Supporting Statement A

Status: Original and derived artifacts are available for this document.

Download: docx | pdf | html

Supporting Statement for Paperwork Reduction Act Submission
Survey of Market Absorption of New Multifamily Units (SOMA)
OMB Control # 2528-0013



    A. Justification

    1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

This Information Collection Request (ICR) is being submitted to OMB as an extension of a currently approved collection under OMB control number 2528-0013. Current OMB approval expires on 9/30/2026.

The Survey of Market Absorption of New Multifamily Units (SOMA) provides the data necessary to measure the rate at which different types of new rental apartments and new condominium/cooperative apartments are absorbed, that is, taken off the market, usually by being rented or sold - within the first 12 months after a building’s completion. The data are collected at quarterly intervals until 12 months expire or until the units in a building are completely absorbed, which may occur sooner. The data is collected from building managers, rental and sales agents, as well as building and property owners.

What SOMA collects

For Condos and Co-Ops, SOMA collects information on asking sales price, the number of units taken off the market (absorbed), the number of units in the building, the number of floors in the building, presence of elevators, items included in the condo or co-op fee (Electric, Gas, Water, Sewer, Cable or Satellite TV, Internet or WiFi, Swimming Pool, Off-street parking, Washer/Dryer, and Laundry Facilities). Since 2002, the survey has asked whether the unit is in a building that is age-restricted and whether the management of the building provides residents with meals, transportation, housekeeping, managing finances, and personal care.

The survey also provides estimates of the apartments’ characteristics being absorbed and provides a basis for analyzing the extent multifamily-building activity is meeting the present and future needs of the public. The survey has been conducted since 1970.

The authority to collect information is in Sections 501 and 502 of the Housing and Urban Development Act of 1970 (Public Law 91-609) (12 U.S.C. §§ 1701z-1; 1701z-2(d) and (g)). Please see Appendix A for the relevant section of HUD’s statutory authority. Full text of the statutory language is included as Appendix A to this Supporting Statement.

2.	Indicate how, by whom and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

This Information Collection Request (ICR) is being submitted to OMB as an extension of a currently approved collection under OMB control number 2528-0013. Data from this survey enable the Department of Housing and Urban Development (HUD) to analyze the characteristics, location, and rents or prices of newly completed multifamily rental and condominium units and to assess how quickly they are being absorbed by the market. These data are useful as a barometer of new rental units demand (particularly in the local market areas) because the absorption rates indicate the relative tightness or looseness of rental markets. The data may be used to address the adequacy of the supply of rental housing stock. HUD uses the data in its quarterly US Housing Market Conditions reports and in reporting housing market data on HUDUSER.gov.1

The Federal Reserve Board uses the data to compare asking rents for rental properties with monthly mortgage payments data. The Board also uses the data as an indicator of strength of demand for different types of new rental units, and as a measure of the volume of nonsubsidized, privately financed multifamily units being completed.

Historically, the Fiscal Analysis Division of the Congressional Budget Office, the Council of Economic Advisors, and the Office of Thrift Supervision as well as many other public and private entities use this data for rental housing market analysis and forecasting future trends. For example, the National Association of Home Builders uses the SOMA for its economic research blog, Eye on Housing.2

Federal programs and federal policy will be impacted if this housing market analysis information is not collected.

3.	Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

SOMA data has been collected using Computer-Assisted Personal Interviewing (CAPI) since April 2014. Field Representatives (FRs) conduct SOMA interviews over the phone whenever possible using the CAPI instrument. FRs conduct in-person interviews only after obtaining supervisor permission and only ask about the remaining units that were not absorbed last time. Screen shots of the instrument are included as Appendix B of this Supporting Statement. 


4.	Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

After a review of other surveys taken by the Census Bureau, including the Survey of Construction, the American Housing Survey, the Current Population Survey, the American Community Survey, and the Housing Vacancy Survey, we have determined that none of the other Census Bureau survey products provide the absorption information for new multi-unit buildings the SOMA produces.

The SOMA follows a sample of multifamily buildings with five or more units from the Survey of Construction (SOC) to measure characteristics and absorption rates 3, 6, 9, and 12 months after a building’s completion. Census is currently exploring the possibility of using building permit data aggregated by private companies to build some or all of the SOC frame and, if necessary, use satellites to monitor construction progress to reduce the need for SOC interviews. The SOMA can potentially be supplemented or replaced by two types of administrative records data (i.e., Multifamily Public Records Data, collected by companies like Zillow and Redfin, and Third-Party Multifamily Rental Data, collected by companies like Costar and Realpage). However, evaluating the feasibility of replacing or supplementing the SOMA with administrative records requires assessing the quality of address information (because data will need to be matched to the SOC sample), available data points, and timeliness of data delivery.

Multifamily Public Records Data

Rented Units in SOMA: The information that SOMA collects for multifamily rental units likely could not be gathered from public record sources. Public records do not typically contain information about individual units in multifamily rental properties. Data are collected at the property level (at the level of ownership), not the unit level.

