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Comparable Project Profile

Special Project Types

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

If the RCS appraiser uses comparables from project categories that would not typically be suitable for use as comparables for multifamily rental housing, as outlined under Section 910. C.4, the RCS appraiser must consult the guidance provided below.

  • A. Cooperative Project (Co-Op): A Co-Op is a multi-unit project in which those who own the project actually own shares in the Ownership of the overall project as a whole. For the purposes of an RCS, the fact that the project is a co-op doesn’t significantly affect the market rental rate of the subject and/or the comparable project. Depending on the market evaluation that is performed by the RCS appraiser, an adjustment may be justified for the Ownership being a co-op but most likely it will have no effect on the concluded market rental rate.

  • B. Elderly/Disabled: Housing designated for elderly families or families that include an individual with a disability are different from traditional market rate projects because these projects typically include services offered at no extra cost to the tenant. The mix of these services will vary widely among projects in each market as well as between different markets. Upon identification of housing designated for elderly families or families that include an individual with a disability, the RCS appraiser should determine what extra services are provided (and how they are funded) and during the comparable selection process attempt to identify projects that offer similar services with the same restrictions as well as being in the defined market area. The preference in selection would be to go outside the market area and find comparable projects offering the same or similar services, rather than locating projects within the defined market areas but offering different services. If the property designated for elderly families or families that include an individual with a disability project doesn’t offer any services above and beyond a normal market rate project, then no adjustments would be required and the comparable selection could utilize traditional market rate projects for comparison. However, an adjustment would most likely be required due to the restriction of the tenant pool as compared to a traditional market rate project.

  • C. Student Housing: Included as a Special Project due primarily to the growth of these projects, and the “by the bed” rental structure that they often offer. There are two types of projects that fall under the Student Housing category; (1) traditional apartment projects that are rented by the unit, but are restricted to students and (2) “by the bed” projects.

  • D. The first project type is one that is similar in operations and rentals to the traditional apartment project, and specifically similar to an elderly or age-restricted project. The tenant rents a studio or larger unit, containing a kitchen, bath, and sleeping quarters.

The second project type is one that has become very popular over the last 10-20 years and that is a project that rents beds, rather than apartment units. Accordingly, there will be two or more tenants sharing a living unit. This concept is similar to a college dorm concept mixed with a traditional apartment project. Commonly, these projects will also offer services that cater to students and student-living and will be located on and very close to campus. As an RCS will in all cases involve estimating market rents for self-

Appendix 9-4 – Published March 2023

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contained living units rather than bed rentals within shared apartment units, this second project type cannot under any circumstance be used as a rental comparable for the RCS.

  • E. Congregate-Care Projects: Included as a Special Project Type due to the amount of extended services available, and the “by the bed” rental structure that they sometimes offer. There are several types of projects that fall under Congregate-Care Housing but all offer some level of home health care services to either the elderly or persons with special needs. The different types could include (1) Assisted-living facilities, (2) senior citizen housing, or (3) other age-restricted retirement communities. Congregate-care housing typically offers enhanced healthcare services for the elderly, whereas the typical elderly housing projects offer only limited services with no specific healthcare applications.

For some care facilities, residents lease a bed rather than a private unit. Typically, that kind of facility will offer skilled nursing, and will require payment on a daily rather than monthly basis. The RCS appraiser will not encounter this type of facility for purposes of estimating rent for a Section 8 project. Accordingly, there is no reason to use projects rented on a daily rather than monthly basis as rental comparables. As an RCS will, in all cases, involve estimating market rents for self-contained living units rented on a monthly basis, rather than daily bed rentals, this project type cannot under any circumstance be used as a rental comparable for the RCS.

  • F. After-Rehabilitation: Included as a Special Property Type due to the hypothetical assumption that the proposed renovation has been completed. This requires a dual review of the subject project in its “as is” state, and a “projected” review as though all units and common areas that will be renovated have already been renovated, in accordance with the specifications provided in the renovation scope of work. This then requires the RCS appraiser to include comparables similar to the subject project in its post-renovation condition.

pleted. This requires a dual review of the subject project in its “as is” state, and a “projected” review as though all units and common areas that will be renovated have already been renovated, in accordance with the specifications provided in the renovation scope of work. This then requires the RCS appraiser to include comparables similar to the subject project in its post-renovation condition.

The RCS appraiser should review what if, any repairs are proposed for the subject project. Proposed changes to the subject project other than routine repairs for deferred maintenance may need to be reflected in Form 92273-S8 adjustments to rental comparables. Examples of adjustments that may need to be reflected in the RCS appraiser’s Form 92273-S8 analysis would include changes in utility configuration, such as installing separate living unit meters that effectively convert an Owner-paid utility service to a tenant-paid basis. Another example of possible adjustments would be additions or reductions in the scope of non-shelter services, such as would occur if management were proposing to eliminate an on-site day care facility or other amenity. Even if no specific change is proposed to utility configuration, available amenities, or available non-shelter services, the subject project’s overall condition and appeal may be enhanced by the proposed scope of work. Accordingly, the RCS appraiser needs to consider how adjustments for line items 7 and 8 of the form 92273-S8 (Year built/Yr. Renovated and Condition/Street Appeal) will be affected.

