1. Tenant Qualification Seminar Blended Project Challenges
Sheryl Putnam
Nan McKay & Associates

2. Qualifying tenants in blended projects requires additional consideration
All program rules must be considered
Makes compliance more complex
Program regulations sometimes conflict
RAD conversions present some unique challenges

3. Programs may be blended at the unit level or the project level
These are both blended properties, but compliance activities will be slightly different
PBV/LIHTC
PBV
LIHTC

4. Important Considerations
Tenant files
Forms
Income limits
Student eligibility
Income calculation
Employment income
Zero income
Sporadic income
Rent setting
Utility allowances
Termination requirements
Increases in income
Interim reporting requirements
RAD issues
Initial qualification of households
Termination/grievance requirements

5. Initial Qualification of RAD Households
PHAs will choose either RAD PBRA or RAD PBV
HUD regulations state that in-place residents have the absolute right to return to the project once rehab is complete
HUD does not allow re-screening of in-place households for RAD PBRA or RAD PBV
HUD eligibility factors

6. Initial Qualification of RAD Households
In-place households must have rent phased-in if RAD conversion results in tenant monthly rent increase by more than 10% or $25
3 year or 5 year phase-in (PHA policy)
In-place households with high income levels may not qualify under LIHTC income limits
Need a plan to address those households

7. RAD PBRA RAD PBRA + LIHTC Issue
For BOTH in-place residents at the time of conversion AND for new admissions, when the household’s total tenant payment (TTP) exceeds the RAD PBRA gross rent, the household must pay the TTP
Issue
Household TTP could exceed the LIHTC maximum gross rent at conversion or anytime thereafter for all households
PIH Notice REV-2

8. RAD PBV In-Place Households
RAD PBV + LIHTC
For in-place households at the time of conversion, when the household’s total tenant payment (TTP) exceeds the RAD PBV gross rent, the household must pay the TTP
Issue
Household TTP could exceed the LIHTC maximum gross rent at conversion or anytime thereafter for in-place households
In-place households treated differently – must track
PIH Notice REV-2

9. RAD PBV New Admissions after Conversion
RAD PBV + LIHTC
For new admissions after conversion follow regular PBV regulations at 24 CFR 983
When household income increases to point where $0 housing assistance is paid on behalf of household, household pays full rent to owner
(Can be $0 HAP for 180 days. Terminated from program at day 181)
Issue
Tenant paid rent could exceed the LIHTC maximum gross rent limit once HAP is $0 for new admission households

10. Termination and Grievance Requirements for RAD PBRA and RAD PBV
All in-place and future residents must be afforded public housing termination and grievance rights
Include in House Rules for RAD PBRA
See Attachment IE – House Rules: Addendum A - Resident Procedural Rights (PIH Notice REV-2)
Include in Administrative Plan and owner’s lease for RAD PBV
PIH Notice REV-2

11. RAD Guidance
RAD PBRA: 24 CFR 880 although parts do not apply to RAD PBRA projects
See Appendix 1 (PIH Notice REV-2)
RAD PBV: 24 CFR 983 and 24 CFR 982 although parts of both do not apply to RAD PBV projects
PIH Notice REV-2
Quick Reference Guides (PBRA and PBV)
RAD Conversion Guide
RAD Relocation Notice H ; PIH

12. Thank you!