The 2026 law removed RAD's deadline and raised the cap

Public housing authorities no longer face a RAD deadline. The 21st Century ROAD to Housing Act became law on July 11, 2026 as Public Law 119-101, and section 212 rewrote parts of the RAD statute. Two matter for every PHA planning a conversion: there is no end date, and the cap is 555,000 units instead of 455,000.

What section 212 changed

The RAD statute lives in the 2012 HUD appropriations act (Public Law 112-55) as a run of provisos, and Congress amends it by editing those provisos. Section 212 made these changes:

  1. Struck “until September 30, 2029” and inserted “for fiscal year 2012 and each fiscal year thereafter”. Public housing conversions are now open-ended.
  2. Struck “455,000” and inserted “555,000” as the cap on public housing units that can convert.
  3. Added that HUD’s tenant protections can include “a mandatory tenant lease and management plan addendum” for converted properties not covered by another program.
  4. Required HUD to assess and publish findings on public housing conversions every year.
  5. Gave HUD authority to impose civil money penalties or other remedial action for material violations of RAD requirements.

What did not change

The rules for running a conversion. CHAPs, Financing Plans, rent setting, PBV and PBRA terms, ownership and control, relocation, and the feasibility benchmarks HUD added in Supplemental Notice 4C all still come from the RAD notice (Notice H-2019-09 / PIH-2019-23, Revision 4, as amended by Supplementals 4B and 4C).

The Component 2 side, which converts Mod Rehab, Rent Supplement, RAP and Section 202 and 811 PRAC properties, already had no deadline and no cap.

The gap between the law and the notice

HUD’s RAD notice still says 455,000 units and September 30, 2029. As of late October 2026, HUD’s RAD notices page listed no new notice implementing section 212. The RAD Resource Desk’s home page already shows the 555,000 figure.

For a housing authority the practical reading is simple. The cap and the deadline in the notice are out of date, because the statute controls them. Everything else in the notice still applies until HUD replaces it.

How much room is left

HUD’s RAD data shows the closed conversions and the deals between CHAP and closing. The home page meter plots both against the new cap. The rest of the cap is not all free: HUD also reserves units under portfolio and Moving to Work awards that haven’t reached CHAP.

Sources

Short answers

Does a housing authority still need to apply by September 30, 2029?

No. Section 212 of Public Law 119-101 replaced "until September 30, 2029" with "for fiscal year 2012 and each fiscal year thereafter" in the RAD statute. HUD's RAD notice still shows the old date because HUD has not reissued it.

Do the new civil money penalties apply to existing conversions?

The statute lets HUD impose penalties or other remedies for material violations of RAD requirements under both components. How HUD will use that authority, and against which properties, depends on guidance HUD had not issued as of October 2026.

About the author

Janover Capital LLC, commercial mortgage team. Prepared by the commercial mortgage team at Janover Capital LLC. Sources are cited at the bottom of each page, with their dates.

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