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PHADA Submits Comments on Proposed RAD Information Collection

On June 9, HUD issued a 60-Day Notice of Proposed Information Collection: Rental Assistance Demonstration (RAD) Choice Mobility and Long-Term Affordability Evaluation, and shared unreviewed draft survey instruments provided by its contractor. PHADA submitted comments that highlighted the additional administrative burden the information collection would place on participating housing authorities, especially smaller agencies and those with earlier RAD conversions.

PHADA also noted that no substantive new information was proposed to be collected regarding long-term affordability of projects converted under RAD beyond prioritization of long-term concerns by owners and managers of RAD projects. While a useful piece of information, it will not provide any definitive data on the risks and protections around long-term affordability across the converted portfolio. PHADA urges HUD and its contractors to use existing data to perform such an assessment.

PHADA’s full comments are available here.

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