From CHAP to closing, with HUD's deadlines
A RAD public housing conversion moves through four HUD approvals: the CHAP, the Financing Plan, the RAD Conversion Commitment (RCC) and closing. The deadlines that bite are 270 days from CHAP to Financing Plan, 30 days to sign the RCC, and 90 days from the RCC to close. All of them come from the RAD notice (Notice H-2019-09 / PIH-2019-23, Revision 4, as amended through Supplemental 4C).
1. Application and the PHA Plan
The housing authority applies for a single project, a multi-phase project or a portfolio. The conversion has to appear in the PHA Plan as a significant amendment, which means a public process before the board acts.
2. CHAP
HUD issues a Commitment to enter into a Housing Assistance Payments contract (CHAP). It fixes the initial RAD rents and terms and isn’t negotiable. The PHA accepts it by starting the inventory removal in HUD’s PIC system. HUD can revoke a CHAP for ineligibility, infeasibility or lack of progress.
3. Concept call and Financing Plan
Before submitting, the PHA and its partners hold a concept call with HUD through the RAD Resource Desk. The Financing Plan is due within 270 days of the CHAP, unless HUD sets a project-specific date; if HUD invites the submission after the concept call, it is due within 60 days of that invitation.
The Financing Plan carries the sources and uses, the scope of work, the debt and equity commitments and the environmental review documents. Every RAD conversion is now reviewed under 24 CFR Part 50, with HUD as the responsible entity.
Supplemental 4C added feasibility tests the plan has to pass. A deal with debt must show debt service coverage of at least 1.11 over ten years, at 2% annual revenue growth and 3% expense growth. A deal without debt must keep the operating expense ratio at or below 80% for the first five stabilized years. A deal without tax credits or commercial debt needs a six-month operating reserve.
4. RCC
When HUD accepts the plan it issues the RAD Conversion Commitment. The PHA has 30 days to sign it, and the RCC allows 90 days from issuance to close.
5. Closing
HUD reviews the draft closing documents. A construction or bridge loan needs a take-out commitment, and an FHA-insured loan runs through HUD’s multifamily underwriting in parallel. The HAP contract takes effect on the first day of one of the two months after closing, and residents sign new Section 8 leases.
Where the time goes
The deadlines above are HUD’s. The longer clocks usually belong to the money: a 4% tax credit deal needs a bond allocation and an investor, a 9% deal needs to win a competitive round, and an FHA loan has its own processing queue. In HUD’s RAD data as of October 2026, the median time from CHAP to closing across 1,858 closed conversions with both dates was about 22 months, and about 25 months for deals that closed in 2023 or later. (Early awards that HUD dates January 1, 2013 are left out of that count.) Each housing authority’s page lists its own dates.
Sources
- HUD, RAD Notice Revision 4 as amended by Supplementals 4B and 4C, sections 1.9, 1.12 and 1.13, and Supplemental 4C section X.
- Federal Register, June 16, 2025: Supplemental 4C effective date.