the ‘perfect’ tenant file - mahma€¦ · 1 the ‘perfect’ tenant file andrew hill...

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The ‘Perfect’ Tenant FileAndrew Hill

[email protected]

Agenda

• What does the Handbook say?• The MOR File Review• Suggested organization of a tenant file

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CHAPTER 3. ELIGIBILITY FOR ASSISTANCE AND OCCUPANCY

3-9 Disclosure of Social Security Numbers• When determining the eligibility of an individual who meets

the exception requirements for SSN disclosure and verification, documentation must be obtained that verifies the applicant’s exemption status. A certification from the tenant is not acceptable verification of the exemption status. This documentation must be retained in the tenant file.

3-11 Consent and Verification Forms• A current form HUD-9887 must be on file before owners

access the EIV employment and income information for a tenant.

CHAPTER 4. WAITING LIST AND TENANT SELECTION

4-4 Tenant Selection Plan

• Retention of information. Owners must retain all documentation relating to an individual’s domestic violence, dating violence or stalking in a separate file that is kept in a separate secure location from other tenant files.

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4-22 Record-Keeping

• The owner must retain current applications as long as their status on the waiting list is active.

• Once the applicant is taken off the waiting list, the owner must retain the application, *form HUD-92006 completed by the applicant*, initial rejection notice, applicant reply, copy of the owner’s final response, and all documentation supporting the reason for removal from the list for three years.

• When an applicant moves in and begins to receive assistance, the application *and form HUD-92006 completed by the applicant* must be maintained in the tenant file for the duration of the tenancy and for three years after the tenant leaves the property.


4-22 Record-Keeping

• All files must be kept secure so that personal information remains confidential.

• The applicant’s or tenant’s file should be available for review by the applicant or tenant upon request or by a third party who provides signed authorization for access from the applicant or tenant. EIV income data found in the tenant’s file has additional disclosure requirements

• The owner must dispose of applicant and tenant files and records in a manner that will prevent any unauthorized access to personal information, e.g., burn, pulverize, shred, etc.

• Owners must keep records and submit reports and information as required by HUD to enable HUD and the owner to ascertain whether the owner has complied, or is complying with, nondiscrimination requirements.

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CHAPTER 5. DETERMINING INCOME AND CALCULATING RENT

5-23 Record-Keeping Procedures

Owners must keep the following documents in the tenant’s file at the project site:

• All original, signed forms HUD-9887 and HUD-9887-A;

• A copy of signed individual consent forms;

• A copy of the EIV Income Report, regardless of whether or not any income is reported for the household, along with the HUD-50059 and any other documentation obtained supporting income and rent determinations; and

• Third-party verifications received from third-party sources.



B. Owners must maintain documentation of all verification efforts throughout the term of each tenancy and for at least three years after the tenant moves out

C. The tenant’s file should be available for review by the tenant upon request or by a third party who provides signed authorization for access from the tenant.

Note: EIV data of an adult household member may not be shared (or a copy provided or displayed) with another adult household member, unless the individual has provided written consent to disclose such information.

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• Owners must maintain applicant and tenant information in a way to ensure confidentiality. Any applicant or tenant affected by negligent disclosure or improper use of information may bring civil action for damages and seek other relief, as appropriate, against the employee. Forms HUD-9887 and HUD-9887- A describe the penalties for the improper use of consent forms.

• Owners must dispose of tenant files and records in a manner that will prevent any unauthorized access to personal information, e.g., burn, pulverize, shred, etc.

CHAPTER 6. LEASE REQUIREMENTS AND LEASING ACTIVITIES

6-5 Lease Requirements

The following documents must be attached to the lease:

• HUD-50059 signed by the tenant and the owner;

• HUD-50059-A signed by the owner and, when applicable, by the tenant.

