9-7. PREPARING A RENT COMPARABILITY STUDY

An Owner who is required or decides to procure an RCS must ensure that the RCS:

• A. Is prepared by, or under, the direction of an RCS appraiser who meets the requirements set forth in paragraph 9-8.A.

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• B. Covers all unit types that receive Section 8 assistance in the contracts being renewed. The Owner may also include other Section 8 unit types in other contracts for which the Owner plans to request renewal within the next 5 years.

• C. Estimates comparable market rents for each Section 8 unit type by adjusting the rents of comparable units to reflect the location, condition, street appeal, amenities, and utilities of the Section 8 units. Note: The RCS appraiser must estimate market rent without considering the market’s ability to absorb all Section 8 units.

• D. Is concise but contains enough information that a person unfamiliar with the subject property and market area can understand how the RCS appraiser arrived at the adjustments and opinion of the subject property’s market rent. HUD provides a Sample RCS in Appendix 9-2-2.

• E. Is submitted to HUD/the CA no later than 120 days before the end of the 5-year life cycle of the RCS or contract renewal in cases where the contract is being terminated early and renewed.

  1. Not more than 90 calendar days may have elapsed between the date of the RCS and the date the Owner submits the RCS to HUD/the CA.

  2. Early submissions are allowed, but Owners must not submit more than 180 days before the end of the prior RCS’s five-year life cycle or early contract termination.

  3. For transactions involving an early termination and renewal, if more than 180 days will have elapsed between the date of submission and the termination date, the Owner must, not more than 180 days prior to the termination date, submit a letter from an appraiser updating the RCS and confirming that current rents are no lower than in the original study. If more than 18 months will have elapsed between the original submission and the termination date, then the Owner must submit a fully updated study.

• F. Includes a cover letter from the Owner and all materials listed in Appendix 9-2-1 ( Template for Owner’s Cover Letter & Owner’s Checklist ). To expedite HUD review, the Owner and RCS appraiser must ensure that all materials are submitted in electronic format in the same order as shown in the Owner’s Checklist .

• G. Complies with Standard 1 and Standard 2 of Uniform Standards of Professional Appraisal Practice (USPAP), which establish requirements for the development and reporting of a real property appraisal.

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