I'm joined by Susan Connelly, the Chief Operating Officer and Principal at Housing Opportunities Unlimited (HOU). Housing Opportunities Unlimited is a housing relocation consultant that advises clients on compliance with Uniform Relocation Act (URA) requirements.
Our Nixon Peabody Affordable Housing attorneys often collaborate with Susan and her team at HOU when URA compliance is necessary. Their insights assist property owners and developers in ensuring that projects subject to URA compliance meet regulatory standards while addressing the needs of affected residents.
What is the Uniform Relocation Act and what are its main objectives?
The Uniform Relocation Assistance and Real Property Acquisition Act (URA) and its complementary implementing guidelines, Handbook 1378, outline the requirements for developers working onsite with existing residents using various public financing resources. The URA ensures the proper and supportive treatment of residents during the rehabilitation or one-to-one replacement of public and affordable housing.
Can you give an example of when the Uniform Relocation Act (URA) applies to HUD projects?
If people are using RAD (Rental Assistance Demonstration) to rehabilitate public housing, URA comes into play in two ways. One, the RAD regulations reference URA. Two, if your project requires residents to move offsite, all URA regulations apply. This includes the intent of certain subsections of URA and the whole application, depending on where residents are being relocated and for how long.
When should property owners start thinking about Uniform Relocation Act (URA) compliance during relocation? What initial steps are required?
Recently, changes were made to URA that brought the treatment of temporary relocation closer to permanent relocation. This includes identifying a specific apartment 90 days prior to the start of the individual’s move. It’s important that developers and housing authorities think through the implications and prepare their relocation plan to reflect the regulations and the reality of what can be done.
What are the initial steps for property owners to provide resident notifications under the Uniform Relocation Act (URA)?
It depends on the sources of financing that the project is using. Notification of eligibility goes out very early if someone is over income for the new program. There are notices under different programs that need to go out even before finishing the deal. Once you have closed and are moving forward, you start with a 90-day notice to all residents, letting them know their estimated move date and what support they can expect from the relocation agent.
What benefits are residents entitled to under the Uniform Relocation Act (URA) during the relocation process?
The overall goal of URA is to limit the fiscal impact on residents. Developers must ensure that all moving costs are covered, including costs related to utilities and change of address. If a resident needs to be relocated offsite, transportation to schools and regular activities must be provided. HUD has identified a whole host of things to ensure residents aren’t incurring the cost of the project.
Why is Uniform Relocation Act (URA) compliance crucial? What are the consequences for property owners who fail to meet URA requirements?
Non-compliance opens up the project to lawsuits from residents, giving them legal standing to bring a lawsuit. HUD can also intervene if public money is being used and rules aren’t followed, which most people want to avoid. Worst case scenario, HUD can recapture funds if URA rules were not followed.
We’re recording this episode in early April 2025. With a new administration in office since January, what are the potential changes in Uniform Relocation Act (URA) compliance?
Even if the administration changes URA rules, most developers will recognize the need to have some form of URA as part of their process, especially in states with high real estate values and local resident protections.
Connect with Susan Connelly at housingopportunities.com.
