NOTE: The following summary of Section 504 applies to any housing that has ever…

• B. Summary of Section 504 of the Rehabilitation Act of 1973 and 24 CFR Part 8 - Uniform Federal Accessibility Standards (UFAS) Requirements or the Deeming Notice (See Appendix 5, Section A.5.2):

Any property built with assistance, or became assisted prior to July 11, 1988 has been obligated since such time to bring the property into compliance with UFAS or the Deeming Notice requirements (including 5% of total units as mobility accessible and 2% of total units as sensory accessible units) through any replacements and alterations that took place over time, unless particular elements of compliance required alteration of a load-bearing wall or would have caused an undue financial and administrative burden (see 24 CFR 8.23).

In the decades since 1988 significant compliance should have been achieved. Some existing properties may have become assisted after 1988 and compliance should, (but may not), have been achieved at the time of assistance and these properties also must make all replacements and alterations conform so as to achieve compliance over time as well as addressing the needs of disabled tenants. No assisted property is exempt. All must either be in compliance or must be progressing toward compliance subject only to forbearance for particular items of non-compliance by reason of the “load bearing wall” and the “undue financial and administrative burden” exemptions.

C. If processing direct to Firm Commitment Application, include Appendix 5, Section A.5.6.1 (Section A.5.6.1.B.2 and Section A.5.6.1.B.3.

• D. Summary of HUD Architectural Review:

1. Architectural/Engineering exhibits, per Appendix 5, Section A.5.4.2. If incomplete or unacceptable, specify and indicate reasons.

2. Review of Physical Conditions and Scope of Work.

Physical conditions:

• 1. Condition of project and assessed RUL of components justified; photography supports assessment, level of investigation consistent with age, type of construction and condition of the buildings.
• 2. If Seismic risk thresholds are exceeded and a seismic analysis and report are required per Appendix 5, Section A.5.3, recommended retrofits have been included in scope of work.

Rehabilitation Scope of Work:

• 1. Proposed rehabilitation work as described in Scope of Work Summary address identified deficiencies, repair needs, obsolescence and other improvement needs consistent with Joint Inspection Report and other due diligence reports.
• 2. Plans and specs describe all the proposed work, consistent with Scope of Work Summary and in compliance with Appendix 5, Section A.5.5.
• 3. Expected future repair, replacement, and major maintenance needs account for proposed rehabilitation as well as assessed condition of all other capital items not repaired or replaced as part of the rehabilitation.

If not acceptable, indicate reasons.

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Appendix 5 Architectural and Construction Analysis A.5.6 HUD Architectural Review Report Format

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3. Architectural Analysis and Review Reports by Lender’s Construction Analyst (per Chapter 5, Section 5.7.3.A.16).

   • Site design and conditions.

• Building and building systems design.

Design features unusual for the particular structure type and/or system.

• Accessibility:

  • 1. Any noncompliance with Fair Housing Act Design and Construction requirements?
  • 2. Any noncompliance with UFAS or the Deeming Notice for assisted housing?
  • 3. Any noncompliance with Title III of the ADA?

If not acceptable, indicate reasons.

4. CNA e-Tool data entries.

Complies with the requirements in Chapter 5, Section 5.7.3.A.11.

Complies with the requirements in Chapter 5, Section 5.9.3.A.4 and Section 5.9.3.A.6.

• Review of Architecture and Engineering (A/E) portion of Lender’s completed form HUD-92264 and the CNA e-Tool entries for accuracy with respect to property characteristics and other A/E related exhibits.

• Physical inventory (e.g., sites, buildings, units, components and replacement alternatives) consistent with the Architect’s plans and specs.

• Estimate of replacement costs (form HUD-92329, Schedule of Insurable Values).

• Financial plan for funding future capital replacement needs, per Appendix 5, Section A.5.7. Future replacements are consistent with owners proposed distinctions between capital items and operating expense.

If not acceptable, indicate reasons.

5. Review of Construction Contracts.

   • AIA B108 and Amendments and Project Architect’s certification, per Chapter 5, Section 5.2.3.

• Owner Contractor Agreement, Supplementary Conditions, Construction Contract, per Chapter 5, Section 5.5.

• Identities of interest disclosed and acceptable.

If not acceptable, indicate reasons.

6. Energy related requirements per Chapter 6. If not acceptable, indicate reasons.

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Appendix 5 Architectural and Construction Analysis A.5.6 HUD Architectural Review Report Format

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E. I have reviewed the subject project and hereby make the following recommendation(s):

Reviewer:

Name of Reviewer: Signature and Date of Review:

Concurrence: Name of Team Leader: Signature and Date of Concurrence:

Date:

Date: