Form HUD 9834 HUD 9834 Multifamily Housing Projects

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. 04/30/2018

PRA: 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. The 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. 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. HUD does not ensure confidentiality to respondents. 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

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 retrieves Addendum B and forwards the completed form to 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 (11/2012)

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. 02/28/2015

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: Insured HUD-Held Non-Insured Co-Insured	Contract Administrator: HUD CA PBCA	Type of Subsidy: Section 8 Rent Supplement PAC RAP Section 236 PRAC Section 221(d)(3) BMIR Unsubsidized	Type of Housing: 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	A	C	TCD	Enter a score between 1 and 100 for the General Appearance and Security Rating. If this Section was not reviewed, enter 0. is 10% of the overall score. This category is rated
General Appearance
Security
B. Follow-up and Monitoring of Project Inspections	A	C	TCD	Enter a score between 1 and 100 for the Follow-up and Monitoring of Project Inspections Rating . If this Section was not reviewed, enter 0. is 10% of the overall score. This category is rated
Follow-Up and Monitoring of Last Physical Inspection and Observations
Follow-Up and Monitoring of Lead-Based Paint Inspection
C. Maintenance and Standard Operating Procedures	A	C	TCD	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. This category is rated
Maintenance
Vacancy and Turnover
Energy Conservation
D. Financial Management/Procurement	A	C	TCD	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. This category is rated
Budget Management
Cash Controls
Cost Controls
Procurement Controls
Accounts Receivable/Payable
Accounting and Bookkeeping
E. Leasing and Occupancy	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. This category is rated
Application Processing/ Tenant Selection
Leases and Deposits
Eviction/Termination of Assistance Procedures
Enterprise Income Verification (EIV) System Access and Security Compliance
Compliance with Using EIV Data and Reports
Tenant Rental Assistance Certification Systems (TRACS) Monitoring and Compliance
TRACS Security Requirements
Tenant File Security
Summary of Tenant File Review
F. Tenant/Management Relations	A	C	TCD	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. This category is rated
Tenant Concerns
Provision of Tenant Services
G. General Management Practices	A	C	TCD	Enter a score between 1 and 100 for the General Management Practices Rating. If this Section was not reviewed, enter 0. is 10% of the overall score. This category is rated
General Management Operations
Owner/Agent Participation
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):

Signature: _

Date:

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

Signature:

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 (11/2012)

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. 02/28/2015

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:

• The condition describes the problem or deficiency

• The criteria cites 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
  Corrective actions are required for all findings.

Item Number

Finding

Target Completion Date

form HUD-9834 (11/2012) 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. 02/28/2015

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:

2. Were Exigent Health and Safety (EH&S) conditions cited in the report? B3

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 N/A

If not, list depository and amount of any construction escrows remaining.

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.

3. 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.

3. 

   

   Has a lead-based paint inspection been conducted? 4B Yes No Information Not Available
   Comments:

4. What were the results of the Lead-Based Paint Inspection/Evaluation: 4B

Was lead found? Yes No N/A

If yes, is there a HUD approved lead hazard control plan? Yes No N/A

Comments

3. 

   

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

Comments:

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

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

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 1 of 6

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. 02/28/2015

Desk Review (Continued)

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 Yes No N/A

Date last report was due:
Date last report received:

Monthly Accounting Report Yes No N/A

Excess Income Report (HUD-93479, 80, 81) Yes No N/A

Quarterly performance report for projects on flexible subsidy, modification, workout, etc. Yes No N/A

Annual operating budget (cooperatives) Yes No N/A

If the reports have been submitted, were they received in acceptable form? Yes No

Comments:

9. Has t he owner corrected all findings on HUD financial and/or Inspector General audits? Yes No N/A
   This question applies only to HUD Staff and Mortgagees.

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? Yes No
    This question applies only to HUD Staff. D10

Indicate latest OPIIS rating and check problem areas flagged by OPIIS.

Administrative Maintenance Utility Taxes and Insurance Financial

Also, use OPIIS to conduct an expense comparison with other similar projects.
Comments:

11. 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:

11. 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. $

11. 

    

    If applicable, have all deposits due to the residual receipts fund been made? Yes No
    This question applies only to HUD Staff.

