NLHA 2018 Fall Meeting with John Doyle's Panel Discussion

In October of 2018, John Doyle participated in a panel discussion at the NLHA Washington DC Conference.

Discussion Points-

• HUD has an increased participation in more of our RCS’s than ever before due to the 140% test.

• There is a more specific process developed by HUD for reviewers- this may have helped eliminate some reviewers that were not following the process but may have also introduced more detailed review…

• This process has introduced a new twist to how to resolve disagreements—can we still appeal?

• Owners need to advocate for themselves and pay attention to the review process.

Appraisal companies like the ones on the panel- Gill Group & Doyle Advisors (and The Signal Group too)- may play different roles- work for owners, work for HUD, act as a reviewer—these experts understand all sides of what the job is and how to make sure you are getting what you need.

What are items that an owner should be aware of when obtaining an Rent Comp Study, that may affect its usefulness?

• Qualifications of appraiser

• How long the report is acceptable without an update

• Steps to update

Aside from just the rents themselves for a HAP contract, what other things can an RCS affect? These include how the rents don’t just affect the bottom line but how they can affect the overall value, the ability to sell properties with lower rents (but maybe lower cap rates), the effects concluded rents have on other affordable projects in the area, and more.

The issues or lack of clarity about how appeals should be handled

• Bad reports ordered by HUD overturned—Appeal

• Getting a solution without an appeal.

• What is not supposed to happen in a review (HUD reviewer wanting to have you pick different comps)