On December 20, HUD issued Notice PIH 2022-38/FPM-19-2022 Reporting Supplement to the Implementation of the Final Rule on Section 3 Regulations – 24 CFR Part 75.
The primary purpose of the notice is to formally amend the reporting deadline requirements included in Notice PIH 2022-10 Implementing the Final Rule on Section 3. Section 3 Compliance Reporting for public housing funding is now delayed until further notice.
Section 3 itself is not delayed, and compliance with the new rule is still required. Only the reporting to HUD is suspended, and only for public housing operating and capital funding. HAs still must retain records of Section 3 activities and documentation of compliance for each reporting period. The notice provides links to various tools and forms that can be used, though use of these is not required and HAs may use their own formats.
The change in reporting requirements announced by this notice does not apply to HUD Community Planning and Development and grant programs, nor to Choice Neighborhoods or RAD post-conversion activities. Section 3 reporting for CPD programs is completed either through the Integrated Disbursement and Information System (IDIS) or the Disaster Recovery Grant Reporting (DRGR) system. Choice Neighborhoods Section 3 Reporting is done through the CNInform platform, and RAD post-conversion Section 3 reporting (when required) is done via the RAD Office. Recipients of funding from other HUD programs use their specific reporting systems.
See PHADA’s news alert on the April 2022 implementation notice here. Information on HUD Section 3 resources, with links to prior PHADA analysis of the new rule can be found here. PHADA welcomes feedback on challenges and benefits of new rule implementation, the usefulness of tools and resources provided by HUD, and any suggested recommendations on Section 3.