HUD-9628 Required Contents for Rent Comparablity Study

Appendix 9-10

Required Contents for Rent Comparablity Study
See Appendix 9-3 for a Sample RCS.
1. Transmittal Letter signed by the Appraiser. Address to project owner and date as
of the date you gave the report to the owner. Include:
appraiser's name, company name, address, telephone, fax number and email
address (These may be included in letterhead or body of letter.)
project name, FHA/other project number of the Section 8 project
table of estimated market rent for each unit type included in the study. Use table
format shown below. In last column, enter “Y” for yes if you prepared a Rent
Grid for that unit type. Enter “N” for No for secondary unit types for which you
did not prepare a grid, but instead adjusted the primary type’s estimated rent.
Estimated Market

Unit
Type

#
Units

Size
(Sq. Ft)

Rent

$/
Sq. Ft

Prepared
Grid?
(Y/N)

Total
statement that market rents were defined and estimated in accordance with
Sections 9-7 through 9-13 of this Chapter and the report was prepared in
accordance with Sections 9-14 through 9-16 of this Chapter.
appraiser’s acknowledgment of how his / her report will be used: Suggested
language -- I understand that HUD/the Section 8 Contract Administrator (CA)
and the project owner will use my estimate of market rents to determine: 1) the
owner’s options for renewing the project’s Section 8 contracts; and 2) the
maximum rents allowed under any renewal contract.
2. Scope of Work. Acknowledge that all work was done in accordance with the
requirements set forth in this notice. Provide a narrative describing:
dates, number and types of inspections, and how unit sizes were verified.
how rent, condition and amenity data were collected and verified. Note
interviews, records reviewed, Internet sites used, etc. Indicate time period during
which data was collected.
any data that was unobtainable or estimated and all efforts to obtain that data.
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Appendix 9-10

any assistance from assistant appraisers.
3. Description of Subject Property. Address the items listed below. Note: If the units
being renewed are located on scattered sites and those sites differ significantly on
condition, services, street appeal or other factors listed below, note those differences.
property name and address (street, city, county, cross streets) and neighborhood
name if applicable).
site characteristics and improvements: number of buildings and their design
(construction material, structure type), number of units; topography and density;
and access to site.
unit mix for all units in the project, not just the Section 8 units. Use the table
format below. Include all revenue-producing units in the project & group them by
major unit types (e.g., # bedrooms/ # baths). (See Section 9-10A 6 for a definition
of rent restricted units.).

Unit
Type

#
Units

Total

Interior
Size
(SF)

#
Pjt- Based
Sec 8 units

#
Other Rent
Restricted
Units

Total

Total

#
Units
Not Rent
Restricted

Total

condition: age of property, state of repair, any recent/ planned rehab or
refurbishing.
schedule of charges collected in addition to rent.
3 to 5 labeled, color photos of exterior and interior (See Section 9-9B for more
on photos. Place photos at the end of the RCS or in the body of RCS’s description
of the subject.).
population or occupancy group targeted for this project (e.g., elderly), if any.
summary of unit design and amenities.
summary of project service/ site amenities: parking, recreational facilities,
community areas, security, service coordination, neighborhood networks,
transportation, meal services, social or educational activities, emergency call
systems, laundry or housekeeping, and any other amenities for elderly or disabled.
name and phone number of contact person with whom you verified or collected
information on the subject property
4. Identification of the Subject’s Market Area. Identify the geographic area from
which the subject would normally draw its applicants.
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Appendix 9-10

