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Transfer of Assistance for Mod Rehab Component 2 Conversion
We have a 47 unit mod rehab project that may be interested in redeveloping under RAD at another site. Is this permissible under RAD?Yes, transfers of assistance are permitted for Mod Rehab RAD conversions. See Section 2.4(I) in the RAD Notice for scenarios under which assistance may be transferred to another site.
Conversion Processing Times
I'm working with an MOD/SRO owner converting to RAD PBV. Once the application is received, are the current processing times still 180 days per the notice, pending all owner/PHA required information is received?The RAD Program Notice PIH-2012-32-(HA), addresses this in paragraphs 2.8.4.A and B on page 153. HUD will review and either approve/reject/request more information in 60 days. HUD’s approval letter requires closing within 90 days. In the case of a PBV conversion, the HAP contract is issued by the Public Housing Authority, and the Owner would need to coordinate timing with the PHA also.
Mod Unit Conversions Under First Component
Is there still a 1,250 unit cap for Mod Rehab conversions under the 1st component?No. That cap was removed with the publication of PIH Notice 2012-32 REV-1. [Updated 7.29.13]
2nd Component of RAD; Combining Mod Rehab Contracts
I am preparing a Conversion application for a project that involves consolidating two mod rehab contracts (and properties) under one new ownership and LIHTC financing structure. Is there a way that we can submit a single RAD application rather than having to submit individual applications for each Mod Rehab contract? All of the financing is interwoven.Yes, you can. When completing the Mod Rehab RAD Application, which is only used for the first component, fill out a single application, including the total units at the project and make sure you attach both Mod Rehab contracts. For data for which the two contracts may have different numbers (e.g. rents and utility allowances) use the weighted average.[Updated 7.29.13]
Mod Rehab Contract Expiring Before RAD Conversion
What should we do if the Mod Rehab contract is expected to expire before the RAD conversion is completed?If the Mod Rehab contract is expected to expire before the RAD conversion is completed, the Owner may request a short term renewal contract for the period necessary to complete the conversion.
Mod Rehab Competitive Conversion to PBVs
We have a High Rise Building of 180 units all of 3 Bedrooms. The property is under the Mod Rehab Program and has 168 units under the HAP Contract only. The contract expired on June 14, 2009, since that time we have renewed year to year. We would like to apply under the RAD program (Section 2 of the Notice) for the option of PBV. But we need the conversion for all HAP units. Is this possible (Section 2.2.5 A 2 of the Notice mentions that the assistance is for only 50% of the units)?The Section of the Notice that you mention in your question generally limits the number of units at any given site that can be assisted by project-based vouchers to 50% unless there are "exception" units at the site. Exception units include scattered site units, units occupied by the elderly or disabled, or units occupied by families receiving supportive services. In effect, no more than 50% of the units at a site can be assisted by project-based vouchers and occupied by families not receiving supportive services. Assuming your project is primarily occupied by families, to maintain all 168 units of assistance at the current site, you would need to provide or arrange for supportive services for at least 78 families. You may also want to consider a conversion to PBRA, in which all 168 HAP units would be eligible for conversion without a supportive service requirement.