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Administrative Plan <br />Housing Authority of the <br />City of Santa Ana <br />Effective: January 2011 <br />Submitted to HUD: <br />ABOUT THE REFERENCES CITED IN THE ADMINISTRATIVE PLAN <br />AUTHORITIES IN THE ADMINISTRATIVE PLAN <br />Authority for the Housing Authority of the City of Santa Ana's (SAHA's) policies is derived <br />from many sources. Primary among these sources are regulations and guidance issued by HUD. <br />State law also directs SAHA policy. State law must be followed where such law exists and does <br />not conflict with federal regulations. In the absence of legal requirements or HUD guidance, <br />industry practice may lead to SAHA policy. <br />HUD <br />HUD provides the primary source of SAHA policy through federal regulations, HUD Notices <br />and handbooks. Compliance with federal regulations, current HUD Notices and HUD handbooks <br />is mandatory. <br />HUD provides nonmandatory guidance to PHAs through HUD published guidebooks. Expired <br />HUD Notices and handbooks also provide guidance for SAHA policy. Following HUD guidance <br />is optional, as long as SAHA policies comply with federal law, federal regulations and <br />mandatory policy. Because HUD has already determined that the guidance it provides is <br />consistent with mandatory policies, SAHA reliance on HUD guidance provides the SAHA with a <br />"safe harbor." <br />Content contained on the HUD website can provide further clarification of HUD policies. For <br />example, FAQs on the HUD website can provide direction on the application of federal <br />regulations to a specific pattern. <br />State Law <br />Where there is no mandatory federal guidance, SAHA must comply with state law, if it exists. <br />Where state law is more restrictive than federal law, but does not conflict with it, SAHA will <br />follow the state law. <br />Intro-i <br />iii29i2oio <br />