• Move-in inspection report signed by both the owner and tenant;

• House Rules, if such rules have been developed by the owner;

• Lead-based paint disclosure form (if applicable);

• Pet rules (if applicable);

• Owner’s Live-in Aide addendum (if applicable).

• Owner’s Police or Security Personnel addendum (if applicable);

• HUD issued (VAWA) Lease Addendum (Section 8 only).

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CHAPTER 6. LEASE REQUIREMENTS AND LEASING ACTIVITIES

LEASE REQUIREMENTS AND LEASING ACTIVITIES

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CHAPTER 8. TERMINATION

8-7 Termination of Assistance Related to Establishing Citizenship or Eligible Immigration Status

The owner must retain for a minimum of 5 years the following documents that may have been submitted by the tenant or provided to the owner as part of the DHS appeal or the informal hearing process:• The application for financial assistance;

• The form completed by the tenant for income re-examination;

• Photocopies of any original documents (front and back), including original DHS documents;

• The signed verification consent form;

• The DHS verification results;

• The request for an DHS appeal;

• The final DHS determination;

• The request for an informal hearing; and

• The final informal hearing decision.

CHAPTER 8. TERMINATION

8-14 Drug Abuse and Other Criminal Activity

C. Procedures for Accessing Criminal Records

14. Criminal records obtained by the owner are to be maintained confidentially, not misused or improperly disseminated, and destroyed three years after tenancy is terminated. Criminal records, including State lifetime sex offender registration checks, received for applicants who never move-in are to be retained with the application for three years.

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CHAPTER 9. ENTERPRISE INCOME VERIFICATION (EIV)

9-14 Retention of EIV Reports

A. Owners must retain:

1. The Income Report, the Summary Report(s) showing Identity Verification Status as “Verified” and the Income Discrepancy Report(s) and supporting documentation must be retained in the tenant file for the term of tenancy plus three years.

2. Any tenant provided documentation, or other third party verification of income, received to supplement the SSA or NDNHdata must be retained in the tenant file for the term of tenancy plus three years.

CHAPTER 9. ENTERPRISE INCOME VERIFICATION (EIV)

9-14 Retention of EIV Reports

A. Owners must retain:

3. Results of the Existing Tenant Search must be retained with the application:

a. If applicant is not admitted, the application and search results must be retained for three years.

b. If applicant is admitted, the application and search results must be retained in the tenant file for the term of tenancy plus three years.

4. The master files for the New Hires Report, Identity Verification Reports, Multiple Subsidy Report and Deceased Tenants Report must be retained for three years.

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Master Files

AR/IR Monthly Quarterly

x

x

x

x

x

Title of ReportMust (or best practice) be accessed at least

App. Process W/in 90 Days of MI

Failed EIV Pre‐Screening Summary

Deceased Tenant Summary

Master File

New Hire Summary

Multiple Subsidy Summary

Failed Verification (Failed SSA Identity Test) Summary

AR/IR Monthly Quarterly

x

x

x

x

x

Title of ReportMust (or best practice) be accessed at least

App. Process W/in 90 Days of MI

Failed EIV Pre‐Screening Summary

Deceased Tenant Summary

Master File

New Hire Summary

Multiple Subsidy Summary

Failed Verification (Failed SSA Identity Test) Summary

* If the Existing Tenant Search Report was run for an applicant who did not move into the project (due to rejection or some other reason), this report must be retained in the applicant file for at

least 3 years.** If your Policies and Procedures (P&P) require the No Income Reports to be printed, they must

be stored in the respective tenant file. However, HUD does not require data retention for these reports

*** If a discrepancy is generated for a specific household on the project-wide New Hires or Multiple Subsidy Report, these Detail Reports must be retained in the corresponding tenant file along with

any supporting documentation for the resolution of the discrepancy. (If “New Hires Report” or "Multiple Subsidy Report" are underlined, this shows that there is an active link; the detail report

can be accessed by clicking on that link.)

