Part B. Design, Location, Condition (lines 6 through 10)
HUD Section 8 Renewal Policy Guidebook · 2026 edition · updated 2026-07-29 · United States
This section allows for comparison of the comparable to the subject in terms of design, materials, condition, location, and appeal. The total adjustments in this section should not exceed the value a typical tenant would place on these characteristics in the aggregate.
Line 6. Structure/ Stories. The RCS appraiser must enter the type of structure using recognized codes such as “E” for Elevator, “G” for Garden, “WU” for other walk-up, and “T” for townhouse. The RCS appraiser can select other categories as dictated by market conditions, but must explain the significance of other categories and codes, if different from the recognized codes. For example, in some markets, renters in low-rise buildings may value apartments with private exterior entrances over a shared entry/or shared stairway, even if the units are stacked. In such cases, the RCS appraiser must identify the categories and codes used in the adjustments. Codes such as “WU-Pvt” (private entrance) or “WU-Shrd” (shared entrance) could be used.
The RCS appraiser must follow the letters with a slant bar and the number of stories. For example, the RCS appraiser should enter “WU/3” for a three-story walk-up. The RCS appraiser should try to select comparables that have the same structure type as the subject. If the comparables have a different configuration than the subject, adjustment may be warranted based on market preferences. For instance, the RCS appraiser may make an adjustment for configuration differences such as townhome versus a stacked unit. The RCS appraiser must explain the basis for any adjustment exceeding the larger of $10 or 2 percent of the comparable’s unadjusted rent.
Line 7. Year built/Year renovated. The RCS appraiser must enter the year the project was built. If it has been renovated, the RCS appraiser should follow with a slant bar and the year the project was renovated. For example, 1939/70 would indicate that the project was built in 1939 and renovated in 1970. The RCS appraiser must make adjustments on this line if the effective age (the age indicated by the utility, quality of the structure, and major equipment) affects rental value. The RCS appraiser must consider if basic structures and major equipment have been replaced and whether baths and kitchens have been renovated. Typically, the RCS appraiser should not make any adjustments for age differences of just a few years. When the RCS appraiser chooses to make an adjustment, the amount for each year of age difference should typically be less than $5 per year or 1 percent of the unadjusted rent. Alternatively, the RCS appraiser could make one adjustment for multiples of a fixed number of years of age difference. For example , each multiple of three years of age difference between the subject and the comparable would be assigned a certain dollar amount of adjustment.
6
Appendix 9-1-1 – Published March 2023
Line 8. Condition/Street Appeal. It is mandatory for the RCS appraiser to rate the subject and each comparable per a five-point scale: Excellent, Good, Average, Fair, or Poor. No other classifications are acceptable. For the subject, and every comparable, the RCS appraiser must enter “E” for excellent, “G” for good, “A” for average, “F” for fair, or “P” for poor. If the design of the building or the street appeal of the project would affect the rents it can command, the RCS appraiser must adjust appropriately. The RCS appraiser should consider the overall appearance of the project, such as whether the grounds are clean, whether the landscaping is well maintained, and whether or not the paint and siding are in good condition. Other considerations would be whether the architecture of the buildings and layout of the site are appealing (open space, shrubbery, etc.). In summary, the RCS appraiser must evaluate whether the comparable’s condition/street appeal could cause tenants to pay more or less than they would pay at the subject.
An adjustment of more than the larger of $20 or 4 percent of unadjusted rent for each level of rating difference would require that the RCS appraiser provide specific explanation in the narrative to support the amount of adjustment. Example: a positive adjustment for an “Average” rated comparable versus an “Excellent” rated subject, should not exceed $40, or 8 percent of the unadjusted comparable rent, whichever is larger.
Due to the potential for overlap between adjustment parameters, if the RCS appraiser has made an adjustment on Line 7 for Year Built/Renovated for a comparable, the RCS appraiser must explain if the adjustment exceeds $15 or 3 percent of unadjusted rent, whichever is larger, for each level of rating difference for Line 8 for that same comparable.
Note: Take care not to duplicate adjustments made on line 7. Adjustments made on lines 7 and 8 should not add to more than the adjustment that would be made if the project characteristics referenced on Lines 7 and 8 were considered as a single adjustment.
Line 9. Neighborhood. The RCS appraiser must rate the subject and each comparable according to a five-point scale: Excellent, Good, Average, Fair, or Poor. No other classifications are acceptable. For the subject, and every comparable, the RCS appraiser must enter “E” for excellent, “G” for good, “A” for average, “F” for fair, or “P” for poor. The entry should reflect the market’s reaction to location features that affect rental values. For example, neighborhood desirability; nuisances such as street noise; nearby land uses; crime volume; and access (time/distance) to schools, transportation, shopping, recreation, and medical and employment centers. The Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA) specifically requires that neighborhood (including risk of crime), location and access be considered.
s. For example, neighborhood desirability; nuisances such as street noise; nearby land uses; crime volume; and access (time/distance) to schools, transportation, shopping, recreation, and medical and employment centers. The Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA) specifically requires that neighborhood (including risk of crime), location and access be considered.
An adjustment of more than $20 or 4 percent of unadjusted rent, whichever is larger, for each level of rating difference would require that the RCS appraiser provide specific explanation in the narrative to support the amount of adjustment. For example , a positive adjustment for an “Average” rated comparable versus an “Excellent” rated subject, should not exceed $40, or 8 percent of the unadjusted comparable rate, whichever is larger.
Appendix 9-1-1 – Published March 2023
7
The RCS appraiser must note that the Fair Housing Act prohibits appraisers from discriminating in appraisals, such as making adjustments because of the race, color, religion, sex (including sexual orientation and gender identity), disability, familial status, or national origin of the residents of projects or the surrounding areas. RCS appraiser’s adjustments must be based on objective, quantifiable, and nondiscriminatory factors.
Line 10. Same Market? Miles to Subject? The RCS appraiser must enter “Y” or “N”, depending on whether the comparable is in the same market area as the subject. The RCS appraiser must follow the entry with a slant bar, and the distance between the comparable and the subject in miles. If the comparable is in a different market area, the RCS appraiser must collect quantitative data to compare the rent levels in the two market areas. The RCS appraiser must adjust for any significant difference in rental costs between the two market areas and explain how he/she computed the adjustment. If the comparable is in a different market area and the RCS appraiser chooses to not adjust it for the different market location, the RCS appraiser must explain why .
Get a plain-English answer with a citation back to this text.
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