Owned Units in SOMA (Condos and Co-ops): Public records could be a source for some, but not all, of the data that is collected in the SOMA on owned multifamily units. Condos are single family homes for tax purposes and have records at the unit level. However, there is a wide variation in the timeliness of public records collection throughout the United States. Because of that, publication of SOMA data on condo sales would be less timely without this collection; public records may lag current collation by 12-18 months. A comparison of what SOMA collects versus what companies like Zillow and Redfin collect is detailed below:

What Zillow3 collects for condos/co-ops

Home Values by Number of Bedrooms and Per Square Foot, For Sale Inventory, Days to Pending, List Price, Condo/Co-Op, Single Family, Multifamily 2+ Units, and Duplex/Triplex

What Redfin4 collects for condo/co-ops

Sales Price, Sale-to-list difference, Price per square foot, Inventory (number of homes on the market), New Listings, Months of supply, Number of Homes Sold, and Days on Market

Third-party data on Multifamily Rentals

Third party vendors can provide some of the data that is collected in the SOMA for multifamily properties; however, some limitations make this impractical. First, the level of detail needed for SOMA (occupancy rates by bedroom size and rent rate category) could come from rent roll records. Third party data vendors, like Costar or RealPage, compile data from rent rolls via property management software that many rental property management companies use. Costar (https://www.costar.com/customers/multifamily-property-managers), for instance, claims to have a Census of rental units in 20+ unit buildings and collects data from property management systems on vacancy, absorption, rental rates, and some amenities. They, and other software vendors, provide detailed rental data for purchase. However, to ensure SOC and SOMA respondent confidentiality, the Census Bureau would have to purchase data for all rental properties from each software vendor and conduct the matching at Census. The cost of purchasing the rental data from multiple software vendors is likely to greatly exceed the SOMA budget.

Lastly, we know from data sources like the Rental Housing Finance Survey, and from property management software companies themselves, that some smaller rental properties (<50 units) manage their properties using other property management software applications. Thus, if we depended on large property management software companies to supply data from their subscribers, we won’t receive data from smaller rental properties.

5.	If the collection of information impacts small businesses or other small entities describe any methods used to minimize burden.

This information does not disproportionally impact small businesses or other small entities.

6.	Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The data are collected quarterly for each building until a building is completely absorbed, with the first interview for each building occurring 3 months after completion. If necessary, additional interviews are conducted for units that are not absorbed after 6, 9, and 12 months. A less-frequent collection schedule would alter the basis for analysis, affect data comparability, and may introduce bias into the results. It would also affect other organizations, like the National Association of Home Builders, that make use of this survey data for their products.

    7.  Explain any special circumstances that would cause an information collection to be conducted in a manner:

The proposed data collection activities are consistent with the guidelines set forth in 5 CFR 1320 (Controlling Paperwork Burdens on the Public). There are no special circumstances that require deviation from these guidelines. The following below are “Not Applicable” to this collection:

    • requiring respondents to report information to the agency more than quarterly – “Not Applicable;”
    • requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it – “Not Applicable;”
    • requiring respondents to submit more than an original and two copies of any document – “Not Applicable;”
    • requiring respondents to retain records other than health, medical, government contract, grant-in-aid, or tax records for more than three years – “Not Applicable;”
    • in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study – “Not Applicable;”
    • requiring the use of a statistical data classification that has not been reviewed and approved by OMB – “Not Applicable;”
    • that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use – “Not Applicable”; or
    • requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law – “Not Applicable”.


8.	If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. 
    • Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping disclosure, or reporting format (if any) and the data elements to be recorded, disclosed, or reported.
    • Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years — even if the collection of information activity is the same as in prior periods. There may be circumstances that preclude consultation in a specific situation. These circumstances should be explained.

In accordance with 5 CFR 1320.8 (Paperwork Reduction Act of 1995), HUD published a 60-Day Notice of Proposed Information Collection in the Federal Register on March 2, 2026, (Docket No. FR-7103-N-04, pages 10104-10105) related to the data collection activities for the Survey of Market Absorption of New Multi-Family Units. The notice provides a 60-day period for public comments, and comments are due May 1, 2026. This supporting statement will be updated with a summary of any public comments that are received. (See Appendix C for a copy of the Federal Register Notice.)

This data collection was initiated in 1970. Prior to and during 1970-71, frequent consultations were held among representatives of the Department of Housing and Urban Development (HUD), the Census Bureau, and persons from outside the agencies. Currently, consultations occur as needed between officials of the two agencies. Discussions have been held periodically with members of the Housing Statistics Users Group on the status of SOMA. This group is comprised of trade and private sector organizations that use housing data. Comments are also welcome from survey respondents and are given careful consideration, as are those from other representatives of the user community.

    9. Explain any decision to provide any payment or gift to respondents, other than renumeration of contractors or grantees.

