HUD recently issued Notice PIH-2018-13 providing additional information on calendar year (CY) 2017 executive compensation reporting. The notice specifically instructs PHAs on how to use the HUD-52725 Form that reports executive compensation for CY 2017. PHAs must report compensation for the top management official, the top financial official, and the highest compensated employee who is neither the top management official nor the top financial official. PHAs must submit their CY 2017 executive compensation data to HUD using form HUD-52725, which is a web-based form PHAs submit online through HUD’s Secure Systems portal.

The requirements apply to all PHAs that administer a public housing or Section 8 program, including PHAs that have converted their entire public housing portfolio through RAD that still receive funding sourced from Section 8 or 9 of the U.S. Housing Act of 1937. HUD has noted in the guidance that any PHA that fails to comply with the PHA executive compensation reporting requirements will be in violation of the PHA’s Annual Contributions Contract (ACC).