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9-3. ROAD MAP TO CHAPTER NINE

HUD Section 8 Renewal Policy Guidebook · 2026 edition · updated 2026-09-23 · United States

The table below provides a road map to Owners, RCS appraisers, and reviewers (both initial and substantive reviewers). Besides focusing on the relevant Sections and Appendices highlighted in the table below, HUD recommends that all preparers and users of Rent Comparability Studies review the entire Chapter Nine and its Appendices to ensure compliance with all requirements for the respective Section 8 contract renewal.

Chapter Nine – Published March 2023

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Sections Topic Primary Stakeholder(s) Primary Stakeholder(s) Primary Stakeholder(s)
Owner RCS
Appraiser
RCS
Reviewer*
9-1 - 9-3 Background, Applicability, and
Roadmap to Chapter Nine
✓ ✓ ✓
9-4 - 9-6 Alternatives to RCS (Using SAFMR or
Using Non-Section 8 Units)
✓ ✓
9-7 Preparing an RCS ✓ ✓
9-8 Appraiser’s Qualifications ✓ ✓
9-9 - 9-13 Analyzing the Subject Project
Selecting Comparable Units
Collecting and Documenting Data on
Comparable Units
Computing Adjusted Rents for
Comparable Units
Deriving Estimated Market Rents
✓
9-14 Procedure for Mandatory Market Rent
Threshold
✓ ✓ ✓
9-15 - 9-16 HUD Reviews of RCS
Initial and Substantive Review
✓
9-17 - 9-18 Communicating Results of HUD/CA
Reviews
Owner Appeals
✓ ✓
9-19 Imposing Sanctions on Appraisers ✓
Appendix Topic Owner RCS
Appraiser
RCS
Reviewer*
9-1 Guidance to RCS Appraisers ✓
9-2 Guidance to Owners ✓
9-3 Guidance to Reviewers ✓ ✓
9-4 Forms Used in Preparation and Review
of an RCS
✓ ✓ ✓

*Reviewer includes initial reviewer and substantive reviewer as defined in Section 9-16

Chapter Nine – Published March 2023

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