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• The Comprehensive Needs Assessment is a description of current and future financial resources and needs of certain multifamily projects [403].TX:
  
• The CNA involves project residents in its development, from start to finish [404].TX:
  
• It is based on a thorough and detailed physical inspection of the project.TX:
  
• The Comprehensive Needs Assessment includes a statement of any assistance needed under programs administered by the Department [403].TX:
  
• It describes available resources for meeting the current and future needs of the project and the likelihood of obtaining such resources [403].
  

Such resources include assistance from private foundations, State and local governments, any HUD programs, rent increases, refinancing, Flexible Subsidy, Loan Management Set Aside (LMSA), and Section 241 Loans:

• The CNA also includes descriptions of modernization needs and activities, descriptions of supportive services needed and supportive services provided, descriptions of security needs, and descriptions of any personnel needs of the project, including service coordinators and security staff [403]..TX:
  
• In the future, funds for Flexible Subsidy and Loan Management Set Aside Section 8 assistance will be targeted to address the needs identified in the CNA process and to meet emergency needs in properties, rather than being awarded through competitive NOFAs [409]. The Department will use CNAs to inform itself and Congress of the condition of the portfolio and to use the information for funding of assistance.

IV. WHO IS COVERED. The owners of the following kinds of projects are required to submit a Comprehensive Needs Assessment unless:

1) they are eligible for assistance under the HOME Investment partnership Act or,

2) they have received or are receiving incentives or if they have given a Notice of Intent under the Low-Income Housing preservation and Resident Homeownership Act of 1990, or the provisions of the Emergency Low Income Housing preservation Act of 1987 (as in effect immediately before November 28, 1990, the date of the enactment of the Cranston-Gonzalez National Affordable Housing Act [401(1)(B)]:

• Section 221(d) (3) MIR (Market Interest Rate) projects.
  
• Section 221(d) (5) BMIR (Below Market Interest Rate) projects.
  
• Section 236 projects with mortgages insured, assisted, or held by HUD (including State/Local Agency Section 236 projects).
  
• Any housing that is reserved for occupancy by very low-income elderly persons pursuant to section 202(d)(1) of the Housing Act of 1959 [401(1)(A)(i)];
  
• Any housing that is assisted under the provisions of section 202 of the Housing Act of 1959 (as such section existed before the effectiveness of the amendment made by section 801(a) of the Cranston-Gonzalez National Affordable Housing Act)[401(1) (A) (ii)];..TX:
  
• Any housing that is financed by a loan or mortgage insured, assisted, or held by the Secretary or a State or State agency under Section 236 of the National Housing Act [401(1)(A)(iii)];.TX:
  
• Any housing that is financed by a loan or mortgage insured or held by the Secretary pursuant to section 221(d) (3) of the National Housing Act [401(1)(A)(iv)]; or
  
• Any multifamily housing project that was designed or designed to serve, or is serving, elderly persons or families and is assisted under a program administered by the Secretary [401(2)].
  

If a Notice of Intent has been filed, but no incentives received, the Notice of Intent may be withdrawn, in writing. If such Notice has been so withdrawn, the Owner is then eligible to participate under the prepare a project's CNA [402]. This entity, the "Needs Assessor," also must have an arms-length, non-identity of interest relationship with the project's managing agent (if any). The entity that the owner engages must have the skills needed to prepare the CNA. These skills include the capability to conduct (or have conducted) a thorough physical inspection of the property, to prepare capital budgets, to work with residents in eliciting their responses, and to take assessments of resources and the project's financial, physical, and supportive services needs, etc.

• Project owners are to use private, independent, professional entities or persons qualified to conduct and prepare the Comprehensive Needs Assessment.
  
  
• A project mortgagor itself may not prepare the CNA [402] although the owner is required to submit the project's CNA..TX:
  
• The entity conducting the CNA, the "Needs Assessor," is required to treat tenant information and concerns in a confidential manner.
  
• The entity that prepares and submits the CNA must sign and date it, certifying that it is accurate and correct to the best of its knowledge and belief as of the date of the CNA.

VI. WHO PAYS FOR THE COMPREHENSIVE NEEDS ASSESSMENT. The project's mortgagor pays for the CNA. By statute [404], the project owner may use up to $5,000 of project funds to pay for the CNA where funds are available. Up to this $5,000 limit, HUD will authorize releases from Residual Receipts accounts and Reserve Fund for Replacements accounts where a project's operating account is inadequate to pay. for the CNA. The Department expects that smaller projects (those under 50 units) should spend no more than perhaps about $2,500, projects larger than 75 units might need to spend amounts nearer the $5,000 limit. While CNA preparation costs are considered to be an eligible project expense, i.e., paid or payable from project funds, CNA preparation costs may not, by statute [404], be included as a cost or expense used to calculate rent increases.