Guidance on DOT/DORC Requirements Guidance Released

Recently, HUD’s Office of Public and Indian Housing released Notice PIH 2019-14 (HA) titiled “Declaration of Trust or Declaration of Restrictive Covenants (DOT/DORC) Requirements. The notice reminds PHAs of their continuing legal responsibility to ensure a valid DOT/DORC is recorded against all of their public housing property, requires PHAs to be in full compliance with the DOT/DORC, and provides guidance on adding and removing public housing units and other public housing property from IMS/PIC and ACC.

The notice focuses specifically on the terms and compliance of the DOT/DORC, monitoring of the DOT/DORC, and the release of the DOT/DORC if PHAs close out their public housing portfolios via the Rental Assistance Demonstration (RAD), Section 18 demolition/disposition, Section 22 voluntary conversion, or other public housing repositioning options. The notice also details how public housing agencies should add or remove public housing units to their Annual Contributions Contract (ACC), how to terminate the ACC, and how to document ACC removals in IMS/PIC.