If your selected renewal option requires the submission of a RCS, you will need to contract with a state-certified general appraiser to prepare one. Because renewal requests are due to SHCC 120 days before expiration, we recommend that you begin looking for an appraiser at least 7 months in advance. Guidance on how an RCS is prepared is provided in Chapter 9 of the Section 8 Renewal Policy Guidebook.
Not all Rent Comparability Studies are associated with contract renewals. If your contract term exceeds the 5-year life span of the RCS, review the contract requirement to determine if an RCS is required. In limited cases, some properties may be required to submit a Rent Comparability Study with their AAF or Special Rent Adjustment rent adjustment request. If you are unsure if you need a RCS, please contact your Financial Analyst.
Here are a few tips to help you with your submission:
- There are two alternatives to submitting an RCS, which are detailed in Sections 9-5 and 9-6. Please review them as they may save you the cost of an RCS.
- Upon receipt of the RCS from your appraiser, please take the time to review it before submitting it to SHCC. Appendix 9-10 of Chapter 9 is a good tool to get a general idea as to whether your appraiser prepared the RCS in accordance with the requirements.
- Be sure to review the rents for appropriateness. These rents will set the ceiling for maximum allowable rents for the next five years (adjusted by the OCAF in years 2-5).
- An owner cover letter is required. It must include all the certifications and statements listed in Section 9-16. We have created an RCS Owner Cover Letter template for your convenience.
Choosing an Appraiser
Your appraiser will have a lot of impact on the quality of your RCS and ultimately the maximum rent potential for your property. In addition, if your current rents are above the comparable rents determined by your RCS, referral to OAHP is mandatory for eligible properties. Therefore, it is important to choose your appraiser carefully.
To help you get started, we have compiled a list of appraisers who have submitted RCS’s to SHCC in the past. SHCC makes no endorsement of the quality of the appraisers. The state registry of certified general appraisers can be accessed at www.asc.gov.
Third Party Rent Comparability Study
It is important to note that the owner’s Rent Comparability Study will undergo a test to ensure that they do not exceed 140 percent of the median “Gross Rent By Zip Code Tabulation Area” as published by the U.S. Bureau of the Census. If the owner’s RCS rent exceeds this amount, a third party RCS will be ordered from HUD. Therefore, it is important to review both Chapter Nine of the Section 8 Renewal Policy and your study to determine whether a 3rd party RCS will be ordered. There is no appeal process or negotiations allowed when there are differences between comparability studies.HUD’s median rent figures.