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Rent Comparability Studies

If your selected contract renewal option requires the submission of a RCS, you need to contract with a certified general appraiser to prepare one. Guidance on how an RCS is prepared is provided in Chapter 9 of the Section 8 Renewal Policy Guidebook.

Not all Rent Comparability Studies are associated with contract renewals, however. If your contract term exceeds the 5-year life span of the RCS, review the contract requirements to determine if an RCS is required. In some cases, properties may be required to submit a Rent Comparability Study with their AAF or Special Rent Adjustment rent adjustment request. If you are unsure if you need a RCS, please email LOMOD at for assistance.

Here are a few tips to help you with your submission:

  • There are two alternatives to submitting an RCS, which are detailed in Sections 9-5 and 9-6. Please review them as they may save you the cost of an RCS.
  • Upon receipt of the RCS from your appraiser, please take the time to review it before submitting it to LOMOD. Appendix 9-10 of Chapter 9 is a good tool to get a general idea as to whether your appraiser prepared the RCS in accordance with the requirements. HUD will not accept an RCS if it has not been prepared according to the requirements as specified in the Guidebook.
  • Be sure to review the rents for appropriateness. The comparable rents must be from similar like and kind units in the area. These rents will set the ceiling for maximum allowable rents for the next five years (adjusted by the OCAF in years 2-5).
  • An owner cover letter is required. It must include all the certifications and statements listed in Section 9-16.

It is important to note that HUD will also hire an independent third-party appraiser to perform a Rent Comparability Study, and the Project Manager will rely on the information contained in the third-party RCS in determining rents. Therefore, it is important to review your Rent Comparability Study carefully to ensure the results are reflective of market conditions in your area. There is no appeal process when your RCS has been submitted to HUD and HUD’s third-party appraiser determines that the comparable rents are different.