Form HUD 9834 HUD 9834 Multifamily Housing Projects

Management Reviews of Multifamily Housing Programs

9834

Management Reviews of Multifamily Housing Programs

OMB: 2502-0178

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Management Review for
Multifamily Housing Projects

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

PURPOSE: To assess management and oversight of multifamily housing projects.
INSTRUCTIONS: This form is to be completed by HUD staff, Performance Based Contract Administrators (PBCA), Traditional Contract Administrators (CAs) and
Mortgagees of Coinsured Projects (Mortgagees). The Management Review form consists of three parts: Desk Review, On-site Review with Addenda, and Summary
Report. All reviewers of subsidized projects must complete Addenda (A, B, C, & D). Reviewers of unsubsidized projects must complete Addenda B & C only. If any
questions on any given form are not relevant to the program under review or if the information is not available, notate with “N/A”. FHEO staff provide MFH staff a list
of requests for documents and special observations each year. Additional guidance regarding the management process can be found in HUD Handbooks 4350.1, REV-1
and 4566.2.
A. Prior to On-Site Review
Complete Part I – Desk Review
To complete the Desk Review worksheet prior to the on-site visit, review the project files, system reports, and other documents, and contact the HUD
representative for any unavailable information needed to complete the desk review. Fair Housing/Civil Rights review requirements are all in Addendum B.
This portion of the review will assist the reviewer in identifying potential problem areas. Owner must complete Addendum B, Part A, and send it to
Multifamily Housing. HUD staff must complete the entire Desk Review for subsidized projects. For unsubsidized projects, HUD staff/mortgagees must
complete all applicable sections. CAs must complete the entire Desk Review except where noted “This question applies only to HUD Staff/Mortgagees.”
Schedule a date for the on-site review with the owner/agent and confirm the review date in writing. The owner/agent should be given at least a two-week
notice in writing and notified of the documents that need to be available the day of the review, as specified in Addendum C. Addendum C provides a list of
documents notated by the reviewer that the owner/agent must have available during the on-site review. Addendum C and Part A of Addendum B must be
forwarded to the owner/agent with the letter confirming the scheduled on-site review. The reviewer may request additional items as necessary.
B. Conducting the On-Site Review
Complete Part II – On-Site Review
On-Site Reviews will be completed as follows:
(1) HUD staff and Mortgagees must complete all applicable questions in Part II.
(2) CAs must complete all questions in Part II except where noted “This question applies only to HUD staff/Mortgagees.”
(3) HUD staff completing a review of a project which is also reviewed by a CA will only complete questions not applicable to CAs.
In accordance with Part D, bring back all information requested by FHEO.
Use additional sheets as necessary to complete applicable questions.
Upon completion of the on-site review, the reviewer will hold a close-out session with the owner/agent to discuss observations and conclusions.
C. After On-Site Review
The reviewer will record deficiencies, findings and corrective actions. Findings must include the condition, criteria, cause, effect and required corrective
action. The condition describes the problem or deficiency. The criteria should cite the statutory, regulatory or administrative requirements that were not
met. The cause explains why the condition occurred. The effect describes what happened because of the condition. The corrective action provides what the
owner/agent must do to eliminate the deficiency. The corrective action must include a requirement that the owner determine and correct not only the
discovered errors and omissions, but also describe to the reviewer how and what systems, controls, policies and procedures were adjusted or changed to
assure that the errors and omissions do not reoccur. In completing the Report of Findings, the reviewer should also indicate the target completion date.
The reviewer completes Addendum B Section A and forwards the completed form to FHEOmust provide FHEO, along with the approved initial or updated
Affirmative Fair Housing Marketing Plans in accordance with “General Operational Procedures for the Civil Rights Front-End and Limited Monitoring
Reviews of Subsidized Multifamily Housing Projects”, which may be found on FHEO’s web site.
Complete Summary Report as follows:
Based on the Report of Findings, the reviewer will assess the overall performance for each applicable category. The reviewer must indicate A (Acceptable)
or C (Corrective action required) and include target completion dates (TCD) for all corrective action items. For those items not applicable, indicate “N/A” in
the TCD column.
For each of the seven major categories (A, B, C, D, E, F, and G), rate each category by entering a score between 1 and 100. If a category was not reviewed,
enter a score of zero (0). After rating the individual categories, an overall rating must be assessed. This rating will be based upon the ratings assigned in
categories A through G. CAs will rate all categories except Category D. Category D is for HUD staff and Mortgagees only. Additional guidance for ratings
can be found in HUD Handbook 4350.1, REV-1.
Distribute the Summary Report and cover letter as follows:
(1) Project Owner (original)
(2) Management Agent (copy)
(3) HUD office for PBCA reviews rated below average or unsatisfactory
(4) HUD office for all traditional CA reviews
*A copy of the completed Management Review Report, form HUD-9834 and supporting documents must be maintained in the project file.
If a below average or unsatisfactory rating is determined, the owner/agent must be afforded an opportunity to appeal. Guidance on appeal procedures is
provided in HUD Handbook 4350.1, REV-1.
All Secure Systems users must document all required data in the Integrated Real Estate Management System (iREMS).
D. Management Review Deficiency Follow up:
Reviewer must conduct follow-up activity until all corrective actions as required in the Summary Report have been completed. Enter applicable close-out
dates in iREMS.
Housing reviewers will Forward all completed FHEO checklists and attachments to FHEO within five (5) business days of their own on-site reviews or
within 5 business days of receipt of the checklists from the CA, as applicable. Follow-up instructions may be found on FHEO’s web site.
NOTE: The Fair Housing and Equal Opportunity (FHEO) checklist has been included as part of this management review form; however no determination of
compliance with applicable Fair Housing laws and regulations is included in the summary report. CAs must forward the original checklist (Addendum B) to HUD staff.
HUD staff must maintain the original checklist in the project file and forward a copy to the Office of FHEO in the appropriate jurisdiction for review.

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Management Review for
Multifamily Housing Projects
Summary
Date of On-Site Review:

Date of Report:

Project Number:

Contract Number:

Section of the Act:

Name of Owner:

Project Name:

Project Address:

Loan Status:

Contract Administrator:

Type of Subsidy:

Insured
HUD-Held
Non-Insured
Co-Insured

HUD
CA
PBCA

Type of Housing:

Section 8
PAC
Section 236
Section 221(d)(3) BMIR

Rent Supplement
RAP
PRAC
Unsubsidized

Family
Disabled
Elderly
Elderly/Disabled
Other (please specify)

For each applicable category, assess the overall performance by checking the appropriate column. Indicate A (Acceptable) or C (Corrective action required). Include target completion dates (TCD) for all corrective action
items. For those items not applicable, place N/A in the TCD column.
A. General Appearance and Security
C
TCD
Enter a score between 1 and 100 for the General Appearance and Security Rating.
A
If this Section was not reviewed, enter 0.
is 10% of the overall score.
1. General Appearance
2. Security
B. Follow-up and Monitoring of Project Inspections
C
TCD
Enter a score between 1 and 100 for the Follow-up and Monitoring of Project Inspections
A
Rating .
If this Section was not reviewed, enter 0.
3. Follow-Up and Monitoring of Last Physical Inspection and
is 10% of the overall score.
Observations
4. Follow-Up and Monitoring of Lead-Based Paint Inspection
C. Maintenance and Standard Operating Procedures

A

C

TCD

5. Maintenance
6. Vacancy and Turnover
7. Energy Conservation
D. Financial Management/Procurement

Enter a score between 1 and 100 for the Maintenance and Standard Operating Procedures
Rating.
If this Section was not reviewed, enter 0.
is 10% of the overall score.

A

C

TCD

8. Budget Management
9. Cash Controls
10. Cost Controls
11. Procurement Controls
12. Accounts Receivable/Payable
13. Accounting and Bookkeeping
E. Leasing and Occupancy

Enter a score between 1 and 100 for the Financial Management/Procurement Rating.
If this Section was not reviewed, enter 0.
is 25% of the overall score.

A

C

TCD

Enter a score between 1 and 100 for the Leasing and Occupancy Rating.
If this Section was not reviewed, enter 0.
is 25% of the overall score.

F. Tenant/Management Relations

A

C

TCD

23. Tenant Concerns
24. Provision of Tenant Services
G. General Management Practices

Enter a score between 1 and 100 for the Tenant Services Rating.
If this Section was not reviewed, enter 0.
is 10% of the overall score.

A

C

TCD

General Management Practices Rating.
If this Section was not reviewed, enter 0.
is 10% of the overall score.

14. Application Processing/ Tenant Selection
15. Leases and Deposits
16. Eviction/Termination of Assistance Procedures
17. Enterprise Income Verification (EIV) System Access and
Security Compliance
18. Compliance with Using EIV Data and Reports
19. Tenant Rental Assistance Certification Systems (TRACS)
Monitoring and Compliance
20. TRACS Security Requirements
21. Tenant File Security
22. Summary of Tenant File Review

25. General Management Operations
26. Owner/Agent Participation
27. Staffing and Personnel Practices
Overall Rating:
Superior
Above Average

Satisfactory

Below Average

Unsatisfactory

Overall Score:

To calculate an overall score: Multiply the derived performance value by the assigned percentage of the overall rating for each category. Once all tested categories have been calculated based on the
performance indicator and performance indicator values, the total calculated points is divided by the total percentage of overall rating and rounded to the nearest whole number.
For convenience, a utility is included with this form which will perform all of the necessary calculations.

Name and Title of Person Preparing this Report: (Please type or print):

Name and Title of Person Approving this Report: (Please type or print):

Signature: _____________________________________________________________

Signature:______________________________________________________________

Date:

Date:

NOTE: If this review is conducted by a CA or PBCA as indicated above, the overall rating reflects a review as it relates to compliance with the Housing Assistance Payment Contract (HAP) only.

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for
Multifamily Housing Projects

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

Summary
SUMMARY REPORT – FINDINGS
For each “C” item checked on the summary report, reference the appropriate citing, and target completion date. Findings must include the condition, criteria, cause,
effect and required corrective action:
o
The condition describes the problem or deficiency
o
The criteria cites the statutory, regulatory or administrative requirements that were not met
o
The cause explains why the condition occurred
o
The effect describes what happened because of the condition
Corrective actions are required for all findings.
Item
Number

Finding

Target Completion Date

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Management Review for
Multifamily Housing Projects
Part I Desk Review

PART I. DESK REVIEW –The reviewer must complete this section prior to the on-site review using all relevant information in project files and HUD database
systems. Questions on the desk review, which include category references, are linked to the on-site review. Category references on the desk review that relate to the
on-site review must be considered when determining the category rating. Category references are marked following the applicable question (i.e. B3, E14).
If any questions on any given form are not relevant to the program under review or if the information is not available notate with “N/A”.
1. What is the most recent Physical Assessment Subsystem (PASS) score?
B3
Enter PASS Score

Date of REAC inspection

If required, has the project filed a certification that all items listed on the previous REAC inspection have been completed?
Yes
No
If more than one inspection is of record, does the reviewer note repetitive defects?
Yes
No
Comments:

B3

2. Were Exigent Health and Safety (EH&S) conditions cited in the report?

Yes

No

N/A

Comments:

3. Have all latent defects been corrected? This question applies only to newly constructed projects within the last 24 months.
This question applies only to HUD Staff and Mortgagees.
Yes
No
If not, list depository and amount of any construction escrows remaining.

N/A

Comments:
Questions 4 through 6 only apply to subsidized family properties or elderly properties housing children under the age of six that were constructed prior to
1978. If the lead based paint inspection has been conducted and the information was documented on a previous management review, proceed to question 7.
4. Document the year of construction for Lead-Based Paint compliance.
Obtain this information from the Physical Condition/PASS screen in iREMS Open the REAC Inspection Report, then open the PASS Physical Inspection Report.
The year of construction can be found under Buildings/Units.
Date of Construction

If construction occurred after 1977, proceed to question 7.

