Download in PDF format:

Full, standard reference version

Full, highlighted version to emphasize changes in policy		  
     
     

Documentation of REAC inspection policy clarifications and changes has slowly broken down over the last several years to the point that it was housed in several different documents that had differing authors and formats.  These also contained statements that could be read as contradicting each other in some cases.  The primary clarification document was Compilation Bulletin 4.0 version 2, but there were several other supporting documents published at random intervals.

 

The two most distressing problems in this was that 1) the overly vague and broad non “industry standard repairs” (NIS) memo seemed to throw out all the rules and leave defect definitions to the imagination of the inspector and, 2) the real definitions used by our REAC inspectors are actually contained in the decision trees embedded in the RAPID 4.0 software, which have never been published in any printable, distributable document.  Even if one was familiar with all the various, separate policy documents, one did not have access to the decision trees except by installing the public version of the software on their computer and referring to the decision trees there.

 

Finally, REAC has published Compilation Bulletin 4.0, version 3, which is supposed to draw together the still useful content of all previous documents and to supersede them with some new interpretations of policy and new answers to old questions.  This document is available in two versions, which are identical except that one version has added highlighting to conveniently identify and emphasize the changes and new information.

 

The NIS policy that became effective in August 2016 is still with us.  It appears at the bottom of page 4, continuing into page 5 in a newly abbreviated, but still as vague-as-ever form.  REAC scores have dropped across the board in both the multi-family and public housing segments of the housing industry since this policy went into effect, allowing inspectors to cite defects for any repair that the inspector thinks “doesn’t look right” and requiring the inspector in some cases to enter false data into the inspection report to override the decision trees.
 
Important changes...

The new Comp Bulletin instructs inspectors that structures like the one depicted below can now be considered multiple buildings instead of being considered a single building as has been the rule for many years.  This has the potential to greatly reduce the scoring value of building-level defects like certain Systems defects (sprinkler and electrical defects) and certain Exterior defects (wall and door damage.)





External stairs leading into building Common areas are now to be considered elements of Common Areas rather than elements of the Site, also reducing scoring values in nearly all cases.  Where such steps lead to a single Unit, they become part of the Unit.		  
     
  Steps not associated with a building's Common Areas will remain part of the Site.






  
  REAC has retained and finally put into writing the policy that where doors have multiple locking devices, a Level 3 Door Hardware issue will be cited for any inoperable locking device, regardless of the fact that remaining functional locks can still secure the door. 

For example, an optional and additional but inoperable chain lock can be cited as L3 Hardware.

This is apparently contrary to the written UPCS L3 definition that says "a door cannot be locked" and we have maintained that it is an incorrect interpretation of the UPCS up until now.

The bright side of REAC's decision to put this in writing is that they have also specified that this does not apply to resident-installed chain locks.  Where chain locks are not consistently present and it appears that the resident has added their own device, this is NOT a defect.