HUD Publishes Public Housing Cash Management Frequently Asked Questions

March 18, 2026 — On March 12, HUD published a Frequently Asked Question (FAQ) document covering new SF-425 requirements for public housing and mixed finance developments. In 2024 and 2025, HUD released a series of notices implementing cash management requirements and changing the way PHAs use and document Public Housing Operating Fund subsidy. These FAQs supplement previous public housing operating fund accounting notices, including:

• PIH Notice 2024-25 (provisions regarding returning interest earned on Federal Funds),
• PIH Notice 2025-20 (new SF-425 reporting requirements including order of expenditure, report submissions, reserve funds, and grant periods of performance), and
• PIH Notice 2025-22 (provisions regarding interest remittance).

PIH 2025-20 is the primary notice regarding cash management. The FAQs address pending questions regarding new accounting requirements and specify where HUD intends to issue additional regulations. NAHRO has encouraged HUD to release additional information and will continue to do so. Several key takeaways from the FAQs are below.

• Prospective application — the requirement to report using the SF-425 will begin with Calendar Year 2026 operating subsidy grants. No PHAs will need to submit SF-425s in the Public Housing Portal before April 30, 2027. Importantly, the notice does not directly address PHA reserves and whether operating reserves comprised of program revenue from years before CY 2026 could be affected. However, PHAs are reporting on grants per AMP per calendar year beginning in 2026. Interest remittance would also occur on a “current and prospective basis” based on PIH 2024-25.
• The tension between statute, regulation, and guidance — HUD notes there is no statutory or regulatory authority preventing PHAs from retaining non-rental income across years or using it flexibly but that it intends to issue regulations “in the future.” The notice explicitly notes that the guidance “does not address a PHA’s ability to draw down funds.” Although the notice prohibits PHAs from drawing down operating subsidy until program revenue is spent and there are invoices due in the next three days, the guidance that “PHAs must submit a supplemental response on line 12 any time their Cash on Hand amount is greater than the amount they will disburse within the next three business days from submission” is a “reporting request” due to HUD financial reporting requirements. PHAs would still be able to draw down subsidy as before. Additionally, the FAQ document adds that PHAs can draw down funds even if late rents are received.
• Rents — NAHRO members have highlighted the difficulty that spending rents first will pose as the amount of rent collected each month varies. HUD notes that PHAs should evaluate rents collected—not charged—for decision-making purpose.

The notice also discusses other topics, including: possible review and oversight mechanisms, federal share of expenditure fields, accounting bases, grant period of performance details, requests for reporting extensions, insurance settlements, and requirements for mixed finance developments.

Find the FAQs on the Operating Fund Cash Management HUD Exchange page.