On December 1, 2016, HUD issued an update to Chapter 9 of the Section 8 Renewal Policy guidebook. The guidance applies to any Rent Comparability Study (RCS) signed by an appraiser on or after March 1, 2017. Chapter 9 has been completely reorganized and updated, with the following changes:
- The responsibilities of owners, appraisers, and reviewers are now all shown in one place (Chapter 9);
- Highlights provisions unique to RCSs when prepared for an Annual Adjustment Factor (AAF) rent determination;
- Clarifies that the option to use FMRs or rents in non-section 8 units to determine the market rent are only available for Option Two contracts, and that these options may only be used with HUD approval;
- Provides more precise instructions on why and how adjustments to the rent grid are made;
- Increases the documentation that appraisers must provide if an adjustment on the rent grid exceeds a nominal amount or a percentage of the unadjusted rent of the comparable, whichever is greater;
- Provides clearer qualifications for HUD reviewers; and
- Establishes a trigger for a second review if a non-appraiser undertakes the substantial review.
Owners or projects that are required to conduct RCSs should obtain a copy of the revised Chapter 9 and review it for applicability to their circumstances. A copy should also be provided to any appraisers that are conducting RCSs.