HUD Publishes Updated Administrative Guidelines for Project-Based Voucher Subsidy Layering Reviews

By: Meredith Barnett & Adam Norlander

On February 28, 2020, HUD published updated Administrative Guidelines (“New Guidelines”) governing subsidy layering reviews (“SLRs”) for Project-Based Vouchers (“PBVs”).  Effective immediately, the New Guidelines update prior SLR guidelines issued by HUD on September 26, 2014 (79 Fed. Reg. 57955) (“Prior Guidelines”), to:

1. Include new PBV Housing Assistance Payments (“HAP”) contract terms in accordance with the Housing Opportunity Through Modernization Act of 2016 (“HOTMA”);
2. Provide SLR guidelines for Mixed-Finance projects; and
3. Clarify cash flow, debt coverage ratios, net operating income, and operating expense trending requirements.

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