Comment Submitted by John Roberto

The proposed 24 CFR 902.43(a) (6) requires projects to “…inspect their property in accordance with HUD-prescribed physical inspection procedures….” These procedures are not specified. They should be, either by inclusion within this subsection or incorporation by reference. As is, the subparagraph leaves readers uncertain as to exactly what HUD has prescribed. They no doubt will look to the cited 24 CFR part 5, subpart G, for a meaning of the phrase. They will be disappointed to find that the subpart, while the origin of the phrase at 24 CFR 5.705, offers no clue of its meaning. It also offers no other reference that could be used to research the phrase. If “HUD-prescribed physical inspection procedures” means the more stringent of Uniform Physical Conditions Standards or local codes, the subsection should say so. It should not be left open to varying interpretations by HUD personnel and its customers. In any case, it is important that this subsection fully describe the phrase, directly or through incorporation. Its description should not be left to a later notice that readers may or may not find or that may lack a firm regulatory basis.