Comments:

15. Based on the last FASS submission, are accounts payable reasonably current? Yes No

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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 2 of 6

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. 02/28/2015

Desk Review (Continued)

16. 

    

    Does the balance in the security deposit trust account equal or exceed the project’s liability account? Yes No
    This question applies only to HUD Staff and Mortgagees.

If no, explain how deficit will be funded.
Comments:

16. 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:

16. 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? Yes No
    This question applies only to HUD Staff and Mortgagees.

Comments:

19. 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:

19. Does the management agreement reflect HUD’s regulations and guidelines? Yes No N/A
    This question applies only to HUD Staff and Mortgagees.

Comments:

19. 

    

    Has a management entity profile been submitted to HUD? Yes No
    This question applies only to HUD Staff and Mortgagees.

If yes, is it relevant to the agent’s organization and how it operates? Yes No

Date of the management entity profile

19. 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:

19. 

    

    Have the principals and board members listed received HUD-2530 approval? Yes No N/A
    This question applies only to HUD Staff.

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? Yes No

This question applies only to HUD Staff and Mortgagees.

Comments:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 3 of 6

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. 02/28/2015

Desk Review (Continued)

Questions 26 –29 apply to OAHP restructuring. If not applicable proceed to question 30.

26. 

    

    Has the project’s mortgage been restructured? Yes No This question applies only to HUD Staff.

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:

26. Is the owner eligible for incentives? Yes No This question applies only to HUD Staff.

If yes, has the owner calculated those incentives correctly? (i.e., Capital Recovery Fee (CRF) and/or Incentive Performance Fee (IPF))

Yes No

Comments:

26. 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.

29. 

    

    Does the rental income generate excess income? Yes No N/A
    This question applies only to HUD Staff.

Comments:

29. 

    

    Has the owner/agent received approval to retain excess income? Yes No

This question applies only to HUD Staff. D13

Comments:

29. 

    

    Was an annual report submitted for usage of retained excess income? Yes No

This question applies only to HUD Staff. D13

Comments:

33. Are there any delinquent excess income payments due HUD? Yes No

This question applies only to HUD Staff. D13

If yes, is there a payment plan? Yes No

Comments:

33. Are rent increase requests submitted to HUD promptly when needed? Yes No
    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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 4 of 6

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. 02/28/2015

Desk Review (Continued)

35. 

    

    If approval is required, are rent increase requests submitted promptly? Yes No N/A
    Comments:

36. Complete chart below. (This question applies only to HUD Staff/Mortgagees)

Name of Reserve	As of			Held in Interest Bearing Account?
	Total	Per Unit	Monthly Deposit
Replacement Reserve	$	$	$	Yes No
General Operating Reserve (Co-ops)	$	$	$	Yes No
Residual Receipts	$	$	$	Yes No
Other	$	$	$	Yes No

1. Do balances in replacement or general operating reserve accounts appear adequate to meet future needs? Yes No

If not, what action is recommended?

2. 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:

37. If there is a utility allowance, what was the effective date of last utility allowance adjustment?

What was the date of approval?

If a utility allowance was approved was it implemented in accordance with HUD guidelines? Yes No
Comments:

37. What is the effective date of the last rent adjustment?
    Comments:

38. 

    

    Is the current approved rent schedule sufficient to meet project needs? Yes No
    This question applies only to HUD Staff.

Comments:

37. 

    

    Has a special rent increase been approved? Yes No N/A

If yes, please check the appropriate box. Insurance Taxes Utilities Security Service Coordinator
Comments:

37. 

    

    Are monthly rental subsidy vouchers submitted on time? Yes No N/A
    Comments:

38. 

    

    Is the owner/agent submitting tenant certification data to TRACS to support the voucher billings? Yes No N/A
    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:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 5 of 6

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. 02/28/2015

Desk Review (Continued)

45. What is the term of the subsidy contract? Date the contract term ends:
Comments:

46. 

    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

    
    

    46. 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

    New Hires Report Yes No

    Failed EIV Pre-Screening Report? Yes No

    Failed Verification Report (Failed the SSA Identity Test)? Yes No

    Deceased Tenant Report? Yes No

    Multiple Subsidy Report? Yes No
    Comments:

    46. Is there a Neighborhood Networks Center for the project? (Check iREMS or other available source) Yes No N/A

    If no, answer “N/A” and proceed to 50.

