Presented by Rose Dubin, CPM, COS C4P

o I am not a HUD Employee o I am not an Attorney o I am not a Contract Administrator I am a HUD and Tax Credit consultant/contractor

o The PBCA Contract Administrators may be scheduled to resume Management and Occupancy Review (MORs) this year. Will your property be one of the ones chosen? o Are you currently being reviewed annually? o What are/will HUD and Contract Administrators will be looking for? o How to prepare your tenant files, to be in compliance with HUD’s rules & regulations.

o HUD Manual Manual or Electronic o Tenant File Review Worksheet (In the 9834 Packet – Pages 29-33) o Internet Access o Document Checklist o Calculator with tape o Current Tenant Files

o All other HUD Manual o All other HUD Manuals are obsolete o Can easily download to your desktop o Includes Chapter 9 for EIV o Be sure you have the November 2013 version o Includes all of the attachments

o Be sure to sign up for the RHIIP Listserv for the newest and latest information being disseminated by HUD be/mailinglist o Always check HUDCLIPS (or rely on your Compliance Director) for most current forms being used for content and expiration dates. o Once forms have new dates discard the old forms.

o Do you review them for completion and accuracy? o Are you still placing the time and date received on the application and transferring that information to your waiting list? o Although no longer required by HUD, does your applicant sign to attest to the accuracy of the information? o Are you asking how the applicant came to your site? Best source of Marketing.

o Have you correctly identified all household members on HUD 50059? o Unit size appropriate for the household? o If applicable, are you tracking income targeting? Based on your TSP? o HUD 92006? o Have you run the Existing Tenant Search for all family members and printed out results prior to move in?

o Application o SS# for each family member *Eligible Citizenship o Credit/criminal/sex offender screening Student Certification o Landlord referencesAttachments o Addendums (HUD Approved)Disability, if applicable o Verification of ageHouse Rules/Manual o VAWA (Each 18 & up)Move-in Inspection o Pet Rules, if applicableExisting Tenant Search o Race and Ethnicity Form (voluntary)Security/Pet Deposit o Required company/state/city formsMove-in & Docs o HUD model lease OMB approval date 12/2007

o Is all of your tenant move-in information stored on the left side of your file folder? o How many years of recertification's are you required to keep in the tenant file? o How long are you required to keep the tenant files after the tenant has moved out? o What document does HUD not require you to retain after you have printed the EIV and viewed Income Summary Report that the tenant(s) are “Verified”?

o How are you listing the documents your tenants receive at move-in and recerts? o Are you sure you are giving them all of the correct documents? o Are you making copies of the first pages of the docs you are distributing? o Do you get the tenants signature that they received them?

Tenant Acknowledgement of Documents for Move-in/Recertification of 1/1/16 I, John Smith Unit 1234 have received the following documents ____Lease ____House Rules and Regulations____Bed bug policy ____Resident Handbook____How Rent is Determined ____Pet Rules, if applicable____The Fraud document ____Violence Against Women Addendum____Tenant/Landlord Summary ____Initial Notice____Smoke Detector ____TIC (Tax Credit Properties only)____Parking Agreement ____EIV letter to resident’s____Drug-free housing ____EIV and You brochure____Lead-based paint disclosure ____Owners Notice #1 from Non-citizen packet____Other attachments ____9887 Fact Sheet____Insurance release Agreement ____Residents Rights and Responsibilities____Move-in inspection ____Mold Attachment, if applicable____Security deposit interest information ____Emergency Response system for and Release, if applicable By signing below, the resident acknowledges that the above documents or copies have been received ________________________________________________________________ Residents SignatureDate ________________________________________________________________ Residents SignatureDate ________________________________________________________________ Residents SignatureDate Mgr Int: ________

o Do you send your initial recertification notice out 120 days prior to the effective date? o Are your 2 nd and 3 rd notices sent out on the 1 st day of the following month(s)? Even for the unfinished recerts? o Are your recertification's completed on time? o Are they signed and dated by the appropriate parties? o Did tenant receive a 30 day notice of an increase?

Verifications at Move-in and Certifications o Wages: EIV Income Report 4-8 consecutive pay stubs/verification/tax return/affidavit o SS/SSI: EIV? Printout? o Public Assistance/Contributions/Pensions Child Support/Unemployment o IRA/Annuities/401K,403B,etc. o Savings/Checking/MM/CD/Whole Life/Real Estate o Dependent Allowance o Medical/Disability/Childcare Expense o Elderly/Disabled Allowance o Assets Disposed of

o Does the Assistance Payment listed on the match your HAP? o Adjustments at Move-in? o Adjustments for Move-outs o 50059A for rent/UA change/signatures o When to reprint 50059’s with new Assistance payment

o Did you receive Move-out notice? o Did you complete a Move-out inspection? o Copy of the SD refund check in file? ( if applicable) o Was SD refunded within required timeframe? o Itemized list of deductions to tenant/family? o Bill for any additional monies owed sent? o Move-out date on voucher match file? o Applying for Special Claims for damages or vacancies? What other docs will you need?

o Was the applicant rejection criteria listed in your Tenant Selection Plan? o Is the reason for rejection clear in your letter? o Does your rejection letter allow for the for the applicant to appeal? If applicable: o Did the applicant appeal and meet with staff who was not a part of the initial rejection? o Was applicant notified of appeal decision within 5 days of meeting? Is the letter with the packet? o Note: “HSG Notice ” – Arrest Record must not be sole basis for rejection of applicant.

o Are you required to have VAWA ? o All new tenants fill out a 92006? Existing tenants? o Do your “owner created” forms contain Title 18, Section 1001 of the US Code? (Penalties for Misusing this form language o Are you running annual sex offender/criminal searches?

o Are you giving out “EIV and You Brochure”? o Are you running and printing the Existing Tenant Search prior to move-in? o Move-ins after , running Income and Summary Report 90 days after transmission? o Income Summary Report in file? o Income Report in File? (AR & IR) o Income Discrepancy Report and follow up? o Are you running your EIV reports based on your EIV P & P’s?

EIV Questions on the Tenant File Worksheet o Does the tenant file indicate that the owner/agent has taken necessary steps to address any EIV reported receipt of multiple subsidies? o Does the file contain documentation to verify discrepant person identifiers, and/or subsidy paid as reported on: EIV Multiple Subsidy Report or EIV Deceased Tenant Report? o Were income discrepancies reported on EIV Income Discrepancy Report investigated and file documented with the resolution? o Is there a written Payment Agreement for monies due to the project ? o Does the file contain a recertification as a result of new employment reported on the EIV New Hires Report? o If yes, is the new employment income included in the reported annual income?

? Rose Dubin “How to Conduct Your Own Tenant File Audit”