Part A: Rents Charged (lines 1 through 5)
HUD Section 8 Renewal Policy Guidebook · 2026 edition · updated 2026-07-29 · United States
Before the rents for comparable units can be adjusted for differences from the subject, they must be adjusted for conditions at the comparable project itself. This section makes adjustments that are primarily internal to each individual comparable and produces an effective rent. Subsequent sections adjust each comparable’s effective rent by comparing the comparable to the subject project.
Line 1. $ Last Rent/Restricted? In the “data” column, the RCS appraiser must enter the rent at which this unit type was last leased. This must be a rent that was actually paid; the RCS appraiser must not enter an asking rent which has not yet been achieved. In the adjustments column, the RCS appraiser must enter “Y” if the unit is rent restricted and “N” if it is not. Rent restricted units include those that are subject to rent control, rent stabilization or other restrictions on the unit rent. (e.g., LIHTC, HOME, HOPE VI, and 236/BMIR/Rural Development Section 515 units). The RCS appraiser must identify the specific reason for a yes answer in the narrative explanation of adjustments. Using a comparable from an affordable/restricted project should be only a “last resort,” as adjustments that would need to be made to line items 2 through 39 for a restricted comparable are inherently subjective. However, rent restricted units could be used as comparables when they reasonably represent market rents. Units in market areas with rent control may reasonably represent a market if they were leased recently, and should not be excluded solely on the basis of the rent control. Using a comparable from other categories of project types, such as independent or assisted living facilities or masterplanned retirement communities, for an age-restricted Section 8 project, may be difficult to justify because tenants at those types of projects choose them over conventional apartment projects due to the non-shelter services offered at such facilities. In particular, a comparable property that offers a daily meal or meals included in the monthly rent poses specific challenges with regard to determining appropriate rent adjustments.
Line 2. Date Last Leased. In the data column, the RCS appraiser must enter the date (month/ year) that unit type was most recently leased. This should be the date the most recent lease for the rent on Line 1 became effective. The RCS appraiser should make an adjustment here only if the rental market has changed significantly between the date on this line and the date of the RCS appraiser’s analysis. Adjustments here should be infrequent, as the RCS appraiser should be using only recent lease transactions to begin with. This adjustment may be needed when the comparable is at full occupancy and has had no turnover for an extended period. If market conditions have not changed, the RCS
Appendix 9-1-1 – Published March 2023
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appraiser should not adjust even if considerable time has elapsed since Line 1’s rent became effective.
Line 3. Rent Concessions. The RCS appraiser should evaluate if the comparable is offering initial rent or renewal concessions. The RCS appraiser must enter “Y’ or “N”, and may enter a negative adjustment to reflect the value of the concession, as appropriate. The RCS appraiser must prorate the concession over the lease period. For example, the RCS appraiser would make a ($33) adjustment for one month free on a 12-month lease (requiring 11 monthly rent payments), at $400 /month. If the free month is instead offered as an add-on before or after 12 months of payments, the adjustment in this example would be less ($31).
Line 4. Occupancy percent for Unit Type. The RCS appraiser must consider only the unit type represented by the comparable. The RCS appraiser should enter the approximate percent of units in that type that are occupied as of the data collection date. The RCS appraiser must not enter occupancy for all unit types at the comparable. If the comparable’s occupancy rate for the unit type under consideration is not typical of the comparable’s market, the RCS appraiser must determine if the occupancy differential is due to the rent being set too high/ too low, or due to other factors.
If the occupancy gap is due to factors other than Line 1’s rent level (e.g. condition or location), the RCS appraiser must not make an adjustment. The RCS appraiser should adjust only if the occupancy gap is clearly due to the rent level used on Line 1. If the comparable’s occupancy for the unit type being studied is significantly lower than the typical occupancy rate for that unit type, the RCS appraiser should adjust negatively to indicate that the rent is too high. If the comparable’s occupancy for the unit type being studied is significantly higher than the typical occupancy rate for that unit type, the RCS appraiser should make a positive adjustment.
If the property manager/other contact for a comparable is unwilling or unable to provide occupancy rates by unit type, the RCS appraiser should report overall occupancy for the comparable and note in the explanation for Line Item #4 that the occupancy rate is project-wide. If only overall occupancy is reported, an occupancy adjustment may be made only if the unit mix is such that the RCS appraiser can still conclude that the occupancy for the unit type is significantly different than market occupancy levels for that unit type. Example: If a project has 99 percent occupancy and 100 units (50 one-bedrooms, 50 two-bedrooms), it could still be concluded that the two-bedroom units being studied are at least 98 percent occupied. The RCS appraiser must explain how he/she arrived at that conclusion.
still conclude that the occupancy for the unit type is significantly different than market occupancy levels for that unit type. Example: If a project has 99 percent occupancy and 100 units (50 one-bedrooms, 50 two-bedrooms), it could still be concluded that the two-bedroom units being studied are at least 98 percent occupied. The RCS appraiser must explain how he/she arrived at that conclusion.
- The occupancy adjustment is subjective, and thus it is not expected to be frequently used. Often, unusually low occupancy may have other explanations. For example, a low occupancy project may still be in initial absorption, or may be re-absorbing after a renovation or other unusual event. Conversely, an unusually high occupancy rate may be due to factors such as a high proportion of long-term tenants at below-market rates or the presence of Section 8 voucher tenants, even if new rental transactions there are being done at market rates. The use of an occupancy adjustment should thus be reserved for the specific situation where
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Appendix 9-1-1 – Published March 2023
management is marketing units consistently at unusually low or high rental rates over a sustained period of time as a matter of policy, with measurable impacts on project occupancy.
Line 5. Effective Rent and Rent/Sq. Ft. The RCS appraiser must enter the sum of lines 2, 3, and 4. This yields an effective rent after age of the lease, occupancy, and rental concessions are taken into account. Excel-based Rent Comparability Grids will automatically calculate the total rent. After the RCS appraiser enters the unit size in Part C, the form will also display the effective rent per square foot.
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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