    Comments:

    46. 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:

    46. Are there any unresolved findings from previous management reviews? If yes, specify in the comments section.

    Yes No

    Comments:

    

    

    

    

    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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 6 of 6

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. 02/28/2015

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:

	Security

1. Indicate whether any of the events below have been documented in the last twelve months, and the frequency of the event(s).

Event	Frequency	Event	Frequency
Break-Ins		Arrests
Vandalism		Drug Activity
Auto Theft		Other (please specify):
Personal Assaults		None

Comments:

2. 

   

   Indicate which types of security measures, if any, are utilized on site.

Tenant Patrol Volunteer Organization Paid Car Patrol Paid on-site Guard

Police Patrol TV Monitor Drug Free Housing Plan Security Cameras

Motion Sensors Crime Prevention Plan Community Policing

Other (please specify) None

Comments:

3. Based on the answers provided in questions a and b above, what corrective actions, if any, have been taken by the owner/agent? Comments:

4. 

   

   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)

1. 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:

2. 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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 1 of 19

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. 02/28/2015

On-Site Review (Continued)

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.

1. 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:

2. 

   

   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:

2. Is there a satisfactory inventory system to account for tools, equipment, supplies, and keys (serial numbers, bar codes, etc.)?

Yes No

Comments:

2. Has the owner/agent secured inventory items, such as appliances and tools, to prevent theft? Yes No
   Comments:

3. 

   

   Does the owner/agent have a written procedure that explains the process for inspecting units? Yes No

If yes, review a copy.

Identify employee responsible for conducting the inspections: Name and Title:

Comments:

2. 

   

   How often are units inspected?

Monthly Quarterly Semi-Annually Annually Move-In Move-Out Other (please specify):

Comments:

2. How are unit inspections documented?
   Please Describe:

3. If deficiencies are noted during a unit inspection, what is the procedure for correction?
   Please describe:

4. What is the average number of days from move-out until the unit is ready for occupancy?
   Comments:

5. 

   

   Is there a written procedure for completing work orders? Yes No

If yes, review a copy.

Comments:

2. 

   

   Is there a procedure in place to handle emergency work orders? Yes No

If yes, describe the procedure:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 2 of 19

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. 02/28/2015

On-Site Review (Continued)

k. Is there a backlog of work orders? Yes 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:

12. Who is provided copies of completed work orders? (check all that apply.)

Tenant Tenant File Maintenance Staff Other (please specify)

Comments:

12. 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

1. 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:

2. 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:

3. 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 Rents too High

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)

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:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 3 of 19

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. 02/28/2015

On-Site Review (Continued)

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

1. Does the owner/agent’s staff have access to the current operating budget in order to monitor and control expenses?

Yes No N/A

Comments:

2. Is an operating budget prepared annually and approved by the owner? Yes No N/A

If yes, obtain a copy of the current year’s budget.

Comments:

3. 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:

4. If this is a 202 or 811 project, does the owner/agent maintain a current annual budget? Yes No N/A
   This question applies only to HUD Staff.

If yes, is it available on-site? Yes No

Comments:

9. Cash Controls

1. 

   

   Are collections deposited on the day received or, pending deposit, are they secured and properly controlled? Yes No
   Comments:

2. 

   

   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:

3. 

   

   Do different persons handle bank deposits and accounts receivable, or is an alternative safeguard used? Yes No

Indicate Names and Titles:
Comments:

3. Are all disbursement checks prenumbered, properly identified with account numbers and supported by vouchers or invoices?

Yes No

Comments:

3. 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:

3. 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:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 4 of 19

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. 02/28/2015

On-Site Review (Continued)

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:

2. 

   

   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:

2. Is there a written procedure for checking the quality of work performed by a contractor prior to authorizing payment?

Yes No

Comments:

2. Is there a procedure to assure that the individual authorizing contracted work or services is not the same individual authorizing payment?

Yes No

Comments:

2. Who is the responsible person charged with inspecting the quality of work performed by contractors prior to payment?
   Please provide the name and title:

3. 

   

   Does the project maintain a list of outside contractors? Yes No Comments:

4. 

