Construction teams want units empty as early as possible. RAD sets a hard floor. Under Section 6.8 of the RAD relocation Notice, a PHA may not begin physical relocation until the later of:
- the effective date of the RAD Conversion Commitment (RCC), and
- the expiration of the applicable RAD Notice of Relocation period (30 or 90 days, depending on the type of move).
The 2016 Notice moved this trigger earlier than the prior rule, which tied relocation to closing. That change gives projects more room to stage moves ahead of construction, but only after the RCC is in hand.
Working backward from your construction start
Because the rule is "the later of," the critical path usually runs like this:
- Get the RCC issued and effective.
- Deliver RAD Notices of Relocation so the 30- or 90-day period expires when you need the first units vacant.
- Sequence moves so the first phase of construction has the units it needs.
If the RCC is delayed, every move date shifts with it. Build the relocation schedule as a dependency of the RCC, not as a fixed calendar.
What does not count as "beginning relocation"
Planning activities can and should start well before the RCC: resident surveys, needs assessments, identifying temporary housing, advisory meetings, and issuing the RIN and GIN. What cannot happen early is the physical move itself.
Early moves and resident choices
The GIN warns residents that moving before receiving formal notice of eligibility could jeopardize relocation assistance. Advisory staff should repeat that message so households do not move on their own and lose benefits.
Checklist
- RCC effective date confirmed in writing.
- Each household's notice period calculated from documented delivery dates.
- Construction schedule reconciled to the earliest permissible move date.
- Any request for an exception discussed with the RAD Transaction Manager before acting.
Sources
Disclaimer: This content is for general informational purposes only and is not legal advice. Do not rely on it as a substitute for advice from a qualified attorney. Reading it does not create an attorney-client or consulting relationship. HUD guidance changes; confirm current requirements with your RAD Transaction Manager and counsel before acting. PHA Consultant is not a law firm and is not affiliated with HUD.