Application Process W/in 90 Days of MI AR/IR Monthly Quarterly When Applicable As Described P&P

X

X X

X X

X X

X

X

X

X

Tenant File

Income

Income Discrepancy

No Income as Reported on 50059**

No Income Reported by HHS or SSA**

New Hires Detail***

Multiple Subsidy Report***

Must (or best practice to) be Accessed as least:Title of Report

Existing Tenant Search*

Summary

Application Process W/in 90 Days of MI AR/IR Monthly Quarterly When Applicable As Described P&P

X

X X

X X

X X

X

X

X

X

Tenant File

Income

Income Discrepancy

No Income as Reported on 50059**

No Income Reported by HHS or SSA**

New Hires Detail***

Multiple Subsidy Report***

Must (or best practice to) be Accessed as least:Title of Report

Existing Tenant Search*

Summary

Tenant Files

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MAT User Guide Chapter 77-7 Data Collection and Processing Procedures

E. Record-Keeping Requirements for HUD-50059, HUD-50059-A and Vouchers

1. Owners must keep the signed HUD-50059(s) and copies of the HUD-50059-A(s) for tenants from the time of move-in to move-out and for a minimum of three years thereafter. Owners may move older records off-site when files get large, however, upon request, the files must be made available for review by HUD or the Contract Administrator.

2. Owners must keep a signed paper copy of the subsidy vouchers for at least five years after HUD or the Contract Administrator action.

3. Owners must dispose of all files and records in a manner that will prevent any unauthorized access to personal information, e.g., pulverize, shred, etc.

Form HUD-9834Tenant File Checklist - Addendum A

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File Selection criteria

Head of household or spouse is elderly

Families with deductions for child care

Head of household or spouse is disabled

Families with deductions for medical expenses

Families with large amounts of assets

Families paying minimum rent

Families with zero income EIV income discrepancies

Families with dependents Each bedroom size in the project

Families with students Receiving utility reimbursements

Families with live-in aides

• 1 Addendum A is filled out for each file reviewed.

• Only answer the questions that are relevant for the file type being reviewed.

• Make clear notes in the comment section.

• If a deficiency is corrected on-site after the file has been reviewed, go back to the Addendum A and note that the deficiency was corrected during the review.

Completing the Addendum A

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Addendum A: A. Household Information

•

• Is the application time stamped, or date and time written in and initialed by management?

• Are all questions on the application answered and completely filled in?

• Is the application signed and dated by all members in the household that were 18 at time of application?

• Is the application signed and dated by management if required by program type?

• Does the application require the applicant to list ALL states in which the applicants have lived?

• Is there a Certification of Completeness and Accuracy of info?

• What is the MI date?• Is a form HUD-92006 in the file?• Is the form HUD-92006 filled in and signed; or box checked that

applicant elected not to provide information and form signed?• Were tenants that were not offered this form with the application

or at MI provided the opportunity to provide this information at a recertification?

• Was the form obtained on the current version in effect at the time of execution?

• Effective date of VAWA should be effective date of lease.

A. Household Information

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• If move-in is after 1/31/2010, is there an Existing Tenant Search for each member of the household in the file?

• If move-in is after 1/31/2010 and the reports are missing, is there documentation in the file that EIV was not available during the time the application was being processed for admission?


• Are names, sex, birth dates, social security numbers, and, if applicable, alien registration numbers entered correctly on the HUD-50059?

• Are the relationship, race, ethnicity, and eligibility codes correct (refer to the HUD-50059 instructions posted with the form HUD-50059 on HUDCLIPS Items 38, 40, 41, and 46 for applicable codes)?

• Was there signed Consent? Check the AR too.


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• At move-in, was the unit the correct size for the household based on Occupancy Standards in the TSP and HUD requirements?

• Is the household currently in an appropriate unit size?

• If over-housed at move-in and/or currently over-housed:

– Is appropriate verification in the file documenting that the household is over-housed for an eligible reason?

