Lower rents to HCV landlords through demonstrating non-compliance with "rent reasonableness"

The first approach to reform responds to the documented observation that market rents in Woodlawn are, on average, lower than the rent received by Housing Choice Voucher landlords. The over-payment of subsidy creates an advantage for accepting vouchers in low-rent neighborhoods like Woodlawn over other neighborhoods. By reducing the rent that a landlord would receive, it would also reduce the profits of landlords providing lower-quality management in Woodlawn and assist more households. As discussed in Chapter 5, HUD has a requirement of Òrent reasonablenessÓ that is intended to prevent a landlord from charging a Housing Choice Voucher recipient more than they charge for un-assisted units in the same building (assuming they have unassisted units) and what identical unassisted units would receive on average in the market place.

Because of anecdotal evidence that tenant and CHA payments are more for units located in the same building, statistical evidence that assistance payments are higher than the market rate and the presence of clear regulations that forbid this, the natural solution would be better enforcement. This could include conducting a detailed study/inventory of current apartments rented by HCV residents along with non-assisted apartments that would provide clear evidence of unreasonable rents. It could be argued that this approach reduces the rent that ÒgoodÓ landlords receive in Woodlawn, which would have a depressing effect on housing options. However, these landlords provide a better service and have a credible case for charging more to Housing Choice Voucher recipients. Indeed, helping the market to better distinguish landlords on the basis of management quality would certainly be a positive side effect.

Monitor and support Sub-Area FMR Demonstration

The second approach revolves around the Small Area Fair Market Rent demonstration discussed in Chapter 4. If adopted, this program would reduce the maximum rent any landlord could charge a Housing Choice Voucher recipient in Woodlawn. It would also increase the rent a landlord could charge in a higher-rent area within the region, creating more rental opportunities for assisted households. If successful, this program would work towards the same objective as the first approach, Unlike the first approach, however, it would not as effectively allow apartment and management quality to be a source of differences in rent, since the maximum rent will be reduced for all landlords regardless of quality. Less discretion would give way to a more uniform approach to reducing the incentives for targeting voucher holders.