5. Has a lead-based paint inspection been conducted? 4B

Yes

No

Information Not Available

Yes

No

N/A

If yes, is there a HUD approved lead hazard control plan?

Yes

No

N/A

7. Is an Annual Financial Statement required? (If no, proceed to question 10).
This question applies only to HUD Staff.

Yes

No

Comments:

4B

6. What were the results of the Lead-Based Paint Inspection/Evaluation:
Was lead found?

Comments

Comments:
8. What was the most recent Financial Assessment Subsystem (FASS) score?
This question applies only to HUD Staff

Score

If financial reporting is not required, determine why; and record the reason in reviewer comments below.
Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 1 of 7

Management Review for Multifamily
Housing Projects
Desk Review (Continued)

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

9. Have the following reports been consistently submitted on a timely basis? (Look at multiple periods) Check the appropriate box for reports received, and indicate
whether or not the report was received timely.
This question applies only to HUD Staffand Mortgagees
Annual Audited Financial Statement
Date last report was due:
Date last report received:
Monthly Accounting Report
Excess Income Report (HUD-93479, 80, 81)
Quarterly performance report for projects on flexible subsidy, modification, workout, etc.
Annual operating budget (cooperatives)

Yes

No

N/A

Yes
Yes
Yes
Yes

No
No
No
No

N/A
N/A
N/A
N/A

If the reports have been submitted, were they received in acceptable form?

Yes

No

Yes

No

Comments:
10. Has the owner corrected all findings on HUD financial and or Inspector General audits?
This question applies only to HUD Staff and Mortgagees.

N/A

List findings outstanding and determine whether remedial action is required to assure correction within established goals:

Comments:
11. Do project operating expenses appear reasonable compared with similar projects?
This question applies only to HUD Staff.
D10

Yes

Indicate latest OPIIS rating and check problem areas flagged by OPIIS.
Administrative
Maintenance
Utility
Taxes and Insurance

No

Financial

Also, use OPIIS to conduct an expense comparison with other similar projects.
Comments:
12. Does annual financial analysis or FASS printouts indicate that project is free of actual or potential financial problems?
This question applies only to HUD Staff.
Yes
No
For each of last 3 years, enter Profit (Loss) before depreciation (from the Statement of Profit & Loss).
Year
$
$
$
Comments:
13. If the owner/agent has taken unauthorized distributions, reimbursements, or supervision fees, have these been repaid?
This question applies only to HUD Staff and Mortgagees.
Yes
No
If no, indicate amount due to the project. $
14. If applicable, have all deposits due to the residual receipts fund been made?
This question applies only to HUD Staff.

Yes

No

Yes

No

Comments:
15. Based on the last FASS submission, are accounts payable reasonably current?
This question applies only to HUD Staff and Mortgagees.
D12
Indicate the amount of accounts payable more than 60 days old $
Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 2 of 7

Management Review for Multifamily
Housing Projects
Desk Review (Continued)

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

16. Does the balance in the security deposit trust account equal or exceed the project’s liability account?
This question applies only to HUD Staff and Mortgagees.

Yes

No

If no, explain how deficit will be funded.
Comments:
17. If security deposits are invested in an interest-bearing account, is interest passed through to tenants or transferred to project account?
This question applies only to HUD Staff and Mortgagees.
Yes
No
Comments:
18. Have the owner and managing agent executed and submitted an appropriate Management Certification (form HUD-9839A, B, or C) to HUD?
This question applies only to HUD Staff and Mortgagees.
Yes
No
If yes, please enter date of certification.
Determine that the content of certification is consistent with present operations.
Comments:
19. Is the management fee paid to the agent in accordance with the Management Certification?
This question applies only to HUD Staff and Mortgagees.

Yes

No

Comments:
20. Has the owner and management agent executed a management agreement in accordance with the management certification?
This question applies only to HUD Staff and Mortgagees.
Yes
No
Comments:
21. Does the management agreement reflect HUD’s regulations and guidelines?
This question applies only to HUD Staff and Mortgagees.

Yes

No

22. Has a management entity profile been submitted to HUD?
This question applies only to HUD Staff and Mortgagees.

Yes

No

If yes, is it relevant to the agent’s organization and how it operates?

Yes

N/A

Comments:

No

Date of the management entity profile
23. Do the Management Entity Profile and Management Certifications clearly describe the relationships and responsibilities of the owner and agent?
This question applies only to HUD Staff and Mortgagees.
Yes
No
Determine if management is by an identity-of-interest contractor, and compare the contract arrangement to the annual financial report.
Comments:
24. Have the principals and board members listed received HUD-2530 approval?
This question applies only to HUD Staff.

Yes

No

Yes

No

N/A

Request a list of all current principals and board members and check for HUD-2530 approval.
Comments:
25. Is the agent charging the project for expenses which the agreement requires the agent to pay?
This question applies only to HUD Staff and Mortgagees.
Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 3 of 7

Management Review for Multifamily
Housing Projects
Desk Review (Continued)

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Questions 26 –29 apply to OAHP restructuring. If not applicable proceed to question 30.
26. Has the project’s mortgage been restructured?
This question applies only to HUD Staff.

Yes

No

If yes, is there a use agreement on the project?
Yes
No
If there is a use agreement, does it require any owner certifications?
Yes
No
If owner certifications are required, have they been submitted timely?
Yes
No
If applicable, has work required under the Rehabilitation Escrow been/is being completed according to schedule?
Yes
No
Comments:
27. Is the owner eligible for incentives?
This question applies only to HUD Staff.

Yes

No

If yes, has the owner calculated those incentives correctly? (i.e., Capital Recovery Fee (CRF) and/or Incentive Performance Fee (IPF))
Yes
No
Comments:
28. Does the HUD billing statement (HUD-92771) indicate timely and accurate payments toward the Mortgage Restructuring Note?
This question applies only to HUD Staff.
Yes
No
Comments:

29. If an owner is in non-compliance with HUD business agreements, has the owner been notified by HUD within the required timeframes?
This question applies only to HUD Staff
Yes
No
Comments:

Questions 30 through 33 apply to Section 236 projects. If this is not a Section 236 project proceed to question 34.
30. Does the rental income generate excess income?
This question applies only to HUD Staff.

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

N/A

Comments:
31. Has the owner/agent received approval to retain excess income?
This question applies only to HUD Staff.
D13
Comments:
32. Was an annual report submitted for usage of retained excess income?
This question applies only to HUD Staff.
D13
Comments:
33. Are there any delinquent excess income payments due HUD?
This question applies only to HUD Staff.
D13
If yes, is there a payment plan?
Comments:
34. Are rent increase requests submitted to HUD promptly when needed?
This question applies only to HUD Staff.

Review the timing of the last three rent increase requests and the results of the requests (approval, denial or modification to requested amount),
and whether the rents are comparable to other neighboring properties. If a wide disparity exists, determine the cause of the difference.
Does owner/agent generally provide sufficient documentation for rent increases?
Yes
No
Comments:
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 4 of 7

Management Review for Multifamily
Housing Projects
Desk Review (Continued)

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

35. If approval is required, are rent increase requests submitted promptly?

Yes

No

OMB Approval No. 2502-0178
Exp. 11/30/2011

N/A

Comments:
36. Complete chart below. (This question applies only to HUD Staff/ Mortgagees)
Name of Reserve
Replacement Reserve
General Operating Reserve
(Co-ops)
Residual Receipts
Other

As of
Total
$
$

Per Unit
$
$

Monthly Deposit
$
$

$
$

$
$

$
$

a. Do balances in replacement or general operating reserve accounts appear adequate to meet future needs?

Yes

Held in Interest Bearing
Account?
Yes
Yes

No
No

Yes
Yes

No
No

No

If not, what action is recommended?
b. Are repairs consistently paid from the appropriate operating expense account, and eligible items reimbursed from the reserves?
Yes
No
Comments:
37. Has the owner/agent performed an analysis to determine future Reserve for Replacement needs when submitting a budget based rent increase?
Yes
No
Comments:
38. If there is a utility allowance, what was effective date of last utility allowance adjustment?

What was the date of approval?

If a utility allowance was approved was it implemented within 75 days as required by HUD?

Yes

No

Comments:
39. What is the effective date of the last rent adjustment?
Comments:
40. Is the current approved rent schedule sufficient to meet project needs?
This question applies only to HUD Staff.

Yes

No

Yes

No

Comments:
41. Has a special rent increase been approved?
If yes, please check the appropriate box.

Insurance

Taxes

Utilities

Security

N/A

Service Coordinator

Comments:
42. Are monthly rental subsidy vouchers submitted on time?

Yes

No

N/A

Yes

No

N/A

Comments:
43. Is the owner/agent submitting tenant certification data to TRACS to support the voucher billings?
Comments:
44. Is the owner/agent transmitting data for Section 236 and Section 221(d)(3) BMIR tenants to TRACS as required by the automation rule?
Yes
No
N/A
Comments:
45. What is the term of the subsidy contract?
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 5 of 7

Management Review for Multifamily
Housing Projects
Desk Review (Continued)

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Date the contract term ends:
Comments:
46. List vacancy activity for the past twelve months, and indicate the number for each month. C6.
This information can be obtained from the TRACS Voucher Detail Summary.
JAN

FEB

MAR

APR

MAY

JUNE

JULY

AUG

SEPT

OCT

NOV

DEC

47. Does review of the EIV reports listed below include information that needs a resolution or explanation by the owner/agent? E18b
Income Discrepancy Report?

Yes

No

N/A

New Hires Report

Yes

No

N/A

Failed EIV Pre-Screening Report?

Yes

No

N/A

Failed Verification Report (Failed the SSA Identity Test)?

Yes

No

N/A

Deceased Tenant Report?

Yes

No

N/A

Multiple Subsidy Report?

Yes

No

N/A

Yes

No

N/A

Comments:
48. Is there a Neighborhood Networks Center for the project? (Check iREMS or other available source)
If no, answer “N/A” and proceed to 50.
Comments:

49. If yes to question 48, does the Neighborhood Networks Center have a Strategic Tracking and Reporting Tool (START) Business Plan?
Yes
No
If yes, date HUD approved:
If no, when will a START Business Plan be completed?
Projected date for START Business Plan:
Comments:
50. Are there any unresolved findings from previous management reviews? If yes, specify in the comments section.
Yes
Comments:

No

51. Review complaints, congressional inquiries, etc. received within the last 12 months regarding the overall management practices.
Provide a general description below and attach applicable documentation.
G25
Issue/Complaint

Status

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 6 of 7

Management Review for Multifamily
Housing Projects
Desk Review (Continued)

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 7 of 7

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Part II On-Site Review
Indicate by marking the appropriate box - Yes, No, or N/A if not applicable. Provide comments as needed.

CATEGORY A. GENERAL APPEARANCE & SECURITY
1. General Appearance
Based on observation, are the project’s exterior and common areas (i.e., grounds, landscaping, parking lots, playgrounds, hallways, laundry room, elevator, garbage
area, stairwells, management office) clean, free of graffiti, debris and damage?
Yes
No
N/A
If no, provide location and describe condition(s).
Comments:
2. Security
a. Indicate whether any of the events below have been documented in the last twelve months, and the frequency of the event(s).
Event
Break-Ins
Vandalism
Auto Theft
Personal Assaults

Frequency

Event
Arrests
Drug Activity
Other (please specify):
None

Frequency

Comments:
b. Indicate which types of security measures, if any, are utilized on site.
Tenant Patrol
Police Patrol
Motion Sensors
Other (please specify)

Volunteer Organization
TV Monitor
Crime Prevention Plan

Paid Car Patrol
Drug Free Housing Plan
Community Policing
None

Paid on-site Guard
Security Cameras

Comments:
c. Based on the answers provided in questions a and b above, what corrective actions, if any, have been taken by the owner/agent?
Comments:
d. Has the owner/agent requested a rent increase based on cost increases in security costs?

