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RAD Eligibility for Units Approved Under Section 18

Per the RAD Notice (Section 1.5.B.3), “If a PHA that has been approved for a SAC application decides to pursue RAD for eligible units, the PHA must request that SAC rescind or conditionally rescind its approval of the application. If applicable, the SAC will conditionally rescind its SAC application approval contingent on the successful completion of the RAD transaction and will modify IMS/PIC accordingly. Units for which a PHA has received a SAC approval are ineligible for RAD if the PHA has taken any of the following actions to implement the SAC approval: i. executed a demolition contract; ii. completed a disposition (i.e., transferring title and/or executing a ground lease); iii. received TPVs from HUD as a result of an approval; or iv. Taken any steps to implement relocation under the approval (i.e., issuing the 90-day notice to residents).” With regards to TPVs, HUD deducts the number of TPVs awarded to the PHA from the total units approved under Section 18 to see if any units are eligible for RAD, subject to the other criteria listed above. With regard to whether the PHA has “Taken any steps to implement relocation under the approval (i.e., issuing the 90-day notice to residents),” units are ineligible if they were occupied after the section 18 approval and the PHA issued residents occupying those units the 90-day relocation notice. If the PHA had not yet issued the 90-day relocation notice or if residents had moved prior to the Section 18 approval for any other reason (e.g. health & safety reasons under the PHAs ACOP, attrition, etc.) those units would be eligible for RAD, subject to the other criteria listed above. Finally, if units are found to be eligible for RAD after completing the above analysis, they would not be able to utilize a RAD/Section 18 Blend if all of the units had been vacant for 24 months (or a lesser period as defined in HUD’s annual HCV Processing Notice) as they would be ineligible for Tenant Protection Voucher funding.