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9-8. APPRAISER QUALIFICATIONS

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

This section provides guidance to Owners and RCS appraisers regarding the required qualifications for an RCS appraiser. It also contains general instructions for preparing an RCS and identifies requirements that need to be followed.

  • A. In order to qualify, the RCS appraiser must:

    1. Be a Certified General Appraiser, licensed and in good standing in the state in which the project is located. The license may be temporary or permanent. (An Owner can obtain a list of RCS appraisers meeting this standard at www.asc.gov or from each state’s appraiser regulatory agency.)

    2. Be currently active and regularly engaged in performing Rent Comparability Studies or appraisals of multifamily housing and demonstrate continuing education relating to multifamily housing, market studies, or advanced market analysis and/or separating non–real property features within a property.

    3. Meet all the requirements of the current competency provision in USPAP and have read this Chapter and Appendices. (Additional or updated information on USPAP can be obtained at www.appraisalfoundation.org.)

    4. Have no prospective or present financial interest in the subject Section 8 project, its Ownership or management agent entity, or the principals of those entities.

    5. Not be an employee of the Owner, the management agent, or the principals of those entities or have a business or close personal/family relationship with those parties that would commonly be perceived to create bias or a conflict of interest.

    6. Not be debarred or suspended from doing business with the Federal Government and not be under a Limited Denial of Participation (LDP) imposed by the Regional Center or Satellite Office having jurisdiction over the subject Section 8 project.

    7. Be in compliance with all applicable civil rights laws and statutes and must not have a recent disciplinary citation or finding related to discrimination within the last three years.

  • B. In preparing the RCS, the RCS appraiser must:

    1. Sign and take full responsibility for the report. Appraisal assistants may contribute to any of the tasks if:

      • a. They are employed by the same firm as the RCS appraiser;

      • b. Are in compliance with all applicable civil rights laws and statutes and not found to have a recent disciplinary citation or finding related to discrimination within the last three years; and

      • c. The report identifies the tasks(s) the assistant RCS appraiser performed. There is no specific restriction on the tasks an assistant may perform with respect to the subject property or comparables.

Chapter Nine – Published March 2023

9

  1. Ensure compliance with this Chapter and its appendices, and with USPAP.

    • a. If this Chapter’s requirements go beyond USPAP, the RCS appraiser must consider the Chapter’s requirements to be supplemental standards and must comply with them.
  • b. The RCS appraiser must comply with the Fair Housing Act and must not use or rely on unsupported conclusions related to the comparable or subject properties or their surrounding areas or issue a valuation influenced because of any characteristic protected by the Fair Housing Act. RCS appraisers’ opinions, conclusions, and reports must be impartial and objective and must not illegally discriminate or contribute to illegal discrimination through subjective or stereotypical assumptions. The Fair Housing Act prohibits a person or entity engaged in the real estate appraisals business from discriminating because of race, color, religion, national origin, sex (including sexual orientation and gender identity), disability, or familial status.
  1. Collect, update, or verify all data within 90 calendar days before the date of the RCS appraiser’s letter transmitting the RCS to the Owner (or to HUD, when HUD purchases the study pursuant to Section 9-14). If more than 90 days will have passed between the date of data collection and transmittal of the RCS, the appraiser may verify or update that data to meet this requirement.

  2. Provide a descriptive analysis following the guidance provided in Sections 9-9 through 9-14 and the detailed instructions under Appendix 9-1. The RCS appraiser must download the electronic versions of Word or Excel files for any tables/grids in the RCS, as provided under Appendix 9-1.

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