PHA Must Compensate Owner for Cost of Submitting Comparability Study

Facts: Two site owners sued the Illinois Housing Development Authority (IHDA), alleging that IHDA breached its housing assistance payments (HAP) contracts by: failing to increase contract rents or by raising contract rents by less than the amount called for in the HAP contracts; reducing the automatic Annual Adjustment Factor (AAF) by .01 for units occupied by the same family in consecutive years; and requiring the submission of rent comparability studies without compensating the owners for the costs incurred in the submission of those studies.