5. Description of Neighborhood. Discuss the project’s location noting factors that
would impact market rent level. Cover at least the factors listed below. Note: If the
units being renewed are located on scattered sites and those sites differ significantly on
the factors listed below, note those differences.
property types (multifamily, single family, commercial) and rural/ suburban
/urban nature of community.
access to schools, recreation, transportation, shopping, medical and employment
centers, community services or other features tenants at subject would seek
nuisance (e.g., street noise), crime rates, and other factors affecting the perceived
quality of the neighborhood.
6. Narrative Describing Selection of Comparables.
Provide an overall assessment of the availability of comparables and the quality
of the comparables selected and state why the comparables used were selected. If
the unassisted units in the subject project have the same number of bedrooms and
were not used as comparables, explain why. If less than five comparables were
provided for any primary unit type, say so and explain why.
Identify any comparables that are significantly dissimilar to the subject (e.g.,
different number of bedrooms, different structure type, different level of services).
Describe what research was performed to determine that more similar
comparables were not available.
Identify any comparables that are outside the subject’s market area. Describe
what research was performed to determine that better comparables were not
available in the subject’s market area. Compare the rent levels in the alternate
market area with those in the subject’s market area.
Identify any rent restricted units used as comparables. Explain the type of
restriction (e.g., LIHTC, local rent control, etc.).
Identify any comparables that are owned or managed by companies having an
identity-of interest with the owner or management agent of the subject property.
7. Locator Map.
Identify subject property and each comparable.
Clearly mark major roadways and natural or man-made barriers (e.g., rivers,
freeways, railways, etc).
8. Rent Comparability Grid (Appendix 9-2)
Complete one grid for each primary unit type using instructions in Appendix 9-8
and guidance in Section 9-15 of this Chapter.
Show all comparables for one unit type on one grid. Fill in all lines of the Grid’s
data columns, even if no adjustment is made on a line.
9. Narrative Explaining Adjustments and Market Rent Conclusions for Each Rent
Grid. Review the guidance in Sections 9-12 and 9-13 and the line-by-line
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Appendix 9-10

instructions in Appendix 9-8 before preparing this narrative. Be sure you explain the
items listed below.
Note: Prepare a separate set of explanations for each grid. If an explanation
applies to more than one comparable, you may refer back to that explanation
rather than repeating it each time (e.g., the location adjustment was estimated
for the same reason and in the same way as for comparable #X).
Adjustments made / not made: For each adjustment, briefly explain why the
adjustment was made and how you arrived at the dollar value of the adjustment. If
data columns show a comparable differs significantly from the subject project but
no adjustment was made, explain why.
How market rent was derived from comparables’ adjusted rents. Explain
how the market rent was estimated and why it was derived that way. Note which
comparables were given the most weight and why. If some comparables were
weighted more heavily than others were or the estimated market rent is set at high
end of adjusted rents’ range, explain why.
How market rent for a primary unit was used to derive a market rent for a
similar, secondary unit type. Explain what adjustments were made and why. Put
these comments immediately following Line 46’s comments. (Note: See Section
9-9A2 for guidance on classifying unit types as primary or secondary).
10. Comparable Property Profiles. Provide a one-page, table/ grid profile of each
comparable property used in the RCS. Profile each property only once, regardless of
the number of unit types for which the property was used. The profile must include
at least the items listed below. Appendix 9-4 provides a sample profile, but
appraisers may create their own table / grid formats.
property name and address (street, city, county, cross streets) and neighborhood
name
name and phone number of contact person with whom you verified or collected
information on the property and the date you did so.
a color photo (at least 3” by 5”) of the project’s exterior. (Interior photos may be
included if available, but they are not required).
A rent and unit mix table. Include all units in the project and group them by
major unit types (e.g., # bedrooms/ # baths). Indicate which unit types are used as
comparables in the RCS.

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Appendix 9-10
Unit
Type

No. of
Units

Used as Comp
in RCS?
(Y/N)

Average
Rent

Interior
Size
( SF)

Any Rent
Restrictions?
(Y/N)

Total

Total number of units at the project and project-wide occupancy.
List of any charges tenants pay in addition to rent.
Describe any rent / income/ use restrictions or tenant rent subsidies (Section 8,
certificates, vouchers, state/local payments on behalf of residents) in effect at the
property. Provide this information even if the units covered by the restriction/
subsidy were not the units studied in the RCS.
11. Appraiser Certification (Appendix 9-1)
Fill in blanks and sign and date the Certification. When entering names, also give
title. (Example: Sharon Jones, Assistant Appraiser)
Enter “none” in items 8 and 10 if you have nothing to disclose.
12. Copy of any Temporary License the appraiser is relying upon for this RCS. Any
temporary license relied upon must be issued by the state where the property is
located.
Important: The following items are NOT required in a RCS.
• Demographic trends for the market
• Interior photographs of comparables
• Copy of Engagement Letter
•Appraiser Qualifications (In Appendix 9-1 Appraiser Certification, appraisers certify
that they meet all of the appraiser qualifications set forth in Section 9-8 of this
Chapter)
• Copy of Appraiser's Permanent License

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