– If not over-housed for eligible reason, have all appropriate actions been taken and is the house on the transfer list )if applicable?


• Is the property a pre-1981 or post-1981 universe?

• What are the actual income limits applicable to the property’s location MSA/County that were in effect at the time of move-in?

• Review fields 66-85 on the move-in or initial HUD-50059 and compare to the application, income and asset verifications in the file:

• Was all reported income and assets verified, accurately calculated, and correctly listed on the HUD-50059?


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• If tenant was not income eligible at move-in, was there a HUD approved waiver effective at the time of move-in?

• If no waiver in place at time of move-in, has HUD since issued a retroactive waiver for this tenant?

• Review fields 93 and 114 on the move-in or initial HUD-50059:


• Is there a form HUD-27061-H for each family member (including new members added to the household after MI)?

• Was the form(s) obtained on the current version that was in effect at the time of execution?

• Is all information on the top of each form filled in?

• Is both the race and the ethnicity section of each form filled in?

• If race and/or ethnicity information not filled in, is there a note that the tenant refused to provide race and/or ethnicity?


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• Is there a 9887 signed and dated by ALL adult members of the household that had not expired when verifications processed at the time of MI/IC and each AR?

• Is there a separate 9887A signed and dated for ALL adult members that had not expired when verifications processed at the time of MI/IC and each AR?

• Is each 9887A signed and dated by management? Was this signed PRIOR to obtaining information?


• Are the proper contact names and addresses listed in the top section of the 9887 (3 boxes at the top of the form)?

• Were the forms obtained on the current versions that were in effect at the time of execution?

• Was any member that turned 18 between certifications notified to come in to sign and date the 9887/9887A forms when they turned 18?

• Are 9887/9987A forms obtained at each AR ensuring the current forms on file are “unexpired” (expire 15 months after signed and dated)?


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• Was the household listed on any of the Multiple Subsidy Reports run and maintained in the master file by the O/A in the last 12 months?

• If so, is there a Multiple Subsidy Detail Report for the tenant in the file along with follow up documentation supporting any contacts made, information obtained, and determinations made as well as documentation to support any action taken


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• Was the household for the file being reviewed listed on any of the EIV Reports listed in this question run and maintained in the master file by the O/A in the last 12 months?


B. Verification

• Is there verification/documentation in the file for the SSN of all members that were in the household at move-in?

• Is there verification/documentation in the file for the SSN of all members?

• Under 6 added to the household after MI who did not have a SSN when added: is the file now documented?

• If a member is exempt from having to provide a SSN, is verification in the file documenting the exemption?

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• Is there a completed Tenant Declaration of Citizenship form properly signed and dated for all household members?

• Is there a tenant completed Family Summary sheet that includes all household members?

• Is there an O/A completed Owner Summary of Family sheet that includes all household members?

• If a member declared to be a non-citizen with eligible immigration status: • Have they signed the consent for verification of status?

• Is the proper documentation of eligible immigration status in the file along with the SAVE verification?

B. Verification

• What is the date of move-in? (criminal not required until 6/25/2001)

• Is there documentation in the file that a criminal background screening as well as a screening for eviction from federal housing due to drug activity has been conducted for all states the applicant has resided?

• Are the screenings obtained in accordance with the O/As Tenant Selection Plan as well as HUD requirements (O/A is allowed to create more stringent screening requirements)?

• Did the applicants/tenants screened sign a consent form prior to the screening?

B. Verification

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• What is the date of move-in (sex offender registration screenings not required until 6/25/2001)?

• Is there documentation in the file that a sex offender registration screening has been conducted in the state for which they are applying for housing as well as all states the applicant has resided?

B. Verification

• Is there any additional screening requirements outlined in the TSP (credit, residential/landlord history, references, home visits, etc…)?

• If so, are these additional screenings in the tenant file for all members that were adults at the time of move-in?