   

   Are vendor bills paid in time to obtain maximum trade discounts? Yes No Comments:

5. 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	Name of Contractor		Annual Contract Amount
Elevator			$
Exterminating			$
Apartment Cleaning			$
Heating and A/C			$
Plumbing			$
Security			$
Trash Collection			$
Decorating			$
Grounds			$
Other			$

Comments:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 5 of 19

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. 02/28/2015

On-Site Review (Continued)

12. Accounts Receivable/Payable

1. 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.

Comments:

2. 

   

   Does the procedure for write-off of bad debts appear reasonable? Yes No
   Comments:

3. 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

1. Are books and records maintained as required by HUD Handbook 4370.2 (Chapter 4) and 24 CFR Part 5?

Yes No N/A

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 ( )

Comments:

2. Are all required project accounts in the name of the project in a federally insured institution? Yes No
   Comments:

3. Are operating funds, security deposits, reserve funds, and flexible subsidy funds maintained in separate accounts and properly secured for authorized use?

Yes No

Comments:

4. Does the mortgagor make frequent postings (at least monthly) to the ledger accounts? Yes No
   Comments:

5. 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:

5. Is centralized accounting used for disbursements? Yes No

If yes, are only HUD-insured projects in the pool? Yes No
Comments:

5. If centralized accounting is used, has it been approved by HUD Yes No N/A
   Comments:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 6 of 19

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. 02/28/2015

On-Site Review (Continued)

h. If centralized accounting is used, is it being administered in accordance with HUD’s approval? Yes No N/A

Comments:

9. If the trust account is part of a centralized disbursement account, are only HUD-insured projects in that account?

Yes No

If yes, is the project’s balance transferred to the project account at least once monthly? Yes No

Comments:

9. 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:

PROCEED TO PAGE 8 OF 19 FOR CATEGORY E. LEASING AND OCCUPANCY

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 7 of 19

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. 02/28/2015

On-Site Review (Continued)

CATEGORY E. LEASING AND OCCUPANCY (This Category does not apply to Mortgagees) 14. Application Processing and Tenant Selection

1. Does the application form contain sufficient information to determine applicant eligibility? Yes No

Comments:

2. Does the application ask whether the applicant or any member of the applicant’s household is subject to a liftetime state sex offender registration

program in any state? Yes No

Comments:

3. Does the application ask for a listing of states where the applicant and members of the applicant’s household have resided?

Yes No

3. 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:

3. Is there an arms length procedure between the person who denies an application and the application appeal reviewer?

Yes No

Comments:

3. 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:

3. 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:

3. 

   

   Does the project maintain a waiting list of prospective tenants? Yes No N/A

If yes, does the list include all required elements stated in Handbook 4350.3 REV-1? Yes No
Comments:

3. 

   

   

   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:

4. Were the applicants selected from the waiting list in the proper order, recognizing applicable preferences? Yes No
   Comments:

5. 

   

   When preferences were applied, were they properly documented? Yes No N/A
   Comments:

6. 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:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 8 of 19

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. 02/28/2015

On-Site Review (Continued)

n. Does the advertising program comply with the existing Affirmative Fair Housing Marketing Plan? Yes No

Request to see copies of advertisements.
Comments:

15. 

    

    Is the fair housing sign posted in the rental office? Yes No Comments:

16. 

    

    Is the fair housing logo included in published advertising materials? Yes No Comments:

15. Leases and Deposits

1. 

   

   Have modifications been made to the HUD model lease? Yes No N/A

If yes, has the lease and or lease addenda in use been approved by HUD? Yes No N/A

This does not include lease addenda issued by HUD

1. 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? Yes No N/A

Comments:

4. Are rents collected in accordance with the provisions of the lease? Yes No

Comments:

4. Is the policy for late fee assessment in compliance with the Handbook 4350.3 REV-1 or with state/local requirements?

Yes No

Comments:

4. Are damages caused by tenants properly identified and charged to tenants? Yes No

Comments:

16. Eviction/Termination of Assistance Procedures

1. Are tenants notified of termination of tenancy or assistance in accordance with HUD requirements? Yes No N/A

Comments:

2. Has the owner/agent pursued eviction or termination of assistance for all individuals subject to a lifetime sex offender registration requirement who were erroneously

admitted after June 25, 2001? Yes No N/A

Comments:

2. Are eviction procedures initiated timely, when warranted? Yes No N/A

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 Attorney on contract Attorney on call

NOTE: Addendum D must identify any eviction during the last 12 months which was due to a household member being subject to a state lifetime sex offender registration requirement.

