Comment Submitted by mauricio sanchez

## Public Comment **Docket ID: HUD-2026-0958** **Document ID: HUD-2026-0958-0001** I am a Housing Choice Voucher (HCV) participant and parent in Los Angeles. I submit this comment because the Renewal Funding Inflation Factor (RFIF) is not merely a technical calculation. It affects PHA renewal funding, Per Unit Cost (PUC), payment standards, voucher utilization, landlord participation, and whether families remain housed. Section 8 was established to help low-income families obtain decent housing. See 42 U.S.C. §1437f(a). HUD should not reduce a PHA’s local inflation adjustment because of restrictive zoning, permitting delays, limited housing construction, or other conditions that voucher families cannot control. In high-cost areas such as Los Angeles, reducing renewal funding could cause lower payment standards, fewer voucher issuances, loss of participating owners, HAP interruptions, displacement, and homelessness. HUD should reward jurisdictions that increase housing supply through an additional markup or incentive instead of reducing the funding needed for currently assisted families. Any FY 2027 RFIF methodology should: 1. Preserve an RFIF floor of 1.0. 2. Protect renewal funding for currently leased families. 3. Prevent funding adjustments from causing HAP interruptions or terminations. 4. Consider vacancy rates, affordable units completed, construction and utility costs, population and job growth, rent burdens, voucher success rates, landlord participation, and rent increases affecting in-place tenants. 5. Publish every data source, weighting factor, calculation, and PHA-level result. 6. Provide a correction and appeal process for inaccurate data. Because HUD relies on Voucher Management System (VMS) leasing and cost data, HUD should require reconciliation between VMS records, the PHA HAP register, rent-to-owner amounts, Total Tenant Payment, tenant rent, utility allowances, abatements, HAP-contract terminations, and participant terminations. Unusual HAP interruptions, retroactive adjustments, owner debts, and participant terminations should trigger independent review. HUD should also require PHAs to verify every participating owner, HAP payee, and management company. Verification should include: * Legal and beneficial ownership. * The manager’s authority to represent the owner. * The identity of the person or entity receiving HAP. * Applicable rental registration and occupancy records. * The approved lease and HUD Tenancy Addendum. * Rent reasonableness under 24 C.F.R. §982.507. * Utilities, appliances, fees, and other charges. * NSPIRE inspection results and code violations. * Prior HAP-contract breaches, overpayments, false certifications, or attempts to collect disputed HAP from tenants. Verification is especially important when ownership is hidden behind an LLC, the owner is absent, the manager or HAP payee changes, or tenants report inaccurate information. Federal housing funds must serve the public interest—not become an opportunity for an owner or manager to exploit weak PHA oversight. HUD should reinforce the legal separation between tenant rent and HAP. During an active HAP Contract, the tenant is not responsible for the portion covered by the PHA’s housing assistance payment. PHA nonpayment is not a lease violation, and the owner may not terminate the tenancy for nonpayment of the HAP portion. The HUD Tenancy Addendum is enforceable by the tenant and prevails over conflicting lease provisions under 24 C.F.R. §982.308(f)(2). PHAs should provide participants with a safe, independent process to report unauthorized charges, incorrect rent calculations, unsafe conditions, false owner certifications, retaliation, and inaccurate termination or move-out information. A complaint should not be decided exclusively by the employee whose conduct is disputed. Participants should receive access to relevant records and a written determination explaining the evidence reviewed. Families should not lose their homes because of an owner’s misconduct, inaccurate records, weak PHA oversight, or administrative failures. HUD should adopt an RFIF methodology that protects existing participants, improves program integrity, safeguards federal funds, and prevents avoidable homelessness. Thank you for considering this comment.