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Facts: An owner leased a rental housing facility for elderly residents to a local public housing authority (PHA). The PHA in turn entered into a housing assistance payment (HAP) contract with HUD to provide low-income housing under an amendment enacted in 1974 to the Housing Act of 1937. HAP contracts establish an agreed “maximum monthly rent” the property owners will charge residents, as supplemented by HUD's assistance payments to the owners.
