COC and ESG Rent Reasonableness and FMRs

The links below explain the key relationship between an area’s “rent reasonableness” determination and the published FMR for projects supporting leasing costs and/or rental assistance under the COC Program and ESG program. It’s important to note the differences between housing projects funded under the Leasing Budget Line Item and those funded under the Rental Assistance Budget Line Item.

Recipients must establish their own written policies and procedures for documenting comparable rents and ensure that they are followed when documenting rent reasonableness in the case file. A recipient may require all subrecipients to use a specific form or a particular data source. Use of a single form to collect data on rents for units of different sizes and locations will make the data collection process uniform. A sample form is attached.

Since CPD staff is monitoring these programs for the first time using the new checklists and specifically for ESG Rapid Rehousing activities and COC Permanent Supportive Housing projects, it’s prudent to have a clear understanding of this area.