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Implications of “Days to Relocation” in SAC Application on Operating Fund

As part of the timetable in the SAC application, PHAs include an estimated number of days after HUD approves a SAC application that the PHA plans to start the relocation process. This is not an estimated date that the PHA plans to begin relocation, but instead the estimated number of days after HUD’s approval of the SAC application that the PHA plans to begin the relocation process. PHAs must provide residents who will be displaced by a demolition or disposition action at least 90-days of notice prior to the displacement date. PHAs cannot provide the required 90-day notice until after HUD approves the SAC application. Accordingly, if units are occupied, PHAs cannot enter less than 90-days in this field. If all units are vacant when the PHA submits the SAC application (and the PHA has no plans to re-occupy the units during HUD’s review of the SAC application), the PHA may insert “zero” (0) days in this field.

HUD recognizes that a PHA’s plans to start relocation sometimes change. However, because HUD relies on this information to determine Operating Funds subsidy, PHAs are responsible for ensuring the days to relocation information in a SAC application is reasonably accurate.

  1. Accuracy of Relocation Data. If days to relocation in a SAC application is not reasonably accurate, asset repositioning fee (ARF) payments under 24 CFR 990.190 may begin prematurely and a PHA may receive less Operating Fund subsidy than it otherwise would be entitled to receive. A PHA may even find itself in a situation where it is operating public housing units without any Operating Fund subsidy. Therefore, it is essential that PHAs make timely requests to HUD for any necessary modifications to the days to relocation in a SAC application. Note that after the Operating Fund subsidy revisions deadline in the first year of ARF eligibility, no further changes to the days to relocation in an approved SAC application may be made. Thus, in order to receive all Operating Fund subsidy that they are entitled to receive, PHAs make timely requests HUD.
     
  2. Process for Requesting that HUD Modify Days to Relocation in a SAC Application. If a PHA becomes aware that the days to relocation in an approved SAC application is not reasonably accurate, the PHA submits a request to its local Office of Public Housing to modify the information. Specific steps are as follows:

    1. The PHA sends an email to the Director of its local Office of Public Housing with a copy to the HUD PIH staff member assigned to the PHA using the following Subject “PHA Code, SAC application DDA Number, Modification to Days to Relocation”. The PHA includes the new estimated number for the days to relocation, along with a brief explanation of the reason for the modification.
       
    2. The local Office of Public Housing reviews the request to ensure it is reasonable/it has no information that is inconsistent with the request (e.g. information from residents that relocation has started) and that the new estimated days to relocation is not past the Operating Fund subsidy revisions deadline in the first year of ARF eligibility. The Operating Fund subsidy revisions deadline is the date after which HUD no longer accept PHAs’ requests for revisions to the HUD-52723.
       
    3. If the PHA’s request is acceptable, HUD (SAC) modifies the days to relocation in the SAC application and emails the PHA either notifying it that it has made the change. HUD processes these modifications as technical corrections to approved SAC applications and will not issue a formal written amendment of the SAC application.
       
    4. If the PHA’s is not acceptable (e.g. the requested new days to relocation is past the Operating Fund subsidy revisions deadline in the first year of ARF eligibility, the local Office of Public Housing will deny the request in writing.