• Are the screenings obtained in accordance with the O/As TSP?

• Based on the screenings obtained, did the household meet the additional screening criteria outlined in the O/As TSP to be admitted to the property?

B. Verification

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Disability status• What is the applicable definition of disability for the property?

• If the review is being done for a disabled only or a elderly and disabled property, is admission of disabled applicants limited to a specific type of disability?

• Did the tenant report that they or a member if the household meet the definition of disability for the property’s program type?

B. Verification

Student status• Are applicants/tenants given the opportunity to report student

status for each member of the household at MI, IC, AR, and IR?

• If a member of the household other than a dependent was reported by the applicant/tenant as being a student, is there follow up documentation confirming if the member is a student?

• If the member is a student, has documentation been obtained from the applicant/tenant as well as verifications, if necessary, to determine if the student meets one of the exceptions to be considered eligible for assistance?

B. Verification

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Age of occupants• Is there proper verification of age for each member of the

household in accordance with the O/A policies and HUD requirements?

• If this is an elderly property, or the file being reviewed is for a tenant who is occupying a unit that is restricted to only elderly

• Spouse at least 62 on the date of move-in?

• If not, was there a HUD approved age wavier in place?

• If approved waiver is in place, review the HUD-50059. Is the waiver type code correct?

B. Verification

• What is the program type for the property being reviewed?

• What is the move-in date?

• Does the property have HUD approved modified lease?

– If so, when was the modifications approved?

• If the O/A does not have an approved modified lease, is the correct HUD Model Lease and current version for the program type being used?

C. Lease

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• Is VAWA Addendum in the file as a lease attachment?

• Is the VAWA Addendum properly filled in correct information and dates?

• If HUD has issued additional lease addendums for required use, have they been implemented in accordance with HUD regulations?

C. Lease

• Are the original the lease and all original addendums in the file properly signed and dated by all adult members of the household and management?

• Are the current leases and addendums signed and dated by all adult members of the household and management?

• Were new adult members added to the lease?

• If there was a unit transfer, was a new lease executed for the new unit that was signed and dated by all adult members of the household and management?

C. Lease

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• House Rules• Pet Rules• Lead Paint Disclosure Form• Live-in Addendum• Move-in Inspection Report• HUD-50059’s and HUD-50059-A’s• Other HUD-approved Addendums or Attachments to

the Lease

C. Lease

• What is the program type for the property

• Was the correct SD for the program type collected?

• If a payment agreement was established, was/is it being enforced and is the tenant paying installments as required?

• Does the amount of the SD collected match the amount of the SD listed in other documents in the file?

C. Lease

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• What is the program type for the property?

• If applicable, does the tenant have a pet?

• Was the correct pet deposit for the program type collected?

Note: This question is only applicable to elderly or disabled properties.

C. Lease

• What is the program type for the property?

• If applicable, does the tenant have a pet?

• If required for the program type, was the pet deposit allowed to be paid in installments ($50 down $10 monthly)?

• Are the payment amounts correct?

• Is the payment agreement being enforced by the O/A and payments consistently be made by the tenant?

C. Lease

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• Move-in Inspection (must have decent, safe, sanitary language)

• Annual Inspection– Annual Inspections are commonly not maintained in the file,

but in a separate maintenance file or inspection file which is acceptable as long as they are made available.

C. Lease

• Was an Initial Notice provided at MI and each AR, signed and dated by tenant and management, and the original maintained in the file?

• If an annual certification has been completed or if the next annual certification for the file being reviewed is within 120 days, were the recertification reminder notices provided timely as required and dated copies maintained in the file?

• Do the notices contain accurate information (such as cut off date) and include all required information?

D. Certification/Recertification Activities

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• If an AR, does the recertification month match the MI month (or IC month, if applicable) and was the HUD-50059 signed prior to the effective date by all required parties?

• If an IR, was the effective date correct?