Yes

No

If yes, indicate security measures taken.
Comments:

CATEGORY B. FOLLOW-UP & MONITORING OF PROJECT INSPECTIONS
3. Follow-Up & Monitoring of Project Inspections and Observations (Sampling is at reviewer’s discretion to respond to questions a and b below)
a. Based on a sampling, if EH&S items were identified have the deficiencies been corrected and documented according to the owner/agent’s certification for the most
recent REAC inspection?
Yes
No
N/A
If no, provide an explanation.
Does the analysis show any repetitive or systemic problems?

Yes

No

Comments:
b. Based on a sampling of units and common areas, for all other deficiencies noted in the REAC inspection, as applicable, verify that corrective actions have been
taken. Have the deficiencies been corrected?
Yes
No
N/A
If no, is there a schedule for correcting the deficiencies within a reasonable timeframe to comply with decent, safe, sanitary and good repair standards?
Yes
No
Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

4. Follow-Up & Monitoring of Lead-Based Paint Inspection – The following questions only apply to subsidized family properties or elderly properties
housing children under six years of age that were constructed prior to 1978. If constructed after 1977, check N/A for questions a and b.
a. Is there a certification on file documenting that the project has been certified to be free of lead-based paint or lead hazards?
Yes
No
N/A
If there is a certification, obtain a copy for the project file.
Comments:
b. Is the owner in compliance with the HUD approved lead hazard control plan as noted on the desk review?

Yes

No

N/A

Comments:

CATEGORY C. MAINTENANCE & STANDARD OPERATING PROCEDURES
5. Maintenance
a. Indicate below to confirm that there is a schedule for preventive maintenance/servicing for the items listed that are applicable.
Heating and A/C Equipment
Water Heaters
Carpets and Drapes
Roof, gutter and Fascia Inspection
Major Appliances
Elevators
Motor Vehicles
Sewer lines
Exterior painting
Windows
Recreational equipment
Landscaping maintenance
Other (please specify):
Comments:
b. Is there a satisfactory inventory system to account for tools, equipment, supplies, and keys (serial numbers, bar codes, etc.)?
Yes
No
Comments:
c. Has the owner/agent secured inventory items, such as appliances and tools, to prevent theft?

Yes

No

Yes

No

Comments:
d. Does the owner/agent have a written procedure that explains the process for inspecting units?
If yes, review a copy.
Identify employee responsible for conducting the inspections: Name and Title:
Comments:
e. How often are units inspected?
Monthly

Quarterly

Semi-Annually

Annually

Move-In

Move-Out

Other (please specify):

Comments:
f. How are unit inspections documented?
Please Describe:
g. If deficiencies are noted during a unit inspection, what is the procedure for correction?
Please describe:
h. What is the average number of days from move-out until the unit is ready for occupancy?
Comments:
i. Is there a written procedure for completing work orders?

Yes

No

Yes

No

If yes, review a copy.
Comments:
j. Is there a procedure in place to handle emergency work orders?

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

If yes, describe the procedure:
k. Is there a backlog of work orders?

Yes

OMB Approval No. 2502-0178
Exp. 11/30/2011

No

If a backlog exists, indicate the current number of work orders:
Number between 1-3 days:

Number between 4-7 days:

Number more than one week:

Comments:
l. Who is provided copies of completed work orders? (check all that apply.)
Tenant

Tenant File

Maintenance Staff

Other (please specify)

Comments:
m. Is there documentation by unit that indicates the date of purchase, manufacturer, model, and serial number for appliance purchases (i.e., ranges, refrigerators,
furnaces, air conditioners, hot water heaters, etc.)?
Yes
No
Comments:
6. Vacancy and Turnover
a. How many units were vacant on the date of the on-site visit?
Number of Vacant Units:

Number Ready for Occupancy:

Average Length of time for unit turnover:

Comments:
b. Walk through at least two vacant units that are ready for occupancy. Assess and document unit readiness.
Number of Units Visited:

Number of Units Ready for Occupancy:

Number of Units Not Ready for Occupancy:

Comments:
c. Based on the interview with on-site staff, are any of the factors listed below contributing to vacancy problems? (Below, indicate all that apply.)
Security Problems
Non-competitive Amenities
Inadequate Marketing
Project Reputation
Poor Maintenance
Location
Lack of Demand
Tenant/Management Relations
Applicants Do Not Meet Screening Criteria
Other (please specify)
Bedroom Mix/Size (If yes, indicate which bedroom sizes are hard to rent)

Rents too High

Comments:
d. Based on the responses in questions a, b and c, what actions are being taken by the owner/agent to resolve the issue(s)?
If not applicable, proceed to question 7.
Please describe:
7. Energy Conservation
Has management attempted to reduce energy consumption?

Yes

No

(check all that apply.)
Caulking and weather-stripping
Conversion to individual metering
Storm doors and windows
Consumer education
Water saver devices
Extra insulation
Assessment of Utility Rate Schedule
Energy Efficient Lighting
Energy Star Appliances
Written Energy Conservation Plan
Other (please specify)
None
Comments:

CATEGORY D. FINANCIAL MANAGEMENT/PROCUREMENT
(This Category applies only to HUD Staff and/or Mortgagees as indicated. CAs may proceed to Category E.)
8. Budget Management
a. Does the owner/agent’s staff have access to the current operating budget in order to monitor and control expenses?
Yes
Comments:
b. Is an operating budget prepared annually and approved by the owner?

Yes

No

N/A

No

N/A
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

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U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

If yes, obtain a copy of the current year’s budget.
Comments:
c. Are monthly or quarterly reports prepared by the owner/agent indicating variances between actual income and expenses versus budgeted income and expenses?
Yes
No
N/A
Comments:
d. If this is a 202 or 811 project, does the owner/agent maintain a current annual budget?
This question applies only to HUD Staff.

Yes

No

Yes

No

9. Cash Controls
a. Are collections deposited on the day received or, pending deposit, are they secured and properly controlled? Yes

No

If yes, is it available on-site?

N/A

Comments:

Comments:
b. Are adequate controls in place when cash is accepted?

Yes

No

N/A

Check the controls that are used.
Pre-numbered rent receipts

Bank collections

Safe

Lock box

Comments:
c. Do different persons handle bank deposits and accounts receivable, or is an alternative safeguard used?

Yes

No

Indicate Names and Titles:
Comments:
d. Are all disbursement checks prenumbered, properly identified with account numbers and supported by vouchers or invoices?
Yes
No
Comments:
e. Is the supply of unused checks adequately safeguarded, or under the custody of persons who do not sign checks manually, control the use of facsimile signature
plates, or operate the facsimile signature machine?
Yes
No
Comments:
f. Are funds (receipts, disbursements, petty cash, etc.) periodically checked on a surprise basis by a responsible official, other than site employees?
Yes
No
Comments:
g. Are bank statements reconciled promptly upon receipt by someone other than a check signer, and by one who has no cash receipt or disbursement function?
Yes
No
Comments:
10. Cost Controls
a. Are bills, including the mortgage payment, paid in sufficient time to avoid late penalties?

Yes

No

Comments:
b. Are operating expenses, including taxes and utilities, periodically reviewed to assure that project is paying the lowest possible rate?
Yes
No
If yes, provide a recent example.
11. Procurement Controls
a. What is the procedure used to obtain and award contracts?
Describe procedure:
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

b. Are bids obtained prior to awarding contracts?
Yes
No
N/A
Review contracts and determine if bids were obtained and, if the lowest bids were not selected, determine the owner’s/agent’s reasoning for selection.
Comments:
c. Is there a written procedure for checking the quality of work performed by a contractor prior to authorizing payment?
Yes
Comments:

No

d. Is there a procedure to assure that the individual authorizing contracted work or services is not the same individual authorizing payment?
Yes
No
Comments:
e. Who is the responsible person charged with inspecting the quality of work performed by contractors prior to payment?
Please provide the name and title:
f. Does the project maintain a list of outside contractors?

Yes

No

Yes

No

Comments:
g. Are vendor bills paid in time to obtain maximum trade discounts?
Comments:
h. Is there any indication that real or personal property has been subtracted from the mortgaged premises without the permission of the Department?
Comments:
i. Below, check services currently contracted with outside contractors and provide the name of the contractor and annual amount of the contract.
Indicate (by asterisk) whether there is an identify-of-interest relationship between the contractor and the owner/agent.
Service
Elevator

Name of Contractor

Annual Contract Amount
$

Exterminating

$

Apartment Cleaning

$

Heating and A/C

$

Plumbing

$

Security

$

Trash Collection

$

Decorating

$

Grounds

$

Other

$

Comments:
12. Accounts Receivable/Payable
a. Complete the following as of end of last month.
Cash $

Accounts Receivable $

Accounts Payable $

Are tenant accounts receivable within acceptable limits of 10% of one month’s rent potential?

Yes

No

Amount of receivables above is
% of monthly rent potential.
Of this amount, $
is more than 30 days past due.
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

Comments:

b. Does the procedure for write-off of bad debts appear reasonable?

Yes

No

Comments:
c. Has annual “write-off of tenants’ accounts receivable for the last two fiscal years been less than 1% of gross rent potential?
Yes
No
Comments:
d. Are accounts payable reasonably current?
Yes

No

Indicate amount of accounts payable more than 60 days old:
What are the owner/agent plans to reduce outstanding payables?
Comments:
13. Accounting and Bookkeeping
a. Are books and records maintained as required by HUD Handbook 4370.2 (Chapter 4) and 24 CFR Part 5?
Yes
Check books of accounts that are maintained. Indicate where books may be examined.
O – owner’s office; A – agent’s office; P – project site
General Ledger
( )
Rent Receivable Ledger
( )
General Journal
( )
Cash Receipts Journal ( )
Cash Disbursements Journal ( )
Accounts Payable Journal ( )

No

N/A

Comments:
b. Are all required project accounts in the name of the project in a federally insured institution?

Yes

No

Comments:
c. Are operating funds, security deposits, reserve funds, and flexible subsidy funds maintained in separate accounts and properly secured for authorized use?
Yes
No
Comments:
d. Does the mortgagor make frequent postings (at least monthly) to the ledger accounts?

Yes

No

Comments:
e. If applicable is owner adhering to HUD-approved repayment Plan? (loan from reserve for replacement, 236 excess income, capital improvement loan, etc.)
Yes
No
Comments:
f. Is centralized accounting used for disbursements?

Yes

No

Yes

No

Yes

No

N/A

Yes

No

N/A

i. If the trust account is part of a centralized disbursement account, are only HUD-insured projects in that account?
Yes
If yes, is the project’s balance transferred to the project account at least once monthly?
Yes

No
No

If yes, are only HUD-insured projects in the pool?
Comments:
g. If centralized accounting is used, has it been approved by HUD
Comments:
h. If centralized accounting is used, is it being administered in accordance with HUD’s approval?
Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Comments:

j. If there are automobiles and/or debit or credit cards charged to the project, are the titles kept in the name of the project?
Yes
No
If yes, do they have HUD approval?
Yes
No
Comments:

CATEGORY E. LEASING AND OCCUPANCY (This Category does not apply to Mortgagees)
14. Application Processing and Tenant Selection
a. Does the lease application form contain sufficient information to determine applicant eligibility?

Yes

No

Comments:
b. Does the tenant file contain evidence that the owner/manager has completed a check of Dru Sjodin National Sex offender Database or other national database?
Yes
No
Comments:
c. Does the application ask for a listing of states where the applicant and members of the applicant’s household have resided?
Yes
No
d. Is form HUD-92006 “Supplement to Application for Federally Assisted Housing”, an attachment to the application or part of the application package?
Yes
No
Comments:
e. Is there an arms length procedure between the person who denies an application and the application appeal reviewer?
Yes
Comments:

No

f. Has the owner/agent leased a Section 8 unit to a police officer or security personnel who is over the income limits for the project?
Yes
No
If yes, has HUD or CA authorized the admission?
Yes
No
Comments:
g. Does the owner/agent have a written tenant selection plan?

