A recent memo released by HUD dated August 7, 2014, addresses the use of a lender ordered MAP appraisals in lieu of a separate Rent Comparability Study (RCS) for Mark-Up-To-Market transactions. The Department plans to change the current RCS guidelines upon publication of the long awaited updated Section 8 Renewal Policy Guide to allow for the use of a lender ordered MAP appraisal that will serve a dual purpose; serving as an RCS and for use in underwriting an application for HUD mortgage insurance. Guidance in this August 7 memo offers Hub Directors the opportunity to issue waivers to existing requirements until revisions to the Section 8 Renewal Guide are published. Certain instructions apply for issuing waivers.
