New RAD Notice, Revision 4 Released

Earlier today, HUD released the new Rental Assistance Demonstration (RAD) notice: “Rental Assistance Demonstration – Final Implementation, Revision 4” (Notice H-2019-09; PIH-2019-23 (HA)). The RAD program allows for units to be converted from certain Department of Housing and Urban Development (HUD) funding streams, such as public housing, to either a Section 8 project-based voucher (PBV) funding stream or a Section 8 project-based rental assistance (PBRA) funding stream. There are several major changes in this notice, including changes to the First Component of RAD (which allows public housing units to be converted to PBV or PBRA) and implementation of the 2018 Appropriations Act provision allowing Section 202 project rental assistance contracts (PRAC) to be converted to PBV or PBRA.

The changes to the First Component of RAD include the following:

  • A policy that RAD rents will be updated every two years (RAD awards after each update will use the updated rents);
  • A newly added “Concept Call” step to the RAD process, to allow PHAs to receive confirmation that project plans are sufficiently advanced to submit a Financing Plan;
  • More stringent notice requirements for residents in developments to be converted (the new notice details resident participation requirements at each step of the RAD process);
  • A policy that all households residing in regular PBV units will have the same resident rights extended to them as households that reside in RAD-PBVs in converted developments;
  • A mechanism for PHAs to enter into partnerships with each other to convert developments;
  • A policy allowing for rent increases in certain scenarios for PBRA conversions, such as developments located in Opportunity Zones;
  • Elimination of the requirement to submit the Capital Needs Assessment (CNA) tool in certain scenarios; and
  • Other changes (including changed requirements for portfolio awards, a change in how PHAs report debts owed, and broadening the use of “tiered environmental reviews”).

At this time, NAHRO staff are still reviewing the new notice. Additional analysis will be provided in future NAHRO publications.

The RAD Notice, Revision 4 can be found here.

[2:17 pm edit – The new notice can also be found on HUD’s RAD website here.]

Opportunity Zone Hearing on February 14 at 10am

The Treasury department has announced that on February 14 at 10am a public hearing will be held on proposed regulations concerning investing in qualified opportunity funds (QOF). February 14 is the new date for the Opportunity Zone public hearing that was originally scheduled for January 10 but was canceled due to the lapse in Federal appropriations.

The public hearing will focus on the proposed regulations that provide guidance under new section 1400Z-2 of the Internal Revenue Code (Code) relating to gains that may be deferred as a result of a taxpayer’s investment in a qualified opportunity fund (QOF).

The hearing is open to the public and will be held in the IRS Auditorium, Internal Revenue Service Building, 1111 Constitution Avenue, NW, Washington, DC. At this time, it does not appear that there will be a telephone or web-based broadcast of the hearing. NAHRO will attend the hearing and provide a summary of the hearing to our members.

Additional information on the February 14 Opportunity Zone public hearing can be found in the pre-publication Federal Register notice.