Yes

No

If yes, does the plan include all required criteria stated in Chapter 4, Handbook 4350.3 REV-1 and all applicable notices?
Yes
No
N/A
If no, list the required criteria that the tenant selection plan does not include:
Comments:
h. Does the project maintain a waiting list of prospective tenants?
If yes, does the list include all required elements stated in Handbook 4350.3 REV-1?

Yes

No

Yes

No

N/A

Comments:
i. Enter the number of applicants on the waiting list for each type of unit:

0 BR

1 BR

2 BR

3 BR

4 BR

Other:

Comments:
j. Were the applicants selected from the waiting list in the proper order, recognizing applicable preferences?

Yes

No

Yes

No

Comments:

k. When preferences were applied, were they properly documented?

N/A

Comments:
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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Management Review for Multifamily
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On-Site Review (Continued)

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

l. Is documentation available to show that the owner/agent has leased not less than 40% of the Section 8 units that became available for occupancy in the previous fiscal
year to extremely low-income families?
Yes
No
N/A
If yes, please review and obtain a copy.
Comments:
m. What marketing steps has the owner/agent taken to attract extremely low-income families?

If not applicable, proceed to question n.

Please describe:
Comments:
n. Does the advertising program comply with the existing affirmative fair housing marketing plan? Yes

No

Request to see copies of advertisements.
Comments:
o. Is the fair housing sign posted in the rental office?

Yes

No

Comments:
p. Is the fair housing logo included in published advertising materials?

Yes

No

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

Yes

No

Comments:
15. Leases and Deposits
a. Have modifications been made to the HUD model lease?
If yes, has the lease and/or lease addenda in use been approved by HUD?
This does not include lease addenda issued by HUD
Comments:
b. Aside from rents and security deposits, what other charges are assessed (replacement keys, lockouts, etc.)?
List the type and amount of any of these charges.
Comments:
c If other charges aside from rents and security deposits are assessed, have they been approved by HUD?
Comments:
d. Are rents collected in accordance with the provisions of the lease?
Comments:
e. Is the policy for late fee assessment in compliance with the Handbook 4350.3 REV-1 or with state/local requirements?
Yes
No
Comments:
f. Are damages caused by tenants properly identified and charged to tenants?

Yes

No

Yes

No

Comments:
16. Eviction/Termination of Assistance Procedures
a. Are tenants notified of termination of tenancy or assistance in accordance with HUD requirements?

N/A

Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

b. Are eviction procedures initiated timely, when warranted?

Yes

Please document the following:
Number of evictions completed during the last 12 months.
Average cost per eviction
$
Eviction handled by:
Owner/Agent
Attorney on staff of Owner/Agent
NOTE: Addendum D must identify any eviction during the last 12
offender registration requirement.

Attorney on contract

No

N/A

Attorney on call

months which was due to a household member being subject to a state lifetime sex

Comments:
c. Is the termination of assistance initiated timely when warranted?
Reason(s) for termination of assistance:

Yes

No

Yes

No

Yes

No

N/A

Comments:
17. Enterprise Income Verification (EIV) System Access and Security Compliance
Applies to subsidized properties only
a. Does the owner/agent have access to EIV?
Comments:
b. Does the EIV Coordinator(s) and/or agent have an owner approval letter(s) authorizing access to EIV?
Comments:
c. Does the owner/agent and/or EIV Coordinator have:
An initial and currently approved EIV Coordinator Access Authorization Form (CAAF) on file for each person designated by the owner as an EIV
Coordinator?
Yes
No
An initial and currently approved EIV User Access Authorization Form (UAAF) on file for each person designated by the EIV Coordinator as an EIV User?
Yes
No
N/A
Signed copies of the EIV Rules of Behavior for Individuals without access to the EIV system, who use EIV reports and/or data to perform their job
functions?
Yes
No
N/A
Comments:
d. Is there evidence that staff with access to the EIV system or to EIV reports take annual security awareness training?
Yes
If yes, is a record kept of employees who attended the training?
Yes

No
No

N/A

Comments:
e. Does the owner/agent have security measures in place to limit access to EIV information and reports to only those persons who have proper authorization?
Yes
No
Comments:
f. Does the owner/agent have a procedure to review all EIV User IDs to periodically determine if the users still have a valid need to access EIV data?
Yes
No
Comments:
g. Does the owner/agent terminate access promptly (within 30 days) of all users who no longer have a valid need to access EIV data?
Yes
No
Comments:
h. Does the owner/agent have a procedure to document and report the occurrence of all improper disclosures of EIV data?
Yes
No
Have any improper disclosures been reported to the owner/agent?
Yes
No
Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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Management Review for Multifamily
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On-Site Review (Continued)

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Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

i. Does the owner/agent have a procedure to report any occurrence of unauthorized EIV access or security breach to the HUD National Help Desk?
Yes
No
Have any occurrences of unauthorized EIV access or security breaches been reported?
Yes
No
Comments:
j. Is there evidence that the owner/agent or any of their employees are sharing IDs and passwords?

Yes

No

Comments:
k. Is EIV data being improperly shared with other entities (e.g., state officials monitoring LIHTC projects, RHS staff, or Service Coordinators not participating in the
re-certification process)?
Yes
No
Comments:
l. Does the owner/agent keep in the tenant file the Tenant Consent for Disclosure of EIV Information, signed by the tenant and a third party when a third party assists
in the re-certification process?
Yes
No
N/A
Comments:
18. Compliance with Using EIV Data and Reports
Applies to subsidized properties only.
a. Does the owner/agent have policies and procedures describing the use of EIV employment and income information and the EIV reports?
Yes
No
If yes, do they comply with HUD’s usage requirements?
Yes
No
N/A
Comments:
b. Is the owner/agent using the following EIV reports, and taking appropriate action to correct discrepant data in TRACS, and/or to reduce improper subsidy payments
and where applicable, retaining documentation to support the action(s)?
New Hires Report

Yes

No

No Income Report

Yes

No

Failed EIV Pre-screening Report

Yes

No

Failed Verification Report (Failed the SSA Identity Test)

Yes

No

Existing Tenant Search

Yes

No

Multiple Subisidy Report

Yes

No

Deceased Tenant Report

Yes

No

Yes

No

Yes

No

Yes

No

Comments:

19. TRACS Monitoring and Compliance (applies to subsidized properties only)
a. Is the owner/agent using TRACS queries to review and monitor their transmission?
Comments:
b. Is the owner/agent following up and correcting deficiencies identified in TRACS data?
Comments:
20. TRACS Security Requirements (applies to subsidized properties only)
a. Is the owner’s/agent’s “Rules of Behavior for TRACs” current (within last 12 months) and on file?
Comments:

b. Is the owner’s/agent’s completed annual TRACS “Security Training Certificate” current, on file and dated within 30 days of the date of the “Rules of Behavior”?
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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Yes

OMB Approval No. 2502-0178
Exp. 11/30/2011

No

Comments:

21. Tenant File Security
a. Are the tenant files, as well as other files that contain EIV reports, if applicable, locked and secured in a confidential manner?
Yes
No
Comments:
b. Is documentation relating to an individual’s domestic violence, dating violence, or stalking, kept in a separate file in a secure location from other tenant files?
Applicable to Section 8 only.
Yes
No
N/A
Comments:
c. Is access to tenant file information limited to only authorized staff?

Yes

No

Yes

No

Yes

No

Comments:
d. Who is authorized to have access to the tenant files?

Name(s) and Title(s):

Comments:

e. Is the owner/agent maintaining tenant files according to HUD’s document retention requirements?
Comments:
f. Is the owner/agent properly disposing of tenant records (shred, burn, pulverize etc.)?
Comments:

22. Summary of Tenant File Review
This section applies only to subsidized projects and should be completed after the tenant file reviews (See Addendum A.)
The minimum file sample should include review of tenant files of new move-ins, re-certifications (annual, interim, initial), at least one applicant reject file, and at
least one terminated/move-out file. In order to review specific functions (EIV usage, utility reimbursement, pet rules/deposits, minimum rents, etc.) it may be
necessary to target a portion of the files reviewed to specific tenant families. The reviewer should adjust the tenant file sample to meet the needs of the review.
Number of Units
Minimum File Sample
100 or fewer
5 files plus 1 for each 10 units over 50
101-600
10 files plus 1 for each 50 units or part of 50 over 100
601-2000
20 files plus 1 for each 100 units or part of 100 over 600
Over 2000
34 files plus 1 for each 200 units or part of 200 over 2,200
For each question, only answer “Yes” if the files reviewed are acceptable.
Answer “No” if the files are not acceptable and note the number of files with
Number of Files Reviewed =
deficiencies utilizing the tenant file worksheet, Addendum A
(Please note: There is no maximum number of files to be sampled)
a. Tenant Files and Records
i. Are the tenant files organized and properly maintained?

Yes

No

Number of Files with Deficiencies:
Comments:
ii Do the files contain all documentation as required in Handbook 4350.3 REV-1, applicable HUD Notices, and any changes to the CFR?
Yes
No
Documents Missing from Files:
Comments:
b. Application/Tenant Selection
i. Are the applications in the files signed and dated by applicant?

Yes

No

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

Number of Files with Deficiencies:
Comments:
ii. Is screening conducted in accordance with the Tenant Selection Plan?

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

N/A

Yes

No

N/A

Number of Files with Deficiencies:
Comments:
iii. Are the unit sizes appropriate for household composition at the time of this tenant file review?
Number of Files with Deficiencies:
Comments:
iv. If a household was ineligible at move in, were exceptions granted?

N/A

Number of Files with Deficiencies:
Comments:
c. Lease
i. Are the correct model leases used?
Number of Files with Deficiencies:
Comments:
ii. Are the leases signed and dated by all required parties?
Number of Files with Deficiencies:
Comments:
iii. Are HUD issued lease addenda properly signed and in the file?
Number of Files with Deficiencies:
Comments:
iv. Are the applicable addenda attached to the lease?
Number of Files with Deficiencies:
Comments:
v. Are security deposits collected in the correct amount for the program?
Number of Files with Deficiencies:
Comments:
vi. Are pet deposits within acceptable range and payment installments allowed?
Number of Files with Deficiencies:
Comments:
vii. Do the tenant files contain signed acknowledgement(s)and/or copies of the following documents indicating receipt by the tenant?
HUD-9887 Fact Sheet
Number of Files with Deficiencies:
Lead Based Paint Disclosure
Number of Files with Deficiencies:
Resident Rights and Responsibilities Brochure
Number of Files with Deficiencies:
EIV & You Brochure
Number of Files with Deficiencies:
Fact Sheet How Your Rent is Determined

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

N/A

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
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Number of Files with Deficiencies:
Race/Ethnicity Form
Number of Files with Deficiencies:

OMB Approval No. 2502-0178
Exp. 11/30/2011

Yes

No

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

Comments:
d. Certification/Re-Certification Activities:
i. Are re-certification notices issued in accordance with HUD requirements?
Number of Files with Deficiencies:
Comments:
ii. Are certifications completed on time?
Number of Files with Deficiencies:
Comments:
iii. Are all necessary verifications completed and properly documented?
Number of Files with Deficiencies:
Comments:
iv. Are EIV Income Reports used for third party verification of employment and income?
Number of Files with Deficiencies:
Comments:
v. If the tenant disputed the EIV employment and/or income reported in EIV, was a third party verification obtained from the source?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:
vi. Are appropriate actions being taken for income discrepancies reported on the EIV Income Discrepancy Report, and is the action documented?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:
vii. Are income and deductions calculated correctly prior to data entry?
Number of Files with Deficiencies:

