HUD HCV Guidebook § 3.2.1

PHAs use a database of unassisted units to find comparable units to the subject unit. PHAs should focus their
considerations on the factors that affect rent rather than try to measure against an arbitrary standard of
average rents. The danger in a standard is that poorer quality units are likely to be overpaid and higher quality
units underpaid. In addition, ranges or averages should be determined for the submarket areas within the

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marketplace. The broader the area for the range or average, the more likely is an under/overpayment for
particular units. It is better to compare to specific units.
Once the staff member has identified the units most comparable to the program unit, the staff member
should place information on the comparable units in the file.
Exhibits 3: Sample Comparison of Program and Comparable Units and Exhibit 4: Suggested Format Rent
Reasonableness Checklist, provide two alternative sample forms for recording the data on the program and
comparable units for placement in the tenant file. The person conducting rent reasonableness should provide
sufficient information about the evaluation process so that an auditor or supervisor can understand how the
comparables were used to determine the appropriate rent for the program units.
If the initial location selection provides very few units from the database, the analyst may need to expand the
geographic area to include more units for comparison. However, the analyst should consider this distance
and make the best determination possible about the comparability of the units. Documentation in the file
should trace the analyst’s steps, analysis and conclusions.
In some cases, particularly in areas where there are few rental units, it may be hard to identify units that
match on location, building type and number of bedrooms. In these cases, the analyst may need to review the
database to locate units that: 1) have the same number of bedrooms and building type but in a broader
geographic range; or 2) have the same number of bedrooms and are in the same geographic location but are
in other types of buildings. Knowledge of the comparative housing markets and general variations in price by
type of building, along with some creativity, may be needed in cases where there are few direct comparables
in the database. The following example illustrates this point:
Database of comparable units
Many PHAs use a third-party database of rental units to find comparables. When choosing a database, PHAs
should ensure that the database meets the requirements of the program (for example, that the comparable
units in the database are unassisted).
The PHA may create their own database of comparables by researching available units listed online. This may
make more sense in rural areas or for small PHAs where a third-party database does not exist or is cost
prohibitive.
Newspaper and internet listings often contain either the lowest rent or the range of rents among units with the
same number of bedrooms. The PHA can follow-up to determine what causes the rents to vary (e.g., unit size;
location in the development; number of bathrooms; amenities), and record each configuration as a separate
comparable.
Possible Sources of Rental Information on Vacant Units
The best sources of rental information will vary from community to community. PHAs should learn how owners
market their vacant units to locate them for comparability and to recruit new owners to the program.
In some localities, rental property listings may be available from licensing or taxing authorities. Where
licensing does occur, obtaining a list of these units by location, size and type can provide a picture of the
overall rental market.
The following are websites that provide rental listings for many parts of the country. In addition, most of the
major web browsers provide access from their home page to one or more rental housing listing services:
     move.com
     craigslist.org
     Apartments.com
      forrent.com
      padmapper.com
      Zillow.com – Lists all rental units that are publicly listed through real estate agencies; typically
       includes single units or smaller complexes.

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Newspaper ads (including internet versions of newspaper ads);
     Weekly or monthly neighborhood or shopper newspapers that have rental listings;
     “For Rent” signs in windows or on lawns;
     Bulletin boards in community locations, such as grocery stores, laundromats, churches, and social
      service offices; and
PHAs may choose to have a standard form for collecting the data on unassisted units that includes all the
needed information under the regulations. Exhibit 1: Survey for Unassisted Rental Units provides a sample
form.