• Was the recertification processed in a timely manner with regard to when the tenant reported for the recertification?


• Are the HUD-50059s and HUD-50059As in the file that are reviewed signed and dated by all adult household members and management?

• Is there documentation in the file regarding extenuating circumstances if a signature is missing? Is the box on the 50059 checked?


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• Did the re-certifications reviewed result in an increase to the tenant rent?

• If so, did the tenant comply with recertification requirements (e.g., reported for annual recertification by the cutoff date; or changes in a timely manner)?

• If so, was a dated written notice of the increase in the file?


• Questions D. 5. – D. 7 (next slide) should be verified through EIV. These three questions ask the reviewer to check the type of verification used by the O/A.

• Review fields 66-74 on the form HUD-50059 and compare it to the documentation and verifications obtained to determine if wage information on the HUD-50059 is correct.


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• Review fields 66-74 on the form HUD-50059 and compare it to the documentation and verifications obtained to determine if wage information on the HUD-50059 is correct.


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• Question D. 9. specifically asks about assets.

• Review fields 75-85 on the form HUD-50059 and compare it to the documentation and verifications obtained to determine if asset information on the HUD-50059 is correct.

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Review fields 75-85 on the form HUD-50059 and compare it to the documentation and verifications obtained to determine if asset information on the HUD-50059 is correct.

Did the total imputed value of all assets exceed $5,000 and if so was the correct amount used in the adjusted income calculation?

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Review fields 97-106 on the form HUD-50059 and compare it to the documentation and verifications obtained to determine if deduction information on the HUD-50059 is correct. Were all allowances the household was entitled to provided

on the HUD-50059?

• Review fields 97-106 on the form HUD-50059 and compare it to the documentation and verifications obtained to determine if expenses and allowances provided on the HUD-50059 are eligible.

Is the household eligible for all of the expenses and/or allowances claimed on the certifications in the file that were reviewed?


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• Is there a written certification signed and dated from the tenant regarding if they or any member of the household did/did not dispose of any assets in the past 2 years for each MI, IC, and AR certification reviewed in the file?

• If there were assets disposed of, were the assets disposed of for less than fair market value? • If yes, is there documentation of cash value and amount

actually received?


• Review fields 13, 31, and 32 on the HUD-50059s you review and compare them with the Rent Schedule in affect at the time the HUD-50059 was effective:

Does the contract rent and utility allowance match the Rent Schedule in affect at the time of the HUD-50059 effective date?

• If applicable for the file being reviewed, is the last GRC HUD-50059 printed and in the file (signed/dated by management, and, if necessary, the tenants)?


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• Review fields 108-111 on the 50059 and compare it to the amounts the reviewer calculated to determine if the amounts on the 50059 were calculated correctly by the O/A:– Is the TTP correct?

– Is the Tenant Rent correct?

– Is the Utility Reimbursement correct?

– Is the Assistance Payment correct?


• Review fields 108, 109, and 110 on the form HUD-50059. • Has the TTP been calculated at the minimum of $25?

• If yes, is there a UA, and is the tenant receiving a utility reimbursement?

• If no utility reimbursement, is there documentation the tenant requested a hardship waiver and documentation there was a circumstance present warranting a hardship waiver?

• If yes, was a hardship exception granted and was/is it properly executed?


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• Did EIV Income Discrepancy Reports run for the certifications you reviewed indicate that there was a discrepancy?

If there was an actual discrepancy, was this due to tenant not reporting or under reporting income; or was this due to O/A error?


• If a repayment agreement was executed:– Is it signed/dated by management and the tenant and does

it contain all required language?

– Is the O/A tracking payments to make sure the agreement is adhered to by the tenant?

– Was the initial voucher adjustment and subsequent manual adjustment made?

– Are follow up manual voucher adjustments being made as payments are received?


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• Was this tenant listed on any of the new hire reports run in the last 12 months?

If yes, is there a detail report and follow up documentation (contact with tenant, verifications etc.) in the file?