Comments:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2

Page 9 of 19

Comments:

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. 02/28/2015

On-Site Review (Continued)

d. Is the termination of assistance initiated timely when warranted? Yes No N/A

Reason(s) for termination of assistance:

Comments:

17. Enterprise Income Verification (EIV) System Access and Security Compliance
Applies to subsidized properties only

1. 

   

   Does the owner/agent have access to EIV? Yes No
   Comments:

2. Does the EIV Coordinator(s) have an owner approval letter(s) authorizing access to EIV?

Yes No

Comments:

3. 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:

4. Is there evidence that staff with access to the EIV system or to EIV reports take annual security awareness training?

Yes No

Comments:

4. 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:

4. 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:

4. 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:

4. 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:

4. 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:

4. 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:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 10 of 19

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. 02/28/2015

On-Site Review (Continued)

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)?

Summary Report Yes No

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

Comments:

19. TRACS Monitoring and Compliance (applies to subsidized properties only)

1. 

   

   Is the owner/agent using TRACS queries to review and monitor their transmission? Yes No Comments:

2. 

   

   Is the owner/agent following up and correcting deficiencies identified in TRACS data? Yes No Comments:

20. TRACS Security Requirements (applies to subsidized properties only)

1. 

   

   Is the owner’s/agent’s “Rules of Behavior for TRACS” current (within last 12 months) and on file? Yes No
   Comments:

2. 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”?

Yes 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:

2. 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:

2. Is access to tenant file information limited to only authorized staff? Yes No
   Comments:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 11 of 19

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. 02/28/2015

On-Site Review (Continued)

d. Who is authorized to have access to the tenant files? Name(s) and Title(s):
Comments:

5. 

   

   Is the owner/agent maintaining tenant files according to HUD’s document retention requirements? Yes No Comments:

6. 

   

   Is the owner/agent properly disposing of tenant records (shred, burn, pulverize etc.)? Yes No 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 deficiencies utilizing the tenant file worksheet, Addendum A	Number of Files Reviewed =
(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

1. Are the applications in the files signed and dated by applicant? Yes No

Number of Files with Deficiencies:

Comments:

2. Is screening conducted in accordance with the Tenant Selection Plan? Yes No

Number of Files with Deficiencies:

Comments:

3. Are the unit sizes appropriate for household composition at the time of this tenant file review? Yes No

Number of Files with Deficiencies:

Comments:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 12 of 19

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. 02/28/2015

On-Site Review (Continued)

iv. If a household was ineligible at move in, were exceptions granted? Yes No N/A

Number of Files with Deficiencies:

Comments:

c. Lease

1. 

   

   Are the correct model leases used? Yes No

Number of Files with Deficiencies:

Comments:

2. 

   

   Are the leases signed and dated by all required parties? Yes No

Number of Files with Deficiencies:

Comments:

3. 

   

   Are HUD issued lease addenda properly signed and in the file? Yes No

Number of Files with Deficiencies:

Comments:

4. 

   

   Are the applicable addenda attached to the lease? Yes No Number of Files with Deficiencies:

Comments:

5. 

   

   Are security deposits collected in the correct amount for the program? Yes No N/A

Number of Files with Deficiencies:

Comments:

6. 

   

   Are pet deposits within acceptable range and payment installments allowed? Yes No N/A

Number of Files with Deficiencies:

Comments:

7. Do the tenant files contain signed acknowledgement(s) and/or copies as required of the following documents indicating receipt by the tenant?

HUD-9887 Fact Sheet Yes No

Number of Files with Deficiencies:

Lead Based Paint Disclosure Yes No N/A
Number of Files with Deficiencies:

Resident Rights and Responsibilities Brochure Yes No
Number of Files with Deficiencies:

EIV & You Brochure Yes No
Number of Files with Deficiencies:

Fact Sheet How Your Rent is Determined Yes No
Number of Files with Deficiencies:

Race/Ethnicity Form Yes No

Number of Files with Deficiencies:

Comments:

d. Certification/Re-Certification Activities:

i. Are re-certification notices issued in accordance with HUD requirements? Yes No N/A
Number of Files with Deficiencies:

Comments:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 13 of 19

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. 02/28/2015

On-Site Review (Continued)

2. 

