RAD for PRACs Notice Released for Public Feedback

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Earlier last week HUD released a draft section for the next revision of the RAD Notice for review and comment. This draft section addresses the implementation of “RAD for PRAC”, the conversion of conversion of properties assisted by Section 202 Project Rental Assistance Contracts (PRACs). There are approximately 125,000 units assisted by the Section 202 PRACs and could take advantage of this expanded conversion option.

The draft section is available for review at the Multifamily Housing Policy Drafting Table. Comments are to be submitted via e-mail to rad2@hud.gov by Tuesday, March 12th.

Please find below the text of the RADBlast on this topic.

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RAD for PRACs Notice Published on the Drafting Table for Public Feedback

The FY 18 Appropriations Act authorized the conversion of properties assisted by Section 202 Project Rental Assistance Contracts. HUD is in the process of revising the RAD Notice to include a new Section 4 that would provide implementation instructions for the conversion of Section 202 PRACs under RAD. Prior to implementation, a draft Section 4 has been posted to HUD’s Office of Multifamily Housing’s “Drafting Table” where HUD will be accepting public feedback for the next two weeks. Following consideration of public feedback received, the Office of Recap will proceed toward incorporation of the new Section 4 into a revised RAD Notice.
We encourage all interested parties to review and provide feedback on this draft, including on the following:
• Is this document well organized?
• Is the guidance set forth in this document clear? Are there sections that are unclear?
• Are the proposed terms of the Use Agreement reasonable and adequate?
• Are there unique features of 202 PRACs or the elderly population that the properties serve that HUD has not adequately accounted for in this Notice?
• The draft Section describes an option to convert to Section 8 Project-Based Rental Assistance (PBRA) or to Project Based Vouchers (PBV) What is the degree of interest in PBV conversions? Please note that while HUD has developed the framework for a process for seamlessly funding a conversion from PRAC to PBRA, funding a conversion from PRAC to PBV is likely to be more complex.
• Does HUD provide adequate avenues for stakeholders to provide feedback on the direction of the RAD program and, if not, what additional measures for public feedback should HUD consider?
Please send written comments via e-mail to rad2@hud.gov by Tuesday, March 12th.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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