• Was a recertification warranted based on the information obtained?


• Review Field 111 on the HUD-50059 and Field 25 on the HUD-50059A and compare them to the vouchers provided during the review:

E. Billing

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• Is there a written notice to vacate from the tenant in the file?

• If so, was the notice provided 30 days prior to move-out?

• Were there extenuating circumstances causing the tenant to not be able to provide notice as required?

• If so, is this documented in the tenant file?

• Does the O/A have a policy to retain the security deposit refund if the tenant does not provide proper notice to vacate for reasons other than extenuating circumstances?

F. Move-Out File Review Only

• Is there a move-out inspection in the file?

• If so, was the move-out inspection signed and dated by management (and tenant, if applicable)

– The tenant is encouraged but not required to sign the Move-out inspection.

• Were there damages notated on the form and is there an indication of items that were above normal wear and tear?


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• Was interest properly calculated and applied to the security deposit at move-out, if required?

• Were there any charges applied to the security deposit?

• If so, did the charges exceed the security deposit plus interest?

• If a refund (full or partial) is due, is there documentation that the actual refund check was sent/provided within 30 days of move-out (or within state and local law requirements if shorter)?

• Was the refund amount correct?


• Were there any charges against the security deposit; or did the tenant receive a full refund?

• Is there a notice/letter of security deposit disposition in the file?

• If there were charges applied to the security deposit, does the security deposit disposition letter itemize the charges?

• Are the charges applied allowable?

• Do damages coincide with what is listed on the move-out inspection, and other charges (unpaid rent etc…) coincide with the tenant ledger?


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• Were there charges that exceeded the security deposit plus accrued interest?

• If so, did the notice/letter of security deposit disposition with itemized list sent to the tenant state what the remaining amount due was and that the tenant needed to pay the balance due?

• Was the balance due turned over to a collection agency (is there documentation it was turned over), or was the balance written off?


• Does the actual move-out date documented in the file match the move-out date listed on the voucher?

• Were the proper adjustments made on the voucher to reimburse HUD for the overpaid subsidy?

• If tenant was deceased and was the only member, was the Subsidy Terminated 14 days or less from the date of death, and is there documentation in the file for the date of death?


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• Does the reason listed on the rejection letter match documentation in the file?

• Did the reason the applicant was rejected match the criteria listed in the Tenant Selection Plan, and is it in accordance with HUD regulations?

G. Applicant Rejection Review Only

• Does the rejection letter:– Contain the required appeal language?– State the specific reason(s) for the rejection? – Outline the applicant’s right to respond to the owner in

writing or request a meeting within 14 days to dispute the rejection?

– Give persons with disabilities the right to request reasonable accommodations to participate in the informal hearing process?


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• Review the written application rejection letter. Does it contain: – The specifically stated reason(s) for the rejection;

– The applicant’s right to respond to the owner in writing or request a meeting within 14 days to dispute the rejection; and

– Persons with disabilities have the right to request reasonable accommodations to participate in the informal hearing process.


• Did the applicant appeal the rejection? – If so, was the person that reviewed the appeal and/or met

with the applicant someone other than the person that originally rejected the application (i.e. is the person that signed the application rejection letter different from the person that signed the appeal decision letter)?


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• Did the applicant appeal the rejection?– If so, was the applicant notified in writing of the appeal

decision within 5 days of the meeting/hearing?

– If the appeal was overturned, was the applicant re-instated reinstated and re-entered on the waiting list in accordance with established policies and procedures?


Suggested Tenant FileContents and Organization

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Panel 1

• Application

• Form HUD-92006 (Supplement to Application) Consent for Screening

o Screening

o Criminal

o Sex offender

o EIV Existing Tenant Search Report

• Any additional screening (credit check, landlord reference, personal reference, home visit report, etc.)

