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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.

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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

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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 .

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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

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