In August 2015, the Department issued a new Section 8 Renewal Policy Guide.  Section 9-23 of the Guide provides instructions for comparing the median rents as derived by the appraiser in a rent comparability study (RCS) with Census Bureau estimates of the median rents in the project’s zip code.  Should the rents in the owner’s study exceed 140 percent of the median zip code rent threshold, then HUD would secure a third party to create a RCS for comparison purposes.  When the Department issued the Guide, our office also published the list of median zip code rents as of December 2014.