Yes

No

N/A

Yes

No

N/A

ix. If tenants were granted a hardship exemption as part of the minimum rent, was the exemption applied correctly?
Yes
No
Number of Files with Deficiencies:

N/A

Comments:
viii. Does income information on the tenant certifications agree with verified file information?
Number of Files with Deficiencies:
Comments:

Comments:
x. Are Repayment Agreements in accordance with HUD requirements?
Number of Files with Deficiencies:

Yes

No

N/A

Comments:
xi. Are notices provided to tenants in accordance with HUD tenant notification requirements when their portion of rent has increased?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 13 of 18

Management Review for Multifamily
Housing Projects
On-Site Review (Continued)

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

xii. Are the correct contract rents used when determining the subsidy to be paid on behalf of tenants?
Number of Files with Deficiencies:

Yes

OMB Approval No. 2502-0178
Exp. 11/30/2011

No

N/A

Comments:
xiii. If tenants are paying their own utilities, are the current certifications reflecting the correct utility allowances?
Yes
No
Number of Files with Deficiencies:

N/A

Comments:

xiv. Are utility reimbursement checks distributed within 5 business days of receipt of the housing assistance payments?
Yes
No
Number of Files with Deficiencies:

N/A

Comments:

e. Voucher Billing
i. Are there any deficiencies noted in the tenant file review that results in over payment or under payment of the subsidy?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:
ii. For the move-in/move-out tenant file review, does the owner/agent make appropriate voucher adjustments?
Yes
No
Number of Files with Deficiencies:

N/A

Comments:
f. Move-In Files
i. Are proper income limits used for determining eligibility at move-in?
Number of Files with Deficiencies:

Yes

No

N/A

Yes

No

N/A

iii. If the files contain move-in inspections, have the owner/agent and the tenant signed and dated the inspection?
Yes
No
Number of Files with Deficiencies:

N/A

Comments:
ii. Do the files contain move-in inspections?
Number of Files with Deficiencies:
Comments:

Comments:
iv. Do the move-in files created after January 31, 2010 indicate that the owner/agent utilizes the EIV Existing Tenant Search for all
household members and applicants?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:
g. Move-Out Files
i. Do tenants provide written notice of intent to vacate in accordance with the HUD model lease?
Number of Files with Deficiencies:

Yes

No

N/A

Yes

No

N/A

Comments:
ii. Are move-out inspections conducted?
Number of Files with Deficiencies:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 14 of 18

Management Review for Multifamily
Housing Projects
On-Site Review (Continued)

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

Comments:
iii. Are security deposits refunded in 30 days or less if required by state law?
Number of Files with Deficiencies:

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

Comments:
iv. Are tenants provided an itemized list of charges against the security deposits?
Number of Files with Deficiencies:
Comments:
v. If charges exceed the security deposit, are the tenants billed for the balance due?
Number of Files with Deficiencies:
Comments:
h. Application Rejection Files
i. Are applicants denied admittance in accordance with the Tenant Selection Plan?
Number of Files with Deficiencies:
Comments:
ii. Do rejection letters provide applicants the right to appeal?
Number of Files with Deficiencies:
Comments:

iii. If applicant appealed an application rejection, was the appeal reviewed by someone other than person who made the original decision to reject?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:
iv. Were appeals processed and applicants notified of the appeal decision within 5 days of the meeting?
Yes
Number of Files with Deficiencies:

No

N/A

Comments:

CATEGORY F. TENANT/MANAGEMENT RELATIONS (This Category does not apply to Mortgagees)
23. Tenant Concerns
a. Is there a written procedure for resolving tenant complaints or concerns?
If yes, review a copy.

Yes

No

Yes

No

Yes

No

Yes

No

Comments:
b. Does the procedure adequately cover appeals?
Comments:
c. Is there an active tenant organization at this project?
Comments:
d. Is tenant involvement in project operations encouraged?
Comments:
24. Provision of Tenant Services
a. What social services are provided by the project, or the neighborhood, which meet the tenants’ needs? Below, indicate services that are available, and identify the
entity providing the service (i.e., city/county/state, church/school, community groups, etc.) and enter the cost to the project, if any.

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 15 of 18

Management Review for Multifamily
Housing Projects
On-Site Review (Continued)
Service

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Provider

Financial Source

Child Care
Recreation
Health Care
Energy Conservation
Vocational Training/Job Training
Meals
Financial Counseling
Substance Abuse Counseling
Service Coordinator
Neighborhood Networks Center
Other (please specify)
b. Is there a Service Coordinator for the project?
If there is no Service Coordinator, proceed to question 24.f.

Yes

No

Yes

No

Yes

No

Comments:
c. Is the Service Coordinator’s office clearly identifiable and private?
Comments:
d. Are the Service Coordinator’s files kept secure and confidential?

Comments:
e. Does the Service Coordinator maintain a directory of service agencies and contacts, and make the information available to all parties?
Yes
No
Comments:
f. If there is a Neighborhood Networks Center as indicated on the Desk Review, what is the status of operations?
If there is no Neighborhood Networks Center, proceed to question 24.h.
Open for Business
Temporarily Closed – State the date the center will reopen:
Permanently Closed – State the date the center closed:
Comments:

g. What programs are offered at the Neighborhood Networks Center?
GED
Adult Basic Education
Computer Classes
Homework Assistance
English as a Second Language

Job Training
Job Placement
Other (please specify)

Comments:
h. The Department allows owners and their agents to provide services related to renter’s insurance products. Does the owner/agent offer such services?
If the owner/agent offers no such service, proceed to question 25.
Yes
No
Comments:
i. HUD policy prohibits an owner/agent from evicting tenants for delinquent renter’s insurance payments.
How does the owner/agent deal with unpaid renter’s insurance?
Please explain the process:
Comments:
j. Review the renter’s insurance information provided to tenants. Does the information provided to tenants clearly indicate that purchasing insurance is optional, and
not required as a condition of occupancy?
Yes
No
N/A
Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 16 of 18

Management Review for Multifamily
Housing Projects
On-Site Review (Continued)

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

CATEGORY G. GENERAL MANAGEMENT PRACTICES
25. General Management Operations
a. Have the complaints, as noted on the Desk Review, been satisfactorily resolved?

Yes

No

Yes

No

Yes

No

N/A

Comments:
b. Is the project staff able to adequately perform management and maintenance functions?
Comments:
c. How does the owner/agent implement HUD changes in policies and procedures?
Describe the process:
d. Does owner/agent have a formal ongoing training program for its staff?
If yes, indicate types of training used and the frequency.
Type
On-Site

Frequency

Type
Industry/Association Training

HUD Seminars

Local Colleges

Energy Conservation

Other (please specify)

Frequency

Comments:

e. Are reports submitted to the owner from the management agent?
This question applies only to HUD Staff and Mortgagees.

Yes

No

Yes

No

Yes

No

N/A

Comments:
f. Are there signs enabling persons to locate the office?
Comments:

g. Are after hours and emergency telephone numbers posted?
Comments:

h. List the current insurance coverages (property, liability, Directors and Officers, workman’s compensation, automobile). (Check to make sure that HUD is listed as an
additional loss payee, if applicable. Also, check to make sure that the insurance policy is in the name of the mortgagor entity.)
This question applies only to HUD Staff and Mortgagees.
Type

Basic Coverage

Annual Premium

Property
Liability
Other (please specify)
Other (please specify)

Comments:
i. Does the owner/agent have a fidelity bond?
This question applies only to HUD Staff and Mortgagees.

Yes

No

N/A

Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 17 of 18

Management Review for Multifamily
Housing Projects
On-Site Review (Continued)

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

26. Owner/Agent Participation
This question applies only to HUD Staff and Mortgagees. CAs may proceed to question 27.)
a. If the project is owned by a cooperative or a nonprofit entity, does the Board of Directors meet regularly and record minutes?
Yes
No
Comments:
b. Review copies of the minutes. Does a review of the minutes indicate compliance with HUD’s business agreements?
Yes
Comments:

N/A

No

N/A

No

N/A

c. Does the owner/agent have a system or procedure for providing field supervision of on-site personnel?
Yes
Comments:
27. Staffing and Personnel Practices
a. Has management made an effort to employ tenants in accordance with Section 3 of the Housing and Community Development Act of 1968?
Yes
No
Comments:
b. List all on-site staff charged to the project. (Use additional sheets if necessary).
Staff Person /
Title

Date Hired

% of Time
Charged to
Site

Annual Salary

Unit Size

Is the Employee
Receiving Subsidy?

/

%

Yes

No

Is the Employee
occupying a
Non-Income
Producing Unit?
Yes
No

/

%

Yes

No

Yes

No

/

%

Yes

No

Yes

No

/

%

Yes

No

Yes

No

/

%

Yes

No

Yes

No

Comments:
c. Does the staffing chart above match Part D of the Rent Schedule, form HUD-92458 as it relates to non-income producing units?
HUD staff only.
Yes
No
Comments:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 18 of 18

ADDENDUM A
Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Tenant File Review Worksheet
Tenant File Review Worksheet
Instructions: Review the appropriate number of tenant files and complete a copy of this worksheet for each file reviewed. Indicate the initial
move-in date in the appropriate box. Indicate by marking the appropriate box (Yes, No, or N/A) for each document available in the tenant file. For
move-out and applicant rejections files, reviewer should only complete the pertinent sections.
Name of Reviewer:
Type of Review:
Applicant Rejection

Tenant Move-In

Tenant Move-Out

Certification/Recertification

Effective date of certification(s) reviewed:
If this is a Certification or Recertification, check the certification type:
Certification Type
Initial
Annual

Interim

Family Name:
Bedroom Size:

Corrections

Unit Number:
0 Bedroom

1 Bedroom

A. HOUSEHOLD INFORMATION
1. Is the application complete, including the date
and time received by the owner/agent?

2 Bedroom

3 Bedroom

4 Bedroom

Other

Move-in Date:
5 or more Bedrooms
Comments

Yes

No

2. Is there a form HUD-92006, “Supplement to
Application for Federally Assisted Housing” in
the files of tenants who applied after 12/14/2009?
Tenant completion of this form is optional.

Yes

No

N/A

3. Are the EIV Existing Tenant Search results in
the file along with contacts made as a result of
the search?
Applicable to move-ins after January 31, 2010

Yes

No

N/A

4. Are the household members identified
correctly? (as head, spouse, dependent, co-head,
other adult(s), live-in aide, foster child and foster
adult)

Yes

No

5. Is the unit size appropriate for household?

Yes

No

6. Was this household’s income eligible at
move-in?

Yes

No

N/A

This question applies only to a tenant file
move-in review.

Over income?
Very low income?

7. If household was not income eligible at movein, was an exception or waiver granted?

Yes

No

8. Does the file contain the ethnicity and racial
Data Certification as provided to the
owner/agent?

Yes

No

9. Is there current HUD 9887/9887A Consent
Form signed and dated by head, spouse, co-head
regardless of age, and family members at least 18
years of age?

Yes

No

Low income?
Extremely low income?

N/A

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 1 of 5

ADDENDUM A
Management Review for Multifamily
Housing Projects
Tenant File Review (Continued)
10. Is there an acknowledgement and/or signed
document in the file indicating receipt by the
tenant?
Lead based paint
Resident Rights and Responsibilities
Brochure
EIV & You Brochure
Fact Sheet on How Your Rent is
Determined

11. Does the tenant file indicate that the owner
/agent has taken necessary steps to address any
EIV reported receipt of multiple subsidies?

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Yes

No

N/A

Yes
Yes

No
No

Yes

No

Yes

No

N/A

Yes
Yes

No
No

N/A
N/A

12. Does the file contain documentation to verify
discrepant personal identifiers, and/or subsidy
paid, as reported on:
EIV Multiple Subsidy report?
EIV Deceased Tenant Report?

