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Applicability of 5 Year Plan Submission if Converting all AMPs to RADIf a Housing Authority converts all their amps to RAD and submitted an Amendment to their 5 year plan, do they need to submit a 5 year plan again? We believe the HA would not have to because they would no longer be considered public housing.
You are correct that the Housing Authority would not have to submit a 5 Year Plan if all AMPs are being converted to RAD. However, the AMPs will not "officially" leave public housing until the RAD closing so if a 5 Year Plan is due prior to the RAD closings of all of the Housing Authorities AMPs, the Housing Authority would still need to comply with the current public housing rules in place regarding a 5 Year Plan submission.
Submission of Significant Amendment to 5 Year or Annual Plan for Non-MTW PHAsI am a non-MTW PHA. What process do I follow for submitting and receiving approval of our Significant Amendment to the Five Year Plan or Annual Plan as required by the RAD Notice?
A RAD conversion, as noted in Section 1.5(E) of PIH Notice 2012-32, REV 2, requires a Significant Amendment to the PHA’s Five-Year Plan for qualified and non-qualified PHAs or a Significant Amendment to the Annual Plan for non-qualified PHAs. The Notice at Attachment 1 D also outlines elements that the PHA Plan Significant Amendment must address. PHAs will no longer submit Significant Amendments and PHA Plans to the RADPHAPlans@hud.gov mailbox. Non-MTW PHAs must submit Significant Amendments or PHA Plans via email to Field Office Public Housing Director or designated field office contact. The PHA must also upload a memo noting their submission and date to the RAD Resource Desk as part of their Financing Pla uploads. For non-MTW PHAs submitting a regularly scheduled PHA Plan, the Public Housing Field Office should follow their regular PHA Plan review and approval process. The Public Housing Field Office should send a letter confirming approval to the PHA, with a copy to the appropriate RAD Transaction Manager (TM), within 75 days of submission. The PHA will then upload the approval letter to the RAD Resource Desk.