Appendix 9-4 – Published March 2023

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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
    Overview
    1. Address
    2. Place Photo Below:
    3. By my/our signature below, I/We certify that, to the best of m…
    4. Sample RCS Appraiser’s Transmittal Letter
    5. Re: Rent Comparability Study/[Project Name]
    6. Mandatory Market Rent Threshold Test
    7. Sample Owner’s Cover Letter
    8. RCS Submittal Cover Letter for [Project Name]
    9. Owner’s Materials
    10. RCS Materials
    11. Mandatory Market Rent Threshold Materials
    12. Owner’s Signature & Date
    13. Notes for Rent Grid Analysis and Triggers for Secondary Review
    14. Sample Issues Memo from Substantive Reviewer
    15. Special Project Types
    16. Forms Used in Preparation and Review of an RCS
    17. Chapter Ten
    18. Residual Recei pts
    19. Chapter Eleven
    20. 11-1. DEFINITIONS
    21. 11-2. HOUSING CONVERSION ACTIONS
    22. 11-3. TENANT PROTECTIONS
    23. 11-4. OWNER NOTIFICATION REQUIREMENTS
    24. Note: The one-year notification is not required when an owner …
    25. Note: Taping the Notice to the outside of each unit is not acc…
    26. 11-5. LIMITED ENGLISH PROFICIENCY ASSISTANCE
    27. 11-6. EFFECTIVE COMMUNICATIONS
    28. ( Date )
    29. THIS LETTER IS TO NOTIFY YOU THAT WE DO NOT INTEND TO RENEW TH…
    30. HUD Web
    31. ( Date )
    32. THIS LETTER IS TO NOTIFY YOU THAT WE INTEND TO RENEW THE CURRE…
    33. HUD Web
    34. ( Date )
    35. HUD Web
    36. Chapter Twelve
    37. 12-1. PHYSICAL CONDITION
    38. 12-2. EXIGENT HEALTH AND SAFETY (EH&S) DEFICIENCY NOTICE AND P…
    39. Note: hud@work is an internal site with no access for the publ…
    40. Chapter Thirteen
    41. 13-1. HUD’S REFUSAL TO RENEW A SECTION 8 HAP CONTRACT
    42. 13-2. HUD’S DECISION NOT TO RENEW THE EXPIRING CONTRACT
    43. 13-3. OWNER’S APPEAL OF HUD’S REFUSAL TO RENEW A SECTION 8 HAP…
    44. 13-4. HUD’S TENANT NOTIFICATION OF REFUSAL TO RENEW
    45. Chapter Fourteen
    46. 14-1. OVERVIEW
    47. 14-2. PROCESSING
    48. Note: HUD does not accept the RHS utility analysis. The owner …
    49. Note: If the owner of the project is a for profit who is not r…
    50. Note: RHS projects are exempted from debt restructuring under …
    51. Chapter Fifteen
    52. Section 8 Preservation Efforts
    53. 15-1. OVERVIEW
    54. PART ONE: DEFINITION OF NONPROFIT OWNER
    55. 15-2. NONPROFIT OWNER/PURCHASER
    56. 15-3. NONPROFIT CONTROLLED FOR PROFIT ENTITY (OWNER OR PURCHAS…
    57. PART TWO: GENERAL CRITERIA FOR BOTH CAPITAL REPAIRS AND TRANSF…
    58. 15-4. APPLICABILITY
    59. 15-5. BASIC REQUIREMENTS
    60. Note: HUD lacks the authority to allow a project to reduce ren…
    61. 15-6. RENT INCREASES
    62. 15-7. UNASSISTED UNITS IN A HUD PROJECT
    63. 15-8. CAP ON MARKET RENTS
    64. 15-9. PROJECT CAPITAL NEEDS ASSESSMENT AND INCREASED DEPOSITS …
    65. Note: For a non-insured project with an old regulation/LMSA/PD…
    66. PART THREE: CAPITAL REPAIRS PROGRAM
    67. 15-11. GENERAL
    68. 15-12. ADDITIONAL ACCEPTABILITY REQUIREMENTS FOR THE OWNER
    69. 15-13. PROJECT ELIGIBILITY
    70. Part Four: Transfer Program
    71. 15-14. GENERAL
    72. 15-15. ADDITIONAL PURCHASER REQUIREMENTS
    73. 15-16. PROJECT ELIGIBILITY
    74. 15-17. TRANSFER OF PHYSICAL ASSETS (TPA) FOR A HUD INSURED TRA…
    75. Chapter Sixteen
    76. 16-1. BACKGROUND, APPLICABILITY AND OVERVIEW
    77. 16-2. OWNER OPTIONS
    78. 16-3. TIMELINESS
    79. Rent Comparability Study (RCS) . See Comparability Study.

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