Respondents are not paid or otherwise rewarded for their participation in this information collection.

    10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation or agency policy. If the collection requires a system of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

Disclosure of the information provided to us is permitted under the Privacy Act of 1974 (5 U.S.C. § 552a) and may be shared with other Census Bureau staff for the work-related purposes identified in this statement. Disclosure of this information is also subject to the published routine uses as identified in the Privacy Act System of Records Notice COMMERCE/Census-3, Demographic Survey Collection (Census Bureau Sampling Frame). The Census Bureau collects these data in compliance with Title 13 of the United States Code, the Federal Cybersecurity Enforcement Act of 2015, and OMB Circular A-108. The instrument contains a screen that FRs read to all respondents which informs them (1) of the voluntary nature of this survey, (2) of the estimated average burden hours per response, (3) the contact information for the agency to address any comments on the accuracy of the estimate and suggestions for reducing the survey’s burden, (4) that there are no penalties for failure to answer any questions, (5) that the U.S. Census Bureau is required by law to protect respondent information (Title 13, United States Code, Section 9), (6) per the Federal Cybersecurity Enhancement Act of 2015, that respondent data are protected from cybersecurity risks through screening of the systems that transmit data, and (7) that by law, the Census Bureau can only use responses to produce statistics. 
 
    11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

The questionnaire does not include any questions of a sensitive nature.

    12. Provide estimates of the hour burden of the collection of information. The statement should:
    • indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices;
    • if this request covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I; and
    • provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.

The Census Bureau selects completed buildings with five or more housing units in its SOC each month. The number of new buildings in each month’s sample is limited to 1,000. The number of respondents varies each month because a single respondent may be asked to reply for more than one building. 

After the initial interview, FRs only conduct subsequent interviews for buildings that have not been completely absorbed and will determine only the number and types of units remaining for rent or sale.

The burden for initial and subsequent interviews at a particular building averages 30 minutes (0.5 hours), for a maximum estimated burden of 6,000 hours (12,000 respondents’ x 30 minutes) per year. The hourly cost of $44.50 is the 75th percentile hourly wage for Property, Real Estate and Community Association Managers.5


    13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information (do not include the cost of any hour burden shown in Items 12 and 14). 

    • The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s) and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities;
    • If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10) utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate. 
    • Generally, estimates should not include purchases of equipment or services, or portions thereof made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

There will be no cost burden to respondents beyond the costs captured under questions 12 and 14. 

    14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

HUD bears the total cost of the SOMA and funds the survey through a transfer of funds to the Census Bureau. Costs below are broken out by: Census professional staff, field data collection, and technology costs. HUD estimates the costs to the Federal Government for the 2027 SOMA for FY2027 rounded up to be $2,438,000.

Cost Items
FY27
FY28
Professional Staff
 $1,188,940 
 $1,106,302
Field Data Collection
 $   680,320
 $   720,879
Technology
 $   568,740
 $   583,819
TOTAL
 $2,438,000
 $2,411,000


The figures above are based on the following factors:

    • For professional staff, the estimates are based on budgeted “not-to-exceed” amounts for FY 2027. Professional staff include survey methodologists, statisticians, computer programmers and other IT support, communications specialists and managers.

    • For field data collection, projected costs reflect “not-to-exceed” amounts. The Census Bureau’s field case management cost projection model provides the projected costs. The cost projection model uses cost information from prior surveys (including, but not limited to, the SOMA), specifications for the current SOMA, and current local and regional labor rates.

    • Technology costs include laptop purchases and maintenance. The Census Bureau provides this estimate and reflects a cost-sharing portion of the Census Bureau’s annual technology costs for CAPI-based surveys. All surveys using CAPI share technology costs.
  
    15. Explain the reasons for any program changes or adjustments reported in Items 12 and 14 of the Supporting Statement.

This collection will be an extension without change of a currently approved collection. The burden hours from 2024 to 2027 were unchanged, but the annualized cost to the Federal government (question 14) was updated to reflect the GS-13 base wage rate for CY2026 which is the most recent rate available.


    16. For collection of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

SOMA data will be processed as soon as all the information is transmitted directly by the interviewers each month. After the last month of each quarter, the data are tabulated, and the results are posted on the Census’ website (www.census.gov/soma).

The survey produces quarterly estimates which present data on the time it takes to rent or sell new multifamily units completed in a quarter by showing percent absorbed at 3-, 6-, 9-, and 12-month intervals following completion of the buildings. The quarterly estimates are scheduled to be issued during the third week of February, May, August, and November.

Annual estimates and multifamily unit characteristics are released during the third week in February. 

    17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

All data collection instruments will prominently display the expiration date for OMB approval.

    18. Explain each exception to the Certificate.

This submission describing data collection requests no exceptions to the Certificate for Paperwork Reduction Act (5 CFR 1320.9).