Repositioning Public Housing
Repositioning moves families from a public housing platform to other forms of HUD rental assistance, such as Housing Choice Vouchers (HCV), Project-Based Vouchers (PBV), or project-based rental assistance (PBRA). This change can help PHAs preserve affordable housing units, address rehabilitation and physical needs, and place properties on a more stable financial foundation.
Guides to Repositioning
These Guides review the different options and associated planning considerations, available to PHAs as they consider the long-term future of their portfolios, with a focus on converting public housing properties and/or assistance to the Section 8 Program platform. The Guides present repositioning options (specific to the PHA size) in an accessible format to PHAs and their Governing Bodies, their staff, residents, and community members. Each Guide addresses the unique characteristics and opportunities most appropriate to PHAs of the respective size grouping of public housing units.
Helpful Handouts
| Topic | Description |
| Choice Neighborhood: Repositioning & Beyond | Provides information about developing mixed-income housing through Choice Neighborhoods grants. |
| Common Repositioning Financing Sources | Provides a list of common financing sources that PHAs may want to consider when conducting rehabilitation or new development |
| Community Supportive Services (CSS) Program & Repositioning | Chart provides information about the impact various repositioning strategies have on CSS programs and participants |
| DDTF & ARF Summary | Chart explains some of the key elements of Demolition Disposition Transition Fees (DDTF) and Asset Repositioning Fees (ARF) |
| Determining Capital Needs | Intended to help PHAs understand the differences between a RAD Capital Needs Assessment (CNA) and a Section 18 Physical Needs Assessment (PNA) |
| Environmental Reviews for non-RAD Repositioning | An introduction to the environmental review requirements for non-RAD repositioning |
| Establishing an Owner Entity | Information on establishing a separate legal entity (owner entity) to further a PHA’s repositioning goals |
| Faircloth Limit FAQs | Answers to frequently asked questions regarding PHA’s Faircloth Limit |
| How PHAs Can Leverage Partnerships with HFAs | This memo encourages PHAs to engage with their state Housing Finance Agencies (HFA) |
| Pensions & Administrative Considerations | Provides tips for PHAs to consider when analyzing their pension and administrative costs as part of their repositioning strategy |
| Public Housing Closeout FAQs (March 2022) | Shows FAQs for PHAs closing out their ACC inventory |
| Repositioning & Public Housing Funds | Answers to frequently asked questions regarding the use of Public Housing Funds for repositioning |
| Repositioning for Residents | Answers to frequently asked questions that Public Housing residents may have regarding repositioning. |
| Repositioning Options: Summary of Key Characteristics | Chart compares the key program characteristics of each main repositioning option, from eligibility for TPVs to impact on Faircloth |
Public Housing Program Closeout
Overview
As Public Housing Authorities (PHAs) reposition their public housing units, they must consider what they are going to do with their Public Housing Program if and when they end up in a position where they have no public housing units remaining. Please note that closing a Public Housing Program is not equivalent to closing a PHA. PHAs are locally established government entities and continue to exist without a Public Housing Program.
When a PHA submits an IMS/PIC application (e.g., RAD, Section 18, Section 22 Streamlined Voluntary Conversion) to HUD that proposes to remove the last of their public housing units, the PHA must include a Notification of Public Housing Closeout or Future Development (Form HUD-5837) that expresses the PHA’s intention to either closeout its public housing or develop new public housing ACC units in the future.
Some removal tools (including Streamlined Voluntary Conversion (PIH Notice 2019-05), Disposition by Very Small PHAs with 50 or fewer unit under Section 3(A)(3)(b) of PIH Notice 2018-04, and Streamlined RAD authority for PHAs with 50 or fewer units) are required to closeout their Public Housing Programs and terminate their ACCs with HUD. Other removal tools do not require PHAs to close-out. In this case, the PHA may choose to close-out (at its discretion), or may choose to develop new public housing units, with or without HUD funds, provided the PHA has the required “Faircloth” authority.
A PHA may close-out its Public Housing Program through two different administrative paths:
- PIH Notice 2019-13: Public Housing ACC Termination and PHA closeout (link to notice); or
- PIH Notice 2014-24: Process for Public Housing Agency Voluntary Transfers and Consolidations of the Public Housing Program (link to notice)
In both instances, at the end of the close-out process, HUD will terminate its Public Housing Annual Contributions Contract (ACC) with the PHA and the PHA will become either a “Section 8 Housing Choice Voucher (HCV) only” agency in HUD’s records (if the PHA has a Section 8 HCV Program) or a local entity under state law (if the PHA does not have a Section 8 HCV Program).