Note: HUD does not accept the RHS utility analysis. The owner must submit a utility…

B. RHS agreed in November 2010, that any budget based rent adjustment request submitted at the time of the amend rents calculation cannot result in rents above market as determined by the RCS. If the rents resulting from the budget based rent adjustment submission result in a “0” increase or do not exceed the rents that would result from the application of the OCAF, the owner does not need to submit a Rent Comparability Study to show that the rents are below market.

C. AE/CA will accept RHS-approved budgets reflecting the appropriate 8 percent allowable owner’s distribution on equity or any higher level as approved by RHS as an incentive to the owner to prevent prepayment. (This is explained in RHS’s administrative Notice dated April 12, 1999.)