B. VERIFICATION
Have the following items been properly verified and documented?
1. Social Security numbers (except for those
Yes
No
exempted by 24 CFR 5.216)?
Yes
No
EIV Summary Report in file to validate SSNs?
Yes
No
Exemption from SSN disclosure?
2. Eligible immigration status or citizenship
status?
Yes
No

Comments

N/A
N/A

N/A

3. Criminal and drug screening?

Yes

No

4. State lifetime sex offender registration check
in each state where household members reported
they have resided, and/or background checks
conducted using a database that checks against all
state registries?

Yes

No

5. Other screening as disclosed in Tenant
Selection Plan?

Yes

No

N/A

6. Verification of:
Disability status?
Student status?
Ages of occupants?

Yes
Yes
Yes

No
No
No

N/A
N/A
N/A

C. LEASE
1. Is the correct HUD model lease used?

Yes

No

2. Are HUD issued lease addenda in the file?

Yes

No

3. Is the original lease and subsequent leases or
addenda signed and dated by the owner/agent,
head, spouse, co-head, and all other adult
members of the household?

Yes

No

Comments

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 2 of 5

ADDENDUM A
Management Review for Multifamily
Housing Projects
Tenant File Review (Continued)

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

4. Are applicable attachments attached to the
lease, e.g. house rules, pet rules, unit inspection
report?

Yes

No

5. If security deposit is required, is it in the
correct amount?

Yes

No

N/A

Yes

No

N/A

7. If a pet deposit was paid in installments, was
the payment schedule in accordance with the pet
regulations?

Yes

No

N/A

8. Are there inspections in the file:
Move-in (dated and signed by tenant and
owner/agent)?

Yes

No

Annual unit inspections?

Yes

No

If required, enter the amount here: $
6. If pet deposit is required, is it in the correct
amount?
If required, enter the amount here: $

N/A

D. CERTIFICATION/RECERTIFICATION ACTIVITIES
1. Are re-certification notices provided within
the required timeframes?
Yes
No
2. Are re-certifications completed on time?

Yes

No

3. Is the certification signed and dated by the
appropriate parties?

Yes

No

4. Has a 30-day notice of increase in rent been
provided to the tenant?

Yes

No

Comments

N/A

NOTE: If necessary, use additional sheets to complete applicable income information.
All reported income and deductions verified
and calculated correctly?

3rd Party Verification?

Amount
Reported
on 50059
$

5. Wages

EIV Income Report
Traditional 3rd party
Other
Not verified
N/A

6. Social Security benefits

EIV Income Report
Traditional 3rd party
Other
Not verified
N/A

$

7. Unemployment benefits

EIV Income Report
Traditional 3rd party
Other
Not verified
N/A

$

Comments
Did income information on the 50059 agree with verified file
information? If no, comment on discrepancies identified

8. Other Income
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 3 of 5

ADDENDUM A
Management Review for Multifamily
Housing Projects
Tenant File Review (Continued)

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Welfare/Public Assistance/TANF

Yes

No

N/A

$

Child Support

Yes

No

N/A

$

Pensions

Yes

No

N/A

$

Other ________________________

Yes

No

N/A

$

Yes

No

N/A

$

$

Checking Account

Yes

No

N/A

$

$

Savings Account

Yes

No

N/A

$

$

Certificates of Deposit

Yes

No

N/A

$

$

40lK/Keogh/Retirement Accounts

Yes

No

N/A

$

$

Real Estate

Yes

No

N/A

$

$

Yes

No

N/A

$

Dependent Allowance

Yes

No

N/A

$

Elderly/Disabled Household Allowance

Yes

No

N/A

$

Medical Expenses

Yes

No

N/A

$

Disability Expenses

Yes

No

N/A

$

Childcare Expenses

Yes

No

N/A

$

12. Are all expenses and allowances that are
claimed eligible under the HUD Handbook
4350.3 REV-1?

Yes

No

N/A

13. Has the household certified whether or not
they disposed of assets during the past two
years?

Yes

No

N/A

14. Is the correct unit rent being used for
subsidy determination?

Yes

No

Enter the reviewer verified amounts for the
following:
15. Contract Rent
$

Amount Reported on the
50059
$

OMB Approval No. 2502-0178
Exp. 11/30/2011

_____________________________
9. Actual Income from Assets

Cash Value

Other ________________________
_____________________________
10. Imputed income when assets are greater
than $5,000
11. Allowances/Expenses

Utility Allowance

$

$

Gross Rent

$

$

Total Tenant Payment

$

$

Tenant Rent

$

$

Utility Reimbursement

$

$

Assistance Payment

$

$

16. Is the tenant paying minimum rent?
If yes, was a hardship exception granted?
17. Were income discrepancies reported on the
EIV Income Discrepancy Report investigated,
resolved and file documented?

Yes

No

N/A

Yes

No

N/A

Yes

No

N/A

Did income information on the 50059 agree with the verified file
information? If not, comment on any discrepancies identified.

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 4 of 5

ADDENDUM A
Management Review for Multifamily
Housing Projects
Tenant File Review (Continued)
18. Has tenant entered into a written
repayment agreement for monies due to the
project?

Yes

No

N/A

Yes

No

N/A

19. Does file contain a re-certification as a
result of new employment reported on the EIV
New Hires Report?

Yes

No

N/A

If yes, is the new employment income included
in the reported annual income?

Yes

No

N/A

If yes, does the plan contain the required
information?

E. BILLING
1. Does the assistance payment requested on
the monthly billing (HUD-52670-A, Part 1)
agree with the assistance payment on the
applicable form HUD-50059?

Yes

No

N/A

2. If required, have adjustments been made to
the monthly billing?

Yes

No

N/A

Yes

No

2. Is there a move-out inspection?

Yes

No

If yes, enter the date of the inspection

Yes

No

3. Was the security deposit refunded to the
tenant within 30 days, or in accordance with
state or local laws, whichever is shorter?

Yes

No

N/A

4. Was an itemized list of damages and charges
provided to the tenant?

Yes

No

N/A

5. Were any additional charges paid by tenant?

Yes

No

N/A

6. Does the tenant move-out date on the
voucher match the date the tenant vacated?

Yes

No

F. MOVE-OUT FILE REVIEW ONLY
1. Is there a move-out notice from tenant?
If yes, Date of Notice
Move-out date

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

Comments

Comments

G. APPLICANT REJECTION REVIEW ONLY
1. Was the reason the applicant was denied
admittance in accordance with the Tenant
Selection Plan?
Yes

Comments

No

2. If the applicant requested, was the reason for
rejection provided in very specific terms and in
plain language?

Yes

No

3. Did the rejection letter provide the applicant
the right to appeal?

Yes

No

4. If the applicant appealed, was the appeal
reviewed by someone other than the person who
made the original decision?

Yes

No

N/A

5. Was the appeal processed and applicant
notified of the appeal decision within five days
of the meeting?

Yes

No

N/A

N/A

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 5 of 5

ADDENDUM B
Management Review for
Multifamily Housing Projects

U.S. Department of Housing
and Urban Development
Office of Housing – Federal Housing
Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

Office of Fair Housing and Equal Opportunity
And
Office of Multifamily Housing
Checklist for On-Site Limited Monitoring and Section 504 Reviews

Multifamily Housing (Housing) staff or Performance-Based Contract Administrators and Traditional Contract
Administrators (CA) must complete this Checklist when conducting on-site management reviews of subsidized and
unsubsidized multifamily housing projects. The questions on this checklist cover topics that the Housing staff or CA
can be expected to answer and is not intended to cover the full range of civil rights concerns.
NOTE: This document does not require the reviewer to make a determination of civil rights
or Section 504 compliance.
The Checklist is divided into four parts.
Part A: Occupancy/Accessible Units/Program Accessibility – This section, along with
instructions, must be forwarded to the owner/agent for completion prior to the on-site review.
This document must be included with the Documents Reviewer Should Obtain from Owner. See
Part D.
Part B: Limited On-Site Monitoring Review – The reviewer must complete this section during
the on-site management review of all projects.
Part C: Section 504 Review – The reviewer must complete this section during the on-site
management review for all federally-assisted projects.
Part D: Documents Reviewer Should Obtain from the Owner/Agent during the on-site
management review.
Please Note that a “No” response to any question does not necessarily mean there is
a fair housing or civil rights or a Section 504 violation.

Page 1 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

Project Name:
FHA /Project Number:
Section 8/PAC/PRAC Number:
Owner/General Partner Name:

Management Agent Name:

Owner/General Partner Address:

Management Agent Address:

Type of Development:

Cooperative

Elderly Only

Disabled Only

Elderly/Disabled

Family

Other(Specify)

Total Number of Units:

Total Subsidized Units:

Type of Federal Financial Assistance (check all that apply):
Section 8
Section 202
Section 202/8
Section 202 PRAC

Section 811

Section 221(d)(3)BMIR

Number of Units of Each Size: 0 BR
1 BR
Other (Specify)
Resident Manager’s Unit:

Yes

Section 202/PAC

2 BR

3 BR

Section 236
4 BR

Other
5 BR

No

Date of First Occupancy:
Service Coordinator Employed By Project?

Reviewed by:

Housing

Yes

PBCA

No

CA

Mortgagee

Reviewer:
Date:
Phone:
This Section is for Multifamily Housing Staff only:
After a review of the information provided by the owner/agent in Part A, the following as been determined:
The owner/agent is in compliance with Title VI, Subpart D of the Housing and Community Development
Act of 1992.
Possible noncompliance with Title VI, Subpart D of the Housing and Community Development Act of
1992. Referred to the local Office of Fair Housing and Equal Opportunity for additional review and appropriate action.
Title VI, Subpart D of the Housing and Community Development Act of 1992 - Not Applicable
Reviewed By:
(Name and Title)

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 2 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

Project Name:
FHA/Project#
Section 8/PAC/PRAC#
PART A
OCCUPANCY/ACCESSIBLE UNITS/PROGRAM ACCESSIBILITY
Authority:
Section 504 of the Rehabilitation Act of 1973 (24CFR Part 8)
Fair Housing Act/Title VIII Regulations (24 CFR Part 100.200)
Uniform Federal Accessibility Standards (UFAS) (24 CFR Part 40)
Regulatory Agreement
For this Part A, the reviewer must forward the form along with the instructions for completion to the owner/agent prior to the on-site review. For
subsidized projects, the owner/agent must complete the project information above and the information in Sections I, II, and III below. (See
attached instructions.) For unsubsidized projects, the owner/agent must complete the project information above and Sections I and II only.
Section III consists of Section 504 compliance, which does not apply to projects that do not receive federal financial assistance. The reviewer
will retrieve the completed form from the owner/agent during the on-site review.
SECTION I – OCCUPANCY
1. This property was designed primarily for:
Exclusively Elderly

2. Indicate the number of units currently occupied by client groups
below
Exclusively Elderly -

Exclusively Disabled

Exclusively Disabled -

Elderly and Disabled

Elderly/Disabled -

Near Elderly and Disabled

Near-Elderly Disabled -

Family

Family -

3. Is there a use agreement or any other document that indicates that this project must serve only elderly tenants?
Yes
No
If yes, specify type of document:
Effective Date:
Please attach a copy of the document(s) indicated above.

