HUD HCV Guidebook § 2.8

By accepting each monthly housing assistance payment from the PHA, the owner certifies that the rent to
owner is not more than rent charged by the owner for comparable unassisted units on the premises. The
owner must16 provide information requested by the PHA on rents charged by the owner for other units on the
premises, including the rents charged for the three most recently leased, unassisted units in the project, if the
project has 4 or more units. The Request for Tenancy Approval (Form HUD-52517) includes information on
comparable unassisted units on the premises.
In determining the reasonableness of rents for units located in a multifamily project that is not substantially
assisted, the PHA may17 base its determination on the rents charged for the three comparable unassisted
units identified by the owner on the RFTA. In such cases, the PHA does not have to obtain additional rent
comparables in other multifamily housing in the area. Additionally, the PHA may choose to only consider the
most recent rentals in determining the rents that the owner is charging for comparable unassisted units. In
some markets, new families routinely pay higher rents than the rents that longer time families in comparable
units may be paying (often due to local rent stabilization programs or ordinances that limit rent increases for
existing families).
An owner who offers a rent concession for unassisted units at the property (those not qualifying as units in
converted properties; see section 2.4.2 above) must also offer them to HCV/PBV participants.18 The PHA
must use the actual amount of the rent for such unassisted units (that is, the rent with the concession) in
determining the reasonable rent amount. For example, an HCV family is looking to rent a unit in Property A.
The rent to owner is generally $800, but the owner offers a rent credit (a rent concession) of $100 during the
first two months of occupancy. During the initial lease term, the rent amount that the PHA must use for
determining the reasonable rent is $700 for two months ($1,400) and $800 for the remaining ten months
($8,000) in a 12-month period, or $783 (($1,400+$8,000)/12) per month for 12 months.

14
   24 CFR § 982.507(c)(2)
15
   24 CFR § 982.507(c)(2)
16
   24 CFR § 982.507(d)
17
   Notice PIH 2003-12: Determination of Rent Reasonableness – Revision of Request for Tenancy Approval, Form
HUD-52517
18 Notice PIH 2020-19: Rent Reasonableness – Defining Assisted Units for the Housing Choice Voucher and Project-

Based Voucher Programs

Rent Reasonableness                                                                                             6