HUD Proposal Brings New RAD PHA Compliance Requirements
HUD is proposing a rule that increases oversight of executive compensation, directly impacting RAD PHA compliance. If finalized, Public Housing Agencies (PHAs)—including those converted under the Rental Assistance Demonstration (RAD) program—must report compensation details for top-paid executives.
This proposal is still under review, yet RAD PHAs should begin preparing now. After all, oversight of federal dollars remains a key HUD priority.
What This HUD Notice Proposes
In Docket No. FR–7104–N–04, HUD outlines a plan to collect detailed salary data from PHAs receiving federal housing funds. The proposal includes the following requirements:
- Who reports: All PHAs, including RAD-converted agencies
- Who gets reported:
- The top management official
- The top financial official
- Any employee earning above Level IV of the Executive Schedule ($183,500 in 2025)
- How often: Once every three years, covering one full year of pay
- How it’s submitted: Through Form HUD–52725
- Where it goes: HUD will publish the data for public access
Compared to past reporting, this version emphasizes both transparency and accountability.
Why RAD PHA Compliance Still Matters
RAD Conversion Doesn’t Eliminate Federal Oversight
Although RAD offers flexibility, it does not remove compliance responsibilities. If your agency receives funding tied to PBRA or PBV programs, it remains subject to HUD rules. Consequently, this proposal reinforces that RAD PHA compliance remains non-negotiable.
Executive Compensation Will Be Publicly Shared
HUD plans to post salary information online. Therefore, if your RAD agency offers competitive or high executive pay, prepare to explain it. This can be important for building trust with residents, local leaders, and watchdog organizations.
Some Preparation Will Be Necessary
HUD estimates a one-hour reporting burden. However, RAD PHAs should anticipate additional work. You’ll likely need to coordinate between finance, human resources, and compliance to gather:
- Base pay
- Bonuses or incentives
- Benefit details
- Source of funds (e.g., Section 8 or 9)
If you use RAD layering, identifying funding sources becomes even more critical.
What You Can Do Now
1. Start Reviewing Pay Structures
Evaluate executive compensation now. If any roles exceed the federal cap, consider documenting justifications and funding sources.
2. Designate a Compliance Lead
Assign a team member to manage Form HUD–52725, maintain clean records, and track changes.
3. Submit Comments by July 14, 2025
HUD wants your feedback. You can shape this policy by commenting at www.regulations.gov. Be sure to reference Docket No. FR–7104–N–04 or email Eva.L.Fulton@hud.gov.
Specifically, HUD is asking for input on:
- The usefulness of the data
- The accuracy of burden estimates
- Suggestions to streamline reporting
Make sure your agency’s perspective is heard.
What This Means for RAD PHA Leaders
HUD’s proposed rule clearly states that RAD PHA compliance includes executive pay transparency. This measure will require accurate reporting, increased documentation, and public accountability if approved.
With this in mind, now is the perfect time for RAD PHAs to assess readiness, assign responsibilities, and weigh in during the comment period.
