HRA100%

HRA / Project delivery

Lesson 11: Relocation, labor standards and conflicts

14 practice questions · Sources reviewed October 4, 2026

Uses your browser's available voice.

Reading

Protect people affected by the project

Reconstruction changes where people can live while work occurs. Identify all occupants early, including tenants, informal arrangements and people in other structures. Do not assume that the person who applied is the only person affected. HOME requires reasonable steps to minimize displacement. Explain the proposed sequence and resolve a safe living arrangement before demolition or an irreversible move.

Relocation, labor standards and conflicts: four decision stagesIdentify people: Account for owners, tenants and other occupants before planning moves.; Determine applicability: Review relocation, contract-wide labor and project-wide Section 3 requirements.; Resolve interests: Disclose conflicts and obtain any required exception before commitment.; Retain evidence: Preserve notices, checks, clauses, approvals and compliance records.01Identify people02Determine applicability03Resolve interests04Retain evidence
Relocation, labor standards and conflicts: use each stage with its evidence before advancing.
  1. Identify people. Account for owners, tenants and other occupants before planning moves.
  2. Determine applicability. Review relocation, contract-wide labor and project-wide Section 3 requirements.
  3. Resolve interests. Disclose conflicts and obtain any required exception before commitment.
  4. Retain evidence. Preserve notices, checks, clauses, approvals and compliance records.

Owner-occupants and tenants do not automatically have identical relocation rights. The Uniform Relocation Assistance rules contain an exclusion for specified owner-occupant moves resulting from rehabilitation or demolition of their property, while HOME temporary-relocation provisions expressly address residential tenants. The research does not establish that TDHCA will pay an HRA owner's temporary housing in every case. Obtain a written applicability and funding decision; do not promise reimbursement or tell an owner to waive rights using a homemade form.

Build a move and return plan

The proposed planning worksheet records who must move, accessibility and household needs, the expected sequence, suitable housing, storage, utilities, transport, costs, responsible payer, notices and the conditions for return. Use current required forms, including applicable re-occupancy and informed-consent items. The worksheet is a coordination aid, not a substitute for required relocation notices or professional determinations.

Coordinate delays with the living plan. A construction extension does not automatically extend a lodging reservation or provide additional assistance. Keep the household informed through its accessible contact method. If a tenant or other protected occupant may be displaced, elevate the matter before making commitments and obtain the required relocation expertise. Section 104(d) can apply to HOME; it is not exclusively a CDBG issue.

Assess labor requirements at the correct level

Under 24 CFR 92.354, a construction contract covering twelve or more HOME-assisted units triggers the specified federal labor-standard requirements. One contract can cover more than one project. Do not assess only the current household when a procurement bundles multiple homes. Deliberately splitting contracts within one project to avoid the requirements is prohibited. The applicability decision belongs in procurement planning, before bid documents are issued.

Section 3 uses a different framework under 24 CFR Part 75. HUD's February 2026 notice sets the general housing and community-development project threshold at $300,000, effective March 16, 2026. The funding and project definitions matter. Do not use a single contractor's invoice as the entire project measure, and do not treat an older $200,000 printed threshold or the NOFA's Part 135 reference as the current inflation-adjusted authority. Obtain TDHCA direction on grouping HRA activities when needed.

Identify conflicts before funds are committed

Procurement and beneficiary conflicts need review under their applicable provisions. Staff, board members and contractors should disclose relevant interests through the approved process. Disclosure alone does not cure a prohibited conflict. Current 23.26(6) requires the necessary Department submission for a HUD exception where applicable and prohibits commitment or reservation for the affected household until HUD grants the exception.

The proposed GCHS control is to separate inspection and estimating from a person's own bidding interests, assign an independent reviewer and stop the affected procurement or reservation while the issue is resolved. Do not let the person with the interest decide whether it matters. Document the facts, applicable rule, disclosure, legal review where required and authorized outcome. Protect the household's private information during any public-disclosure process.