Unknown

4. If this project is a “covered Section 8 housing project” (see instructions), is there an occupancy preference for the elderly in accordance
with Section 651 of Title VI, Subpart D of the Housing and Community Development Act of 1992?
Yes
No
Refer to HUD Handbook 4350.3, REV-1.
If No, proceed to question 5.
If yes, please enter:
a. the date of the elderly preference:
b. the number of units that must be reserved for occupancy by non-elderly persons with disabilities
c. the date used to determine the number of units reserved for non-elderly persons with disabilities

, and,

5. Is there an occupancy restriction for the elderly in accordance with Section 658 of Title VI, Subpart D of the Housing and Community
Development Act of 1992?
Yes
No
Refer to HUD Handbook 4350.3, REV-1
6. Total Number of Units exclusively for
the Elderly

7. Total Number of Units exclusively for
Persons with Disabilities

8. Total Number of Units exclusively for
Non-Elderly Persons with Disabilities

I certify that this information is true and accurate.
Warning: HUD will prosecute false claims and statements. Convictions may result in criminal and/or civil penalties.
(18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 3 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

Signature of Owner

Date:

Project Name:
FHA/Project#
Section 8/PAC/PRAC#
SECTION II – ACCESSIBLE UNITS
Distribution of all wheelchair and other accessible units in the project.
Bedroom Size
0
1
2
3
4
5
1. All units

Other

Total

2. Total units with project-based
rental assistance
3. Mobility accessible units
4. Vision and/or Hearing
accessible units
*5. (Total Accessible Units)
6. Number of persons on waiting
list who have requested
accessible units
7. Number of accessible units
occupied by elderly or family
tenants
8. Number of accessible units
occupied by non-elderly tenants
with disabilities who require the
features of the unit
9. Number of accessible units
occupied by elderly tenants with
disabilities who require the
features of the unit
10. Percentage of Total Units with Project-Based Rental Assistance
Total line 2 Total line 1 x 100)
%
11. Percentage of Total Units that are mobility accessible
Total line 3 Total line 1 x 100)
%
12. Percentage of Total Units that are vision and/or hearing accessible
Total line 4 Total line 1 x 100)
%
* If a unit is both mobility accessible and vision or hearing accessible, count the unit only once in line 5.
I certify that this information is true and accurate.
Warning: HUD will prosecute false claims and statements. Convictions may result in criminal and/or civil penalties.

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 4 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

(18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)
Signature of Owner

Date:

Project Name:
FHA/Project#
Section 8/PAC/PRAC#
SECTION III – PROGRAM ACCESSIBILITY
SECTION 504 OF THE REHABILITATION ACT OF 1973
Section 504 Coordinator [24 CFR 8.53 (a)]
1. Does the recipient (as defined in 24 CFR 8.3) employ at least 15 employees?

Yes

No

Yes

No

If Yes, answer Question 2.; if No skip to Question 3.
2. Is at least one person designated to coordinate its Section 504 responsibilities?

N/A

If Yes, provide the person’s name and telephone number below.
Name:
Telephone Number:
Program Accessibility Under Section 504, a federally assisted Housing Development is required to ensure that its program is
usable by and accessible to persons with disabilities. This includes, but is not limited to, maintaining housing and non-housing
facilities that are structurally accessible for persons with disabilities. The extent to which facilities must be structurally
accessible depends in part, on whether they are new, altered, or existing. In addition, owner/agents are required to ensure that
appropriate and effective communication methods are used while communicating with persons with disabilities.
YES

NO

COMMENTS

3. Has the owner/agent taken steps to ensure
effective communication using:
a. Qualified sign language and oral
interpreters?
b. Readers?
c. Use of tapes?
d. Braille materials?
Other (Describe):
I certify that this information is true and accurate.
Warning: HUD will prosecute false claims and statements. Convictions may result in criminal and/or civil penalties.
(18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)
Signature of Owner
Date:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 5 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

INSTRUCTIONS FOR COMPLETING PART A
General instructions: Complete the project name, FHA/project number, and section 8/pac/prac information in the form header for each page:
SECTION I - Owner/Agent must respond to all questions in this section.
1. Check the appropriate box that the project was designed to serve. (Check only one box. Do not leave blank.)
Exclusively Elderly - defined as a person 62 years of age or older. (This option is for projects that were designed to serve only elderly
persons/families, i.e. Section 202 PRAC properties)
Exclusively Disabled – Refer to HUD Handbook 4350.3, REV-1, Figure 3-6 for the applicable definition of disability. (This option is for
projects that were designed to serve only persons with disabilities, i.e., Section 202/8 Projects for the Disabled and Section 811 projects.
Please note that Section 202/8 Projects for the Disabled were developed to serve only non-elderly persons with disabilities. However, the
Section 811 Projects were developed to serve persons with disabilities regardless of age as long as the minimum age requirement (age 18) is
met.)
Elderly and Disabled – defined as a property that serves the elderly and non-elderly persons with disabilities. (This option is for projects
that were originally designed to serve only elderly persons/families, however the owner may have elected a preference under Section 651 of
Title VI, Subpart D of the Housing and Community Development Act of 1992 ( Title VI Subpart D) to reserve a percentage of units for nonelderly persons with disabilities in accordance with the provisions of Section 652, Title VI Subpart D. See instruction 4 below for Section
651 definition.)
Family – defined as all persons regardless of age or disability. (This option is for projects that serve all families with no restrictions or
preferences as long as the minimum age requirement is met. Please note that family projects may have some units that are reserved for
persons with mobility/vision/hearing impairments which would require the applicant to meet the accessibility features of the unit.)
2. Enter the number of units occupied by each client group. (Please note that the term “near-elderly disabled” is defined as a person who is at
least 50 years of age and below the age of 62 with a disability as defined in HUD Handbook 4350.3, REV-1.)
Enter zero “0” if there are no units occupied by the listed client group – do not leave blank.
3. If there is a use agreement or other document requiring that the property must serve only elderly persons, answer “Yes”, in the space provided,
and attach a copy of the document(s). If there is no use agreement or other document requiring that the property must serve only elderly
persons, answer “No”. If you are unclear on the term “use agreement”, or are not able to locate the use agreement or other document that
defines the occupancy of your project, the answer is “unknown”. Other documents include the regulatory agreement, loan commitment
papers, financial documents, bid invitation, owner’s management plan, application for funding, and/or application for mortgage insurance.
Please refer to HUD Handbook 4350.3, REV-1, paragraphs 3-17 and 3-18. If you do not have a copy of HUD Handbook 4350.3, REV-1,
copies can be obtained from www.hudclips.org or the HUD Customer Service Center at (800) 767-7468.
4. Section 651 of Title VI Subpart D permits an owner to give preference1 to elderly families if (1) the project was originally developed to serve
the elderly and (2) it is a “covered Section 8 housing project.” “Covered Section 8 housing projects” are projects that were constructed or
substantially rehabilitated pursuant to assistance provided under section 8(b)(2) of the United States Housing Act of 1937, as in effect before
October 1, 1983, that are assisted under a contract for assistance under such section.
Section 651 of Title VI Subpart D applies to the following programs:
The Section 8 New Construction Program, 24 CFR part 880
The Section 8 Substantial Rehabilitation Program, 24 CFR part 881
The State Housing Agencies Program, insofar as it involves new construction and substantial rehabilitation, 24 CFR part 883
The New Construction Set-Aside for Section 515 Rural Rental Housing Projects Program, 24 CFR part 884
The Section 8 Housing Assistance Program for the Disposition of HUD-Owned Projects, insofar as it involves substantial
rehabilitation, 24 CFR part 886 subpart C
“Covered Section 8 housing projects” do not include those developed with funding under the following programs:
Section 202;
Section 202/8;
Section 202 or 811 PRAC;
Section 221 (d)(3); and/or
Section 236.
If an owner elects a Section 651 preference for the elderly, the owner must reserve a number of units for non-elderly persons/families with
disabilities. Title VI Subpart D requires that the owner review the occupancy records on January 1, 1992 and October 28, 1992, the date of
enactment for Title VI Subpart D, and determine the number of non-elderly persons with disabilities that occupied units on those two dates.
Compare the higher of the two numbers with 10 percent of total project units. The lower of the two resulting numbers must be reserved for nonelderly persons with disabilities, or families with disabilities.
For example, an owner has a covered Section 8 project that consists of 100 units, and decides to implement an elderly preference
under Section 651. The first thing the owner must do is find the occupancy records for January 1992 and see how many units
were occupied by non-elderly personswith disabilities, or families with disabilities, on January 1. In this example, it was 10 units.
Then the owner must find the occupancy records for October 1992 and see how many units were occupied by non-elderly
persons/families with disabilities on October 28th, the date of the enactment of the Act. In this example it was 15 units.
1

A “preference” allows an owner to give priority to elderly persons when selecting tenants for occupancy.
form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 6 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

To obtain the number of units that must be reserved for non-elderly disabled persons or families, the owner must take the higher
number of the two dates, which in this example is 15.
Then the owner will then compare that number 15 with a number that is 10 percent of the total project units In this example it’s 10.
Use the lower number for the number of units that must be reserved. Since 10 is less than 15, for this example the owner must
reserve 10 units for non-elderly disabled persons or families.
If an owner determines that there were no non-elderly persons or families occupying units on either January 1, 1992 or October 28,
1992, the required number of units to be reserved for non-elderly persons with disabilities would be zero (0). However, owners
are encouraged to exceed the number of reserved units for non-elderly persons with disabilities if a need exists in the community.
Answer question 4 as follows:
If there is an elderly preference in accordance with Section 651 of Title VI Subpart D, answer “Yes”. If there is no preference
provided to elderly families, answer “No”.
If yes, answer the following:
(a) If there is an occupancy preference in accordance with Section 651, indicate the effective date of the preference.
(b) If there is an occupancy preference in accordance with Section 651, indicate the total number of units that must be reserved
for non-elderly persons with disabilities based on the two dates above.
(c) If there is an occupancy preference in accordance with Section 651, indicate which date (see above) was used to determine
the number of units that must be reserved for non-elderly persons with disabilities.
5. Section 658 of Title VI, Subpart D of the Housing and Community Development Act of 1992 ( Title VI Subpart D) permits owners of “other
federally assisted housing” to continue to restrict occupancy to elderly families in accordance with the rules, standards, and agreements governing
occupancy in such housing in effect at the time the housing was developed. If (A) the project was originally developed to serve the elderly and
(B) the project has continually served elderly tenants. These projects include:
Section 202 Direct Loans (prior to the Section 202 PRAC program)
Section 221(d)(3) BMIR properties (New Construction and Substantial Rehabilitation)
Section 236 properties
Answer question 5 as follows:
If there is an elderly restriction in accordance with Section 658 of Title VI Subpart D, answer “Yes”. If there is no elderly restriction and
occupancy is not limited to elderly applicants, answer “No”.
6. If the property designates a number of units that can be occupied only by elderly persons, indicate the number of units. If the property does
not have units that can only be occupied by elderly persons, enter zero “0”.
7. If the property designates a number of units that can be occupied only by persons with disabilities, indicate the number of units. If the
property does not have units that can only be occupied by persons with disabilities, enter zero “0”.
8. If the property has units that must be occupied by non-elderly persons with disabilities, indicate the number of units. If the property does not
have units that must be occupied by non-elderly persons with disabilities, enter zero “0”.
CERTIFICATION:
Self-Explanatory Must be signed and dated by the owner.
SECTION II – Owner/Agent must respond to all questions in this section.
1. Enter the total number of units (by bedroom size) and enter total in the ”Total” column.
Totals must match numbers entered for each bedroom size.
2. Enter the total number of units (by bedroom size) that are receiving project based rental assistance.
Totals must match numbers entered for each bedroom size.
3. Enter the number of mobility accessible units by bedroom size, and enter the total in the “Total” column. A mobility accessible unit is one
that is located on an accessible route, and when designed, constructed, altered, or adapted, can be approached, entered, and used by individuals
with physical disabilities, including those who use wheelchairs. Although accessibility features include items such as grab bars, flashing fire
alarms, widened doorways, entrance ramps, etc, this question should be answered by stating the number of subsidized units that, when
constructed, are fully accessible in accordance with the Uniform Federal Accessibility Standards (UFAS) which is used to ensure compliance
with Section 504 of the Rehabilitation Act of 1973. These standards were jointly developed by the General Services Administration, the
Department of Housing and Urban Development, the Department of Defense, and the United States Postal Service, under the authority of sections
2, 3, 4, and 4a, respectively, of the Architectural Barriers Act of 1968, as amended, Pub. L. No.90-480, 42 U.S.C. 4151-4157. Copies of the
UFAS are available from the Architectural and Transportation Barriers Compliance Board , 1331 F Street, NW, Suite 1000, Washington, D.C.
20004-1111, Telephone: (202) 272-0080, email address: [email protected]. If the property is accessible in accordance with Minimum
Property Standards (MPS), indicate the number of units that are MPS accessible. Unsubsidized units should also be counted if they meet UFAS
compliance requirements.
Totals must match numbers entered for each bedroom size.
4. Enter the number of units, by bedroom size, that are accessible for vision or hearing disabilities and enter total in the “Total” column. Refer to
UFAS. See instruction number 3 above.
Totals must match numbers entered for each bedroom size.
5. Total the units from rows 3 and 4 for each bedroom size, and enter the total in the “Total” column.
Totals must match numbers entered for each bedroom size.

