the AE/CA less t…
- Note: HUD does not accept the RHS utility analysis. The owner …
- 2-18. WAIVERS
- 2-19. DUNS NUMBER
- Chapter Three
- 3-1. OVERVIEW
- 3-3. OPTION ONE-A ENTITLEMENT MARK-UP-TO-MARKET ELIGIBILITY
- Note: Nonprofit controlled for profit entities as described in…
- 3-4. 150 PERCENT RENT CAP FOR OPTION ONE-A
- 3-5. EXCEEDING THE 150 PERCENT OF FMR CAP
- 3-6. OPTION ONE-B DISCRETIONARY MUTM ELIGIBILITY
- Note: Non-profit owned projects that meet one of the three cri…
- 3-7. RENEWAL REQUESTS
- 3-8. PROCESSING INSTRUCTIONS
- 3-9. ANNUAL RENT ADJUSTMENTS DURING A MULTIYEAR CONTRACT
- Chapter Four
- 4-1. ELIGIBILITY
- Note: Projects currently renewed under either Option Two or Op…
- 4-2. CONTRACT RENEWAL
- 4-3. ANNUAL RENT ADJUSTMENTS DURING A MULTIYEAR CONTRACT
- 4-4. PROCESSING INSTRUCTIONS
- Chapter Five
- Note: WAIVERS TO CHAPTER FIVE WILL BE IN ACCORDANCE WITH RECAP…
- Note: Risk Sharing Projects do not meet the definition of “eli…
- 5-2. BINDING COMMITMENT
- 5-3. ENTRY INTO RECAP
- Note: In cases where a CA makes the determination that contrac…
- 5-4. CONTRACT RENEWALS — RENT OR DEBT RESTRUCTURING
- 5-5. SUBSEQUENT RENEWALS
- 5-6. “WATCH LIST” MTM PROJECTS
- 5-7. GENERAL INFORMATION
- Chapter Six
- 6-1. ELIGIBILITY
- Note: State and local government financed projects that are no…
- Note: In cases where referral to Recap is necessary, CAs must …
- Note: Section 202 and 811 Capital Advance projects are not eli…
- Note: Projects financed under the risk-sharing loan programs u…
- 6-2. RENEWALS
- Reminder: For projects (including 202 projects) that are being…
- 6-3. RENT ADJUSTMENTS FOR MULTI-YEAR CONTRACTS
- 6-4. SECTION 202 REFINANCINGS
- Chapter Seven
- 7-1. ELIGIBILITY
- Portfolio Reengineering Demonstration Program Projects
- 7-2. RENEWAL OF PORTFOLIO REENGINEERING DEMONSTRATION PROJECTS
- FIVE
- Note: Owners can request that the existing Demo Program Use Ag…
- 7-4. PROCESSING INSTRUCTIONS FOR DEMONSTRATION PROJECTS
- 7-5. PRESERVATION PROJECTS (LIHPRHA AND ELIHPA)
- 7-6. OWNER’S SUBMISSION FOR PRESERVATION PROJECTS
- Note: Owners can request that the existing Preservation Use Ag…
- 7-7. PROCESSING INSTRUCTIONS FOR PRESERVATION PROJECTS
- 7-8. PROJECT SPECIFIC RENTS (PSRS)
- Chapter Eight
- 8-1. OVERVIEW
- 8-2. OWNER REQUIREMENTS FOR TENANT NOTIFICATION
- 8-3. PROCESSING INSTRUCTIONS
- Note: If proper notification was not provided, the owner must …
- Chapter Nine
- 9-1. BACKGROUND
- 9-2. APPLICABILITY OF CHAPTER NINE
- 9-3. ROAD MAP TO CHAPTER NINE
- 9-4. ALTERNATIVES TO RENT COMPARABILITY STUDY
- 9-6. METHOD TWO: COMPARING PROPOSED SECTION 8 RENTS WITH RENTS…
- 9-7. PREPARING A RENT COMPARABILITY STUDY
- 9-8. APPRAISER QUALIFICATIONS
- 9-9. ANALYZING THE SUBJECT PROJECT
- Note: Appraisers should not take into consideration demographi…
- Note: Government boundaries like state or county lines often d…
- 9-10. SELECTING COMPARABLE UNITS
- 9-11. COLLECTING AND DOCUMENTING DATA ON COMPARABLE UNITS
- 9-12. COMPUTING ADJUSTED RENTS FOR COMPARABLE UNITS
- 9-13. DERIVING ESTIMATED MARKET RENTS
- 9-14. PROCEDURE FOR MANDATORY MARKET RENT THRESHOLD
- Example Project in ZIP code 76469
- 9-15. HUD REVIEW OF RENT COMPARABILITY STUDY
- 9-16. INITIAL AND SUBSTANTIVE REVIEW OF OWNER’S RCS
- 9-17. COMMUNICATING RESULTS OF HUD/CA REVIEWS
- 9-18. OWNER APPEALS
- 9-19. IMPOSING SANCTIONS ON APPRAISERS
- APPENDICES
- - Instructions for Completing the HUD Form 92273 S8
- Part A: Rents Charged (lines 1 through 5)
- Part B. Design, Location, Condition (lines 6 through 10)
- Part C. Unit Equipment/Amenities (lines 11 through 23)
- Part D. Site Equipment/Amenities (lines 24 through 32)
- Part E. Utilities (lines 33 through 39)
- Part F. Adjustments Recap (lines 40 through 43)
- Part G. Adjusted Rents (lines 44 through 45)
- Required Contents of a Rent Comparability Study
- Comparable Project Profile