*Internal HUD Use Only
*Internal HUD Use Only
Definition of
What level of work is considered "new construction" for a RAD project when rehab is being done? For example, would a PHA be required to perform an FHEO review for "new construction" if it is gut-rehabbing all of the units?For the purposes of RAD, new construction refers to the construction of entirely new structures and/or significant extensions of existing structures. Substantial rehabilitation of an existing structure that may include the demolition of units and walls but that will re-use the existing foundation is not considered new construction.
FHEO Review for Unit Reduction
If I am using both the de minimus reduction and the 75%/25% RAD/Section 18 blend provisions on a RAD transaction, do I need to submit the FHEO Change in Unit Configuration review? All reduced units will be replaced by other PBV units and Tenant Protection Vouchers (TPV), so the number of low-income dwelling units is the same.If all of the reduced units are being replaced with project-based assistance, an FHEO Change in Unit Configuration review is not needed.
Process for Requesting Up-front FHEO Reviews
How long does the FHEO neighborhood and site review take to complete and what is the formal process for requesting the up-front review?HUD expects the upfront civil rights reviews to take approximately 60 days. The upfront civil rights review templates can be found in the Document Library on the RAD Resource Desk and the submission instructions can be found within the templates.
Transfer of Assistance to Site Outside of PHA’s Jurisdiction
Can a PHA do a RAD Transfer of Assistance to sites outside the jurisdiction of the PHA provided that the receiving jurisdiction and the state agency overseeing vouchers approves?See the discussion of Transfer of Assistance in the Notice (including in particular, pages 31-32 of the Notice REV-2). HUD approvals for Transfer of Assistance are made case by case and in HUD's sole discretion. The site will also be subject to site and neighborhood standards. If you would like to discuss a specific proposal for Transfer of Assistance, please contact the RAD Team at RAD@hud.gov.
Timing of Accessibility and Relocation Plan Checklist
Is it appropriate for a PHA to provide the accessibility and relocation plan checklist prior to submission of an application for firm commitment for FHA financing or submission of a financing plan?Yes. PHAs must provide the accessibility and relocation checklist prior to submission of an application for firm commitment for FHA financing or submission of a financing plan. However, since approval of the checklist is required prior to closing, in order to avoid delays HUD strongly recommends that PHAs submit the checklist as soon as details of the transaction are known (i.e. before all of the other components of the Financing Plan or application for firm commitment is ready). Submission of the checklist in an earlier stage will help speed up transaction processing and allow HUD more time to work with a PHA to resolve any issues that may arise during review.
Accessibility and Relocation Plan Checklist
If a PHA is performing a conversion without any rehabilitation or construction, is it necessary to provide an accessibility and relocation plan checklist?Yes. All PHAs participating in RAD must fill out an accessibility and relocation plan checklist. There are only 2 questions that need to be completed on the checklist if the transaction does not involve any rehab or construction. A PHA will be required to fill out the checklist consistent with the provisions in Section 1.12 and Attachment 1A.1.E of PIH Notice 2012-32, REV-1.