• Declaration of Citizenship

• Student Status Certification and/or verification of Student Status

• Form HUD-27061-H (Race & Ethnic Data Reporting Form)

• Verification of SSN (and/or EIV Summary Report with the status of all household members as "Verified")

• Family Summary Sheet

• Owner's Summary of Family Sheet Verification of Disability Status (if applicable)

• Verification of Age (if applicable)

• Verification of Security Deposit

Application & Eligibility

Panel 2

• Leases (current on top, oldest on bottom)

o Violence Against Women Act Addendum

o Pet Addendum (if applicable)

o Live-in Aide Addendum (if applicable)

o Owner’s Police or Security Personnel addendum (if applicable)

• House Rules

• Lead-based Paint Disclosure (if applicable),

• Pet Rules (if applicable)

• Other lease attachments/tenant policies

• Unit Inspection Reports (current on top, oldest on bottom)

• Security Deposit and/or Pet Deposit Receipts

Leases & Attachments

Please note that all applicable addendums mustbe issued with EACH lease and should follow

the respective lease in the file.

43

Panel 3• Ml-50059

• Rent Calculation Worksheet (not required)

• Tenant certification Paperwork, (completed by the tenant, not mandatory)

• EIV Income Report within 90 days after MI

• EIV Income Discrepancy Report (plus any supporting documentation to resolve the discrepancy when applicable)

• Any EIV New Hires Detail or Multiple Subsidy Detail reports (plus any supporting documentation to resolve the discrepancy when applicable)

• Additional third party verification, review of documents from tenant, and/or self-certification of income

• Assets: Third party verification, review of documents from tenant, and/or self-certification

• Asset Disposal Certification

• Medical expenses: Third party verification, review of documents from tenant, and/or self-certification (if applicable)

• Childcare expenses: Third party verification, review of documents from tenant, and/or self-certification (if applicable)


• Annual Acknowledgement of Head of Household’s Receipt of:

o Resident Rights and Responsibilities Brochure, form HUD 9887/9887-A Fact Sheet, the Fact Sheet for HUD Assisted Residents – Project Based Section 8 (Appendix 14),form HUD-1141 “Is Fraud Worth It?” and “EIV and You” brochure

• Notice of Rent Increase

• Initial Notice of recertification

• Form HUD-9887/9887-A

• GR-50059-As and IR-50059s with supporting documents (occurring within the first 12 months of occupancy)

MI Certification

Panel 4• AR-50059• Rent Calculation Worksheet (not required)• Recertification Interview/Verification

Record (Exhibit 7-5, not mandatory)• Tenant re-certification Paperwork,

(completed by the tenant, not mandatory)• EIV Income Report • EIV Income Discrepancy Report (plus any

supporting documentation to resolve the discrepancy when applicable)




• Asset Disposal Certification• Medical expenses: Third party verification,

review of documents from tenant, and/or self-certification (if applicable)







• Form HUD-9887/9887-A

• GR-50059-As and IR-50059s with supporting documents (occurring within the first 12 months of most recent AR)

Current Recertification

44

Panel 5

• Notices of Late Rent

• Grievance

• Reasonable Accommodation Requests

• Miscellaneous

All documents should be stored bydate of the correspondence (mostrecent on top, oldest on bottom)

Management / Tenant Correspondence

Panel 6• AR-50059• Rent Calculation Worksheet (not required)• Recertification Interview/Verification

Record (Exhibit 7-5, not mandatory)• Tenant re-certification Paperwork,

(completed by the tenant, not mandatory)• EIV Income Report • EIV Income Discrepancy Report (plus any

supporting documentation to resolve the discrepancy when applicable)




• Asset Disposal Certification• Medical expenses: Third party verification,

review of documents from tenant, and/or self-certification (if applicable)







• Form HUD-9887/9887-A

• GR-50059-As and IR-50059s with supporting documents (occurring within the first 12 months of most recent AR)

Past Recertifications

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Documents