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 7 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

6. Enter the number of persons currently on the waiting list for an accessible unit, by bedroom size, requiring the features of the unit and enter
total in the “Total” column.
Total must match numbers entered for each bedroom size.
7. Enter the number of accessible units, by bedroom size, that are currently occupied by elderly or family tenants and enter total in the Total
column.
Total must match numbers entered for each bedroom size.
8. Enter the number of accessible units. by bedroom size, occupied by non-elderly tenants with disabilities requiring the features of the unit and
enter total in the “Total” column. These tenants must have a mobility impairment as defined above.
Total must match numbers entered for each bedroom size.
9. Enter the number of accessible units, by bedroom size, occupied by elderly tenants with disabilities requiring the features of the unit and enter
total in the “Total” column. These tenants must have a mobility impairment as defined above.
Total must match numbers entered for each bedroom size.
10. Self-explanatory
11. Self-explanatory
12. Self-explanatory
CERTIFICATION:
Self-Explanatory
Must be signed and dated by the owner.
SECTION III – Owner/Agent must respond to all questions in this section.
This Section is not applicable to unsubsidized projects.
1. The Section 504 Coordinator is required if the owner employs 15 or more people in all its activities. This includes this project combined
with other projects they may own and/or manage. Answer Yes or No. If Yes, proceed to question 2; if No, skip to question 3.
2. Answer Yes or No to this question. If Yes, please provide the name and telephone number of the coordinator for Section 504 related
activities at the project, and go to question 3.
3. Answer Yes or No to each item and provide comments as necessary.
CERTIFICATION:
Self-Explanatory
Must be signed and dated by the owner.

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 8 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

Project Name:
FHA/Project#
Section 8/PAC/PRAC#
PART B
ON-SITE LIMITED MONITORING REVIEW
Authority: 24 CFR 5, 108, 110

Questions 1 through 5 apply to owners of subsidized and unsubsidized projects.
YES

NO

COMMENTS

1. Was this project built or substantially
rehabilitated after February 1972?
(If NO, skip to Question 5.)
2. Does the owner have an approved
Affirmative Fair Housing Marketing Plan
(AFHMP)?
3. If there is an approved AFHMP as indicated
in question 2, is it available on site?
4. Has the owner/agent reviewed the AFHMP
within the last 5 years to ensure that the
information is current and applicable?
5. Date of last AFHMP Update
Date:
6. Does the project maintain Project Profile
Data which shows the composition of the
occupants by the following categories
(24 CFR 121):
a.
Race

b.

National Origin/Ethnicity

c.

Sex

d.

Disability

e.

Familial Status

7. Has the owner/agent developed and
implemented a written Tenant Selection
plan?

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 9 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

Project Name:
FHA/Project#
Section 8/PAC/PRAC#
YES

NO

COMMENTS

8. Does the management agent maintain a
waiting list of applicants by:

(a) Name

(b) Bedroom size

(c) Application date and time?

(d) Requests for accommodations and/or
accessible units?
(e) Preferences?

9. When a tenant/applicant notifies the
owner/agent that he/she has been subject to
unlawful discrimination, does the
owner/agent provide the applicant/tenant
with information about how to file a
complaint with HUD?

Unable to Observe

10. Does the owner/agent maintain a record of
fair housing complaints?

11. Is there a local residency preference?

If yes, was it approved by HUD?

Date of HUD Approval:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 10 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

Project Name:
FHA/Project#
Section 8/PAC/PRAC#

PART C
SECTION 504 REVIEW
The reviewer must complete this section to ensure compliance with Section 504 of the Rehabilitation Act of 1973 (Section 504).
Please note that unsubsidized projects are not required to comply with Section 504, therefore if the project is
unsubsidized, the reviewer may proceed to Part D.
YES

NO

COMMENTS

1. Is there a formal, written grievance procedure
that provides for resolution of complaints
alleging discrimination based on disability, as
required by Section 8.53(b)?
If Yes, document date procedures were
adopted:

Date:

2. Does the owner/agent utilize a
telecommunications device for the hearing
impaired (TTY)?
If No, Is there an alternative method?
Describe under “Comments”
3. When necessary, are auxiliary aides used to
communicate with persons with disabilities?
Describe under “Comments”

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 11 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

Project Name:
FHA/Project#
Section 8/PAC/PRAC#

PART D
DOCUMENTS REVIEWER SHOULD OBTAIN FROM OWNER/AGENT
The reviewer will only bring back documents upon request from FHEO. If the reviewer receives a request from FHEO to obtain
certain documents, indicate in column a. During the on-site review, request the documents and indicate the status in columns b,
c, or d. For items checked in column c, the reviewer must provide the owner/agent the FHEO address for forwarding the
documents.
Document(s)

a. FHEO has
requested that the
reviewer obtain the
following documents:

b. The document has
been gathered and is
attached to the Checklist

c. The Owner/
Agent agrees to
forward the
checked document
to FHEO within ten
(10) business days.

d. The document is not
available.

For Part A
1. Accessible Units/Program
Accessibility, Sections I, II, and III (as
applicable)
For Part B:
2. Most recent Affirmative Fair Housing
Marketing Plan (AFHMP)
3.

Any of the following documents that
are used for outreach as specifically
stated in the project’s AFHMP or used
for other affirmative fair housing
marketing.
Newspapers/Publications
Copy of Radio Ads and Announcements
Copy of TV Ads and Announcements
Photograph of billboards
Letterhead
Handouts
Brochures and Leaflets
Photograph and site signs
Other (Specify):

4.
5.

Project Profile showing occupancy data
(See Part B, Question 5).
Written Tenant Selection Plan

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 12 of 13

ADDENDUM B
OMB Approval No. 2502-0178
U.S. Department of Housing
Management Review for
Exp. 11/30/2011
and Urban Development
Multifamily Housing Projects Office of Housing – Federal Housing Commissioner
Checklist for On-Site Limited Monitoring and Section 504 Reviews (Continued)

Project Name:
FHA/Project#
Section 8/PAC/PRAC#

Please Note: The information below only
pertains to Section 504 compliance.

a. FHEO has
requested that the
reviewer obtain the
following documents:

b. The document has
been gathered and is
attached to the
Checklist.

If this project is unsubsidized, the
reviewer should not complete this section.

c. The Owner/
Agent agrees to
forward the
checked document
to FHEO within ten
(10) business days.

The document is not
available.

For Part C:
6.
Written Grievance Procedure (Part C,
Question 3 and 24 CFR 8.53)
7. Application for Occupancy
8.

Reasonable Accommodation Policy
FHEO requested that the reviewer observe the following:

The result of the observation is:

form HUD-9834 (08/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 13 of 13

ADDENDUM C
Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 11/30/2011

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

DOCUMENTS TO BE MADE AVAILABLE BY OWNER/AGENT
Project Name:

FHA/Project#

Section 8/PAC/PRAC#

Instructions: Reviewers should place a check mark next to those items that must be available for review. Included in this list are
FHEO staff instructions to provide MFH staff a list of requests for documents and special observations each year.
General Documents

`

All Tenant Files and records, including rejected, transfer and move-out files
Current waiting list
Last advertisement and/or copies of apartment brochures
HUD-approved Rent Schedule form HUD-92458
Procurement Files
Work Order Journals and Logs
Cash Disbursement Journal
Fidelity Bond
Property and Liability Insurance
Copies of the form HUD-52670 for the last twelve months, for each subsidy contract
Current annual budget
Quarterly budget variance reports
Reserve for Replacement component analysis
Copy of Rent Roll
Copy of Application form
Copy of lease, lease addenda and house rules
Copy of Pet Policy
Copy of Applicant Rejection Letter
Annual Unit Inspections
Fact Sheet “How Your Rent Is Determined”
Copy of the “Resident Rights & Responsibility”
Lead Based Paint Certifications
EH& S Certifications
All Operating Procedure Manuals
Documentation for Elderly Preferences Under Sections 651 or 658
Income Targeting and Tracking Log
List of all current Principals and Board Members
EIV Coordinator Access Authorization form(s) (CAAFs) – approved initial and current
EIV User Access Authorization form(s) (UAAFs) – approved initial and current
EIV Owner Approval Letter(s)
EIV Policies and Procedures
Rules of Behavior for individuals without access to the EIV system
Copy of TRACS Rules of Behavior, signed and dated
Copy of TRACs and EIV requested Security Awareness Training Certificate, signed and dated
Other

Civil Rights Front End Limited Monitoring and Section 504 Review Documents
Affirmative Fair Housing Marketing Plan
Tenant Selection Plan, including any approved residency preference
Recent advertising
Fair Housing logo and Fair Housing poster

form HUD-9834 (8/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

ADDENDUM D
Management Review for Multifamily
Housing Projects

U.S. Department of Housing and Urban Development
Office of Housing – Federal Housing Commissioner

OMB Approval No. 2502-0178
Exp. 11/30/2011

State Lifetime Sex Offender Statistics

Project Name:
FHA /Project Number:
Section 8/PAC/PRAC Number:

Instructions: Reviewers should record the below statistics on households that include a household member who is subject to a state lifetime sex offender
registration requirement.

1.

Number of households where, in accordance with the owner’s policies and procedures, a household member subject to a state lifetime sex offender
registration requirement was identified at re-certification.
Of the households identified at re-certification:
a.

How many were admitted prior to June 25, 2001, the effective date of the Screening and Eviction for Drug Abuse and Other Criminal
Activitiy final rule, and who had a household member subject to a state lifetime sex offender registration requirement at the time of
admission?
NOTE: These households (admitted prior to June 25, 2001) must not be evicted unless they commit criminal activity while living in
the federally assisted housing or have other lease violations.

2.

b.

How many were erroneously admitted?

c.

How many households include a member that became subject to a state lifetime sex offender requirement after admission?

Number of evictions due to the erroneous admission of a household with a member subject to a state lifetime sex offender registration requirement?

Number of such evictions upheld in court.
3.

Number of evictions due to a household member becoming subject to a state lifetime sex offender registration requirement after admission.

Number of such evictions upheld in court.

Public Reporting Burden for this collection is based on the size of the project and the level of compliance and is estimated to average 8 hours per response,
including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection
of information. This form replaces form HUD-9838, Management Review for Unsubsidized Multifamily Housing Programs. This information is required by 24
C.F.R. 880.612, 24 C.F.R. 884.224, 24 C.F.R. 886.130, 24 C.F.R. 891.450, and/or the Regulatory Agreement. This agency may not collect this information, and you
are not required to complete this form, unless it displays a currently valid OMB control number. The information is used by HUD to evaluate the quality of project
management, determine the causes of project problems, and devise collective actions to stabilize projects and prevent defaults. The information is gathered and
recorded during a review of project operations.
 
 
 

form HUD-9834 (8/2010)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2


File Typeapplication/pdf
File TitleManagement Review
AuthorHarry Messner
File Modified2011-11-30
File Created2011-11-29

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