HUD HCV Guidebook § 2.4.2
Conversion Actions11 (HUD HCV Guidebook)
Operative Text
Units in converted properties (a property undergoing a conversion action that triggers eligibility for a TPV as
described below) are considered assisted if the owner chooses to continue charging below market rents by
offering lower rents or other rent concessions to impacted families who do not receive a voucher. To be
considered assisted, the owner must provide written notification to the PHA, including a list of the covered
families, by unit number; a description and duration of the lower rent or concession; and any additional
information that the PHA deems necessary to determine applicability of the policy to the property.
Upon verification of the information submitted by the owner, the PHA must exclude such units from rent
reasonableness determinations until notified by the owner that either a covered family has moved from the
unit or the rent paid by the family is no longer below market or subject to a rent concession, at which point the
unit is no longer excluded from the rent reasonableness determination.
9
24 CFR § 982.507(b)(1)
10
24 CFR § 982.507(b)
11 Notice PIH 2020-19: Rent Reasonableness – Defining Assisted Units for the Housing Choice Voucher and Project-
Based Voucher Programs
Rent Reasonableness 4
Converted properties include properties undergoing any of the following conversion actions:
Housing conversion actions that occur in the Multifamily Housing Portfolios and include an owner
decision to opt-out of or not renew a Section 8 project-based contract (opt-out); a prepayment of the
mortgage or voluntary termination of the mortgage insurance of a preservation eligible property
(preservation prepayments); a HUD enforcement action against an owner that involves termination or
non-renewal of a Section 8 project-based housing assistance payments; or a HUD property disposition
activity;
Any of the conversion actions covered by Notice PIH 2019-01/H 2019-02, or successor notices, for
which the property has received an award of set-aside TPVs; and
A public housing conversion action including demolitions and/or dispositions approved under Section
18 of the 1937 Act (including demolitions authorized under de minimis authority of such Act); required
conversions approved under Section 33 of the 1937 Act; voluntary conversions approved under
Section 22 of the 1937 Act; and removals initiated under an awarded Choice Neighborhood Initiative
and/or HOPE VI grant.
The unit must be occupied by a family who was residing in the unit on the following date (as applicable) and
did not receive a TPV as a result of the conversion action:
The date of the eligibility event of the housing conversion action;
The later of: (a) the date that the TPV funding application is submitted to HUD by the PHA or (b) the
date of the triggering event, for set-aside TPV actions; or
The date of PIH approval of the Public Housing Conversion or the Choice Neighborhood Initiative award
dateHUD Housing Choice Voucher Guidebook § 2.4.2 establishes when units in properties undergoing certain conversion actions—such as opt-outs from Section 8 project-based contracts, public housing demolitions, or HUD enforcement actions—are treated as 'assisted' for rent reasonableness purposes. A unit qualifies as assisted when the owner voluntarily continues to charge below-market rents or offers rent concessions to affected families who did not receive a Tenant Protection Voucher (TPV) as a result of the conversion. Once a public housing authority (PHA) verifies the owner's written documentation, those units are excluded from standard rent reasonableness determinations until the family moves out or the below-market arrangement ends.
Plain English — not legal advice.
Under HUD Housing Choice Voucher Guidebook § 2.4.2, property owners who choose to maintain below-market rents or offer concessions to families affected by a conversion action—and who want those units treated as assisted—must submit written notification to the PHA. That notification must include a list of covered families by unit number, a description and duration of the rent reduction or concession, and any other information the PHA requests. Compliant operators also notify the PHA promptly when a covered family vacates or when the rent is no longer below market, so the unit's exclusion from rent reasonableness review can be lifted.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
HUD Housing Choice Voucher Guidebook § 2.4.2 provides protections for families living in properties undergoing qualifying conversion actions who did not receive a TPV—meaning their unit may be classified as 'assisted' if the owner continues charging below-market rent or offering concessions. This classification affects how the PHA evaluates rent reasonableness for voucher purposes, which can have implications for housing stability during a conversion. Tenants who believe their unit should be covered under this provision, or who have questions about their rights during a conversion action, may consider contacting their local PHA, a HUD-approved housing counseling agency, or a tenant-rights organization for general information.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
Generated September 26, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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