Preserve compliance evidence

Conduct and retain the required excluded-party checks for relevant firms and persons, with enough identification to avoid confusing similar names. Record date, search result and review. Maintain required contract clauses, labor records and program certifications when applicable. A certificate signed at final draw does not fix an omitted requirement that should have governed bidding or construction.

Use a compliance applicability matrix listing relocation, labor standards, Section 3, lead, asbestos, flood insurance, conflicts and other cross-cutting requirements. For each item, record applies, does not apply or unresolved, with its basis and reviewer. An unsupported "not applicable" is a gap, not evidence. Carry unresolved items into the project hold-point log and resolve them before the affected action.

Work the case

A proposed construction contract covers thirteen HOME-assisted homes, though each household has a separate activity file.

Review the decision

Review Davis-Bacon applicability at the construction-contract level. Separate household files do not reduce thirteen assisted units to one. Ensure the appropriate labor provisions and administration are included before procurement and execution. Assess Section 3 separately using its own project and funding framework.

Apply it in the file

Authorities for this lesson

Practice questions

1. Who should be identified before demolition planning?

  1. Only the named applicant
  2. Only the contractor
  3. All occupants affected by the project
  4. Only the deed's first signer

2. Do owners and tenants always have identical relocation rights?

  1. Yes, without exception
  2. Yes, if the home is old
  3. Yes, if assistance is federal
  4. No

3. Can staff promise HRA payment for every owner's temporary lodging?

  1. No
  2. Yes, automatically
  3. Yes, after a verbal contractor promise
  4. Yes, if the owner keeps a receipt

4. Does Section 104(d) apply only to CDBG?

  1. Yes, always
  2. No
  3. Yes, because HOME is a grant
  4. Yes, for all reconstruction

5. What unit count triggers the cited HOME construction-contract wage provisions?

  1. Every single-house invoice
  2. Only one hundred units
  3. Twelve or more HOME-assisted units
  4. Only rental towers

6. A contract covers thirteen assisted homes in separate files. What should staff assess?

  1. Each file as if no other home exists
  2. Only the most expensive home
  3. Only the first contractor payment
  4. The full contract's labor applicability

7. May a project be split into contracts to evade wage requirements?

  1. No
  2. Yes, whenever convenient
  3. Yes, if each contract is short
  4. Yes, with a different invoice number

8. What is the 2026 general Section 3 project threshold stated in HUD's notice?

  1. $200,000
  2. $300,000
  3. $50,000
  4. $1,000,000

9. Does Section 3 use exactly the Davis-Bacon unit-count test?

  1. Yes, both use twelve units
  2. Yes, both use one invoice
  3. No
  4. Yes, both depend only on the owner

10. Does disclosure alone cure a prohibited conflict?

  1. Yes, always
  2. Yes, if a friend witnesses it
  3. Yes, after reimbursement
  4. No

11. When must the required HUD conflict exception be obtained?

  1. Before the affected commitment or reservation
  2. Only before final payment
  3. After the house is demolished
  4. After the staff member retires

12. What belongs with an exclusion check?

  1. Only a contractor's verbal assurance
  2. Identity, date, result and review
  3. Only a blank certification
  4. Only a screenshot without a name

13. Is an unsupported not-applicable box adequate?

  1. Yes, if all boxes are checked
  2. Yes, if the file is large
  3. No
  4. Yes, if the contractor signs

14. What must a move-and-return plan clarify?

  1. Only the demolition date
  2. Only the contractor's hotel preference
  3. Only the final paint schedule
  4. Housing needs, timing, payer and return conditions

Glossary

URA
Uniform Relocation Assistance and Real Property Acquisition Policies Act framework.
Section 104(d)
Additional anti-displacement and relocation requirements that can apply to HOME.
Davis-Bacon
Federal prevailing-wage requirements when applicable.
Section 3
HUD economic-opportunity requirements under Part 75.
Conflict of interest
An interest prohibited or requiring review under applicable rules.
Exclusion check
A documented review of applicable debarment or exclusion status.
Previous lessonNext lesson

Print the field checklist · Sources and unresolved decisions