HUD published revised Rental Assistance Demonstration (RAD) Notice, PIH 2012-32, REV-2, on Monday, June 15. The Notice addresses stakeholder feedback on RAD’s transactional and operational issues, and also incorporates key changes to the program’s Congressionally-authorized unit cap expansion from 60,000 to 185,000 conversions. Some of the most notable revisions include clarifications to long-term project funding eligibilities and guidance on the overall conversion process:

• The time period for the submission of multi-phase public housing applications is extended to July 1, 2018.
• Finance plan milestones are eliminated to streamline transactional processing and to complement the deadlines of tax credit providers.
• Program eligibility extends to Moderate Rehabilitation Single Room Occupancy (Mod Rehab SRO) properties funded under the McKinney-Vento Homeless Assistance Act.
• Various resident and property management rights and protections are clarified.
• Property owners of Rent Supplement (Rent Supp) and Rental Assistance Payment (RAP) programs are eligible to participate in the RAD Program and also have the option to convert properties through a long-term PBRA contract.
• Clarifications are provided for non-dwelling property and land removal in the context of a conversion.
• Davis-Bacon wage requirements are applied to rehabilitation/construction work.

Demand for the RAD program is anticipated to grow. To prioritize for high-need conversion, preservation, and rehabilitation, HUD has established a public housing waiting list beyond the 185,000 unit cap.

The Ballard Spahr RAD team is assessing the updates to the RAD Notice and working with key stakeholders to identify the impact of the clarifications and modifications on existing and planned projects. We are excited to work with these RAD program changes and look forward to their fruitful implementation.