- Acceptance of CHAP. Within 30 days of CHAP issuance, a PHA must confirm its acceptance of the CHAP by submitting an application (including required attachments) into the Inventory Removals module in PIC identifying the units that will be removed from the public housing Annual Contributions Contract (ACC) when the project completes conversion.62 Failure to submit an application into PIC according to the instructions provided by HUD will result in a suspension of the CHAP and a revocation if not corrected within 15 days of notification, unless HUD identifies just cause for an extension. If the CHAP is re- instated, it will retain its original issuance date. Similarly, if the transaction changes and HUD determines that the PIC application needs to be modified by the PHA, the PHA will have 30 days to resubmit the Inventory Removal application and HUD will follow the above- described procedure for failure to comply.
Removing Acreage in PIC for Multiphase ConversionWe have a large project that we are converting in phases. For the initial phase, in terms of PIC removal, do I include acreage for the entire site or just the portion being converted?
For the PIC removal application, just include the portion being converted at this time.
PIC Removal for Non-Dwelling UnitsMy converting RAD project also includes some non-dwelling units. Do I request removal for the non-dwelling units as well?
Submission of PIC Removal ApplicationOnce I submit the draft PIC Removal application, what happens? Am I out of public housing?
This initial application is a draft, and will not be finalized until your transaction closes and converts through RAD. Your application remains “Under Review.” Although the project will then be exempt from scoring under the Public Housing Assessment System (PHAS), it will otherwise remain in public housing and be subject to all public housing rules and regulations until after closing.
Non-dwelling Units Not Shown in PICHow should the PHA treat non-dwelling buildings that should be removed under the PIC removal application, but are not currently listed in PIC?
On the PIC removal application there is a place to list non-dwelling buildings “not in PIC”, as the application should include all units and buildings, regardless of their dwelling status.
Vacant Units Due to Preparation for Modernization as Part of RADUnder what circumstances can units covered by a CHAP Award be considered "Units Undergoing Modernization"?
Units in a project with CHAP approval, which the PHA plans to modernize, that are vacant because a PHA has not reoccupied them in preparation for modernization pursuant to a for RAD conversion, can be considered as “Units Undergoing Modernization,” provided they comply with 24 CFR 990.145 (excerpted below). To be eligible, such vacant units must need to be vacated for the modernization work to occur. Such vacant units may be categorized as undergoing modernization for a maximum of two years (24 months) prior to the RAD conversion (HAP Effective Date). The units must be approved by the Field Office, and the unit status correctly reflected in PIC. The RAD conversion and planned modernization must be in: 1) A HUD approved PHA Annual Plan for non-qualified PHAs (24 CFR 903); 2) A HUD approved 5-Year Plan for qualified PHAs (24 CFR Part 903) (if no Capital Funds are being used as part of the modernization, a narrative description of the work, including the projected start and completion date, should be included in the Capital Improvements section of the Plan); or 3) a HUD approved Capital Fund Plan (24 CFR 905.300) if Capital Funds are also being used for modernization Units converting to RAD that will not be modernized are not eligible to be categorized as Units Undergoing Modernization. § 990.145 Dwelling units with ap¬proved vacancies. (a) A PHA is eligible to receive oper¬ating subsidy for vacant public housing units for each unit month the units are under an ACC and meet one of the fol¬lowing HUD-approved vacancies: (1) Units undergoing modernization. Vacancies resulting from project mod-ernization or unit modernization (such as work necessary to reoccupy vacant units) provided that one of the fol¬lowing conditions is met: (i) The unit is undergoing moderniza¬tion (i.e., the modernization contract has been awarded or force account work has started) and must be vacant to perform the work, and the construc¬tion is on schedule according to a HUD-approved PHA Annual Plan; or (ii) The unit must be vacant to per¬form the work and the treatment of the vacant unit is included in a HUD-approved PHA Annual Plan, but the time period for placing the vacant unit under construction has not yet expired. The PHA shall place the vacant unit under construction within two federal fiscal years (FFYs) after the FFY in which the capital funds are approved.