I am writing this comment both as a housing advocate and a landlord who rents to a tenant with a voucher. I support the adoption of this guidance and see it as an important step towards helping put the choice in Housing Choice Voucher where many have been denied in the past. I see many comments from those opposing this guidance, specifically the language stating that landlords must only consider the tenant’s portion of the rent in a potential risk assessment. These commenters are basically saying that the cushion for living expenses and unexpected costs created by whatever income multiplier they require does not work when only considering the tenant’s portion of the rent because it is a smaller number. IE 3 X $1,000 requires $3,000 monthly income whereas 3 X $250 would only require $750. This is admittedly a large difference. This analysis however is flawed because it completely ignores the fact that the tenant’s portion of the rent, (ie that $250) is not pulled out of thin air. It is set by a PHA or other entity based on a household's income. This amount the tenant is responsible for is typically set at around a 3^rd of the tenant’s income, thus leaving that tenant with 2/3 of their income for living expenses. This ratio is the accepted standard nationwide of what is considered affordable housing for a particular household. It may not result in the gross numbers a landlord wants to see, but the fact that the PHA continually adjusts a household’s portion of the rent (whether it goes up or down) should give landlords ample assurance that a sufficient cushion is there.

On the subject of the administrative burden of working with a PHA, I can only offer my personal experience. As the guidance states, there really is not much paperwork that is required from a landlord to start receiving payments and the inspection standards are reasonable. In fact, though the process certainly took a few days, I was surprised by how easy it was to get plugged into the system and I have not had any problems yet. If my tenant’s income changes, their portion of the rent is adjusted accordingly, and thus far they have been able to pay, even with one income earner losing their job during the pandemic. And as a landlord, I do support the 15-day exemption once a complete RFTA has been submitted. I do believe in the accountability of PHA’s to do their part to make this work as well. I would encourage landlords and anyone else opposing the guidance to stop fighting this and grasping at straws about income threshold requirements. I think many will be surprised by the experience they have once they begin renting to voucher holders.