Mark your Calendar! New RAD for Public Housing Conversion Office Hours
The Office of Recapitalization is hosting its inaugural RAD for public housing office hours! The office hours are intended to be another forum for public housing authorities (PHAs) and other stakeholders interested in using RAD or RAD/Section 18 Blends to engage with Recap staff on how to recapitalize their public housing properties. Join us to talk with program experts and get advice and feedback.
The first office hour will be held on Tuesday, September 10th at 1:00 – 1:30 pm ET. Look up the date and time of future office hours here. Office hours are open to all and no registration is required so feel free to join at any time by accessing this Teams link. We hope to see you there!
Lock in Fiscal Year 2022 RAD Rents
Public housing properties that convert under RAD enter into a Section 8 contract with contract rents that are calculated based on public housing funding levels. Applicants that are awarded before the end of this year will have a Commitment to enter into a HAP contract (CHAP) that locks-in RAD Rents based on Fiscal Year (FY) 2022 public housing funding levels, which were historically high. Starting in 2025, new awards will have RAD Contract Rents based on FY 2024 public housing funding levels, which on average are expected to be slightly lower for some PHAs. Therefore, we encourage PHAs contemplating a RAD conversion to apply by October in order to lock in the FY 2022 RAD Rents. To find out more, join us for office hours or email rad@hud.gov.
Section 108 Flexibilities Available to Provide Gap Financing
HUD recently announced increased flexibilities for communities who want to use the Section 108 Loan Guarantee Program for affordable housing projects, through the Legacy Challenge. This program offers new flexibilities for up to $250 million in borrowing by CDBG grantees. Funds can be used in affordable housing for:
- Infrastructure to support housing production such as utility installation or upgrades
- Adaptive reuse, including converting unused office space and other commercial space into housing
- Preservation, rehabilitation, and repairs of existing units
- Manufactured housing, including facilities to build new homes
- Eligible housing uses within mixed-use or transit-oriented development
- Loan pool to support local housing development
- Other eligible housing activities
For PHAs and developers, this program may assist your RAD project by providing lower cost access to capital than within the private market, potentially helping to fill gaps in financing. The deadline for Community Development Block Grant (CDBG) grantees to submit a final application is July 1, 2025.
For more information, contact Section108@hud.gov. Additional information on the Legacy Challenge is available here and you can watch leaders speak to the success of Section 108 here.
Federal Flood Risk Management Standard (FFRMS) Implementation Date
On April 23, 2024, HUD published the FFRMS Final Rule, which modifies HUD's floodplain management regulations to better address flood risk.
For RAD PBRA Conversions with or without FHA Risk-Share, HUD extended the implementation schedule such that properties must comply with the new rule starting on January 1, 2025, for any conversions where the Part 50 Environmental Review has not been approved or the Part 58 eight step decision-making process for complying with the floodplain management requirements has not been completed. The January 1, 2025, extended compliance deadline is tied to a completed floodplain management review. In order for a property to be subject to the prior regulation:
- RAD Financing Plans subject to a Part 50 review must be submitted by November 1st in order for HUD to complete and certify the full review before the end-of-year deadline, or
- HUD has to complete the 8-step process including two public notices before the end-of-year deadline.
For RAD PBV Conversions, compliance with the new rule for PIH Part 58s was required as of June 24, 2024. However, environmental reviews that are in progress and published a final 8-step notice prior to that date do not need to reevaluate for the new rule. Additionally, Part 58 environmental reviews that published an NOI-RROF prior to June 24, 2024, also don't need to comply with the new rule and reevaluate. PHAs and Owners must work with their Responsible Entity to ensure that a property's Part 58 environmental review complies with the new rule.
To aid applicants understanding of the new rule, HUD conducted two trainings on the Department's FFRMS approach, limitations on HUD assistance in floodplains, exceptions to the Rule, the eight step decision-making process. Learn more about FFRMS by accessing the recorded trainings on Part 55 Overview and Compliance and Part 200 Overview, Protection of Wetlands, Flood Insurance, and Notifications.
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