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Administrative Plan 7/1/2025 Page 1-14 <br />Mandatory vs. Discretionary Policy <br />HUD makes a distinction between: <br /> Mandatory policies: those driven by legislation, regulations, current handbooks, <br />notices, and legal opinions, and <br /> Optional, non-binding guidance, including guidebooks, notices that have expired and <br />recommendations from individual HUD staff. <br />HUD expects PHAs to adopt local policies and procedures that are consistent with mandatory <br />policies in areas where HUD gives the PHA discretion. The PHA's administrative plan is the <br />foundation of those policies and procedures. HUD’s directions require PHAs to make policy <br />choices that provide sufficient guidance to staff and ensure consistency to program applicants <br />and participants. <br />Creating policies based upon HUD guidance is not mandatory but provides a PHA with a “safe <br />harbor.” HUD has already determined that the recommendations and suggestions it makes are <br />consistent with mandatory policies. If a PHA adopts an alternative strategy, it must make its own <br />determination that the alternative approach is consistent with legislation, regulations, and other <br />mandatory requirements. There may be very good reasons for adopting a policy or procedure that <br />is different than HUD’s safe harbor, but PHAs should carefully think through those decisions. <br />1-III.C. ORGANIZATION OF THE PLAN <br />The plan is organized to provide information to users in particular areas of operation. <br />1-III.D. UPDATING AND REVISING THE PLAN <br />The PHA will revise this administrative plan as needed to comply with changes in HUD <br />regulations. The original plan and any changes must be approved by the Board of <br />Commissioners of the agency, the pertinent sections included in the Agency Plan, and a copy <br />provided to HUD. <br />SAHA Policy <br />SAHA will review and update the plan as needed, to reflect changes in regulations, PHA <br />operations, or when needed to ensure staff consistency in operation. <br />EXHIBIT 1