Q&A: When Must Tenants be Notified of Upcoming Utility Allowance Changes?

Question:  A family moves in on October 14^th.   On October 1, a decrease in the Utility Allowance for November 1 was approved, which would make the tenant rent go up (and the assistance payment go down).  When should I charge this new household the higher rent?  What notice do I need to give them?

Answer:  This household’s rent would go up on November 1^st, along with everyone else’s.  On June 20, 2011, a memo was issued by Carol Galante, then Deputy Assistant Secretary for Multifamily Housing Programs, to clarify this issue.  The memo states (several times) that a decrease in the UA is not a rent change (and thus, by extension, the requirements for rent change notifications do not apply).  The only requirement is to notify in-place tenants “at least 30 days” before management submits the request for a UA decrease to HUD for approval.  The purpose of that notice is to allow them time to comment.