   

   Are certifications completed on time? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 

   

   Are all necessary verifications completed and properly documented? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 

   

   Are EIV Income Reports used for third party verification of employment and income? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 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:

2. 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:

2. 

   

   Are income and deductions calculated correctly prior to data entry? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 

   

   Does income information on the tenant certifications agree with verified file information? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. If tenants were granted a hardship exemption as part of the minimum rent, was the exemption applied correctly?

Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 

   

   Are Repayment Agreements in accordance with HUD requirements? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 14 of 19

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. 02/28/2015

On-Site Review (Continued)

12. 

    

    Are the correct contract rents used when determining the subsidy to be paid on behalf of tenants? Yes No N/A

Number of Files with Deficiencies:

Comments:

12. If tenants are paying their own utilities, are the current certifications reflecting the correct utility allowances?

Yes No N/A

Number of Files with Deficiencies:

Comments:

12. Are utility reimbursement checks distributed within 5 business days of receipt of the housing assistance payments?

Yes No N/A

Number of Files with Deficiencies:

Comments:

e. Voucher Billing

1. 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:

2. For the move-in/move-out tenant file review, does the owner/agent make appropriate voucher adjustments?

Yes No N/A

Number of Files with Deficiencies:

Comments:

f. Move-In Files

1. 

   

   Are proper income limits used for determining eligibility at move-in? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 

   

   Do the files contain move-in inspections? Yes No N/A

Number of Files with Deficiencies:

Comments:

3. If the files contain move-in inspections, have the owner/agent and the tenant signed and dated the inspection?

Yes No N/A

Number of Files with Deficiencies:

Comments:

4. 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? Yes No N/A

Number of Files with Deficiencies:

Comments:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 15 of 19

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. 02/28/2015

On-Site Review (Continued)

2. 

   

   Are move-out inspections conducted? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 

   

   Are security deposits refunded in 30 days or less if required by state law? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 

   

   Are tenants provided an itemized list of charges against the security deposits? Yes No N/A

Number of Files with Deficiencies:

Comments:

2. 

   

   If charges exceed the security deposit, are the tenants billed for the balance due? Yes No N/A

Number of Files with Deficiencies:

Comments:

h. Application Rejection Files

1. 

   

   Are applicants denied admittance in accordance with the Tenant Selection Plan? Yes No N/A

Number of Files with Deficiencies:

Comments:

12. 

    

    Do rejection letters provide applicants the right to appeal? Yes No N/A

Number of Files with Deficiencies:

Comments:

12. 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:

12. Were appeals processed and applicants notified of the appeal decision within 5 days of the meeting?

Yes No N/A

Number of Files with Deficiencies:

Comments:

CATEGORY F. TENANT/MANAGEMENT RELATIONS (This Category does not apply to Mortgagees)

23. Tenant Concerns

1. Is there a written procedure for resolving tenant complaints or concerns? If yes, review a copy. Yes No

Comments:

2. Does the procedure adequately cover appeals? Yes No
   Comments:

3. Is there an active tenant organization at this project? Yes No
   Comments:

4. Is tenant involvement in project operations encouraged? Yes No
   Comments:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 16 of 19

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. 02/28/2015

On-Site Review (Continued)

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.

Provider

Financial Source

Service

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? Yes No

If there is no Service Coordinator, proceed to question 24.f.

Comments:

3. 

   

   Is the Service Coordinator’s office clearly identifiable and private? Yes No Comments:

4. 

   

   Are the Service Coordinator’s files kept secure and confidential? Yes No Comments:

5. Does the Service Coordinator maintain a directory of service agencies and contacts, and make the information available to all parties?

Yes No

Comments:

3. 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:

3. 

   

   What programs are offered at the Neighborhood Networks Center?

GED Adult Basic Education Computer Classes Job Training Job Placement

Homework Assistance English as a Second Language Other (please specify)

Comments:

3. 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:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 17 of 19

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. 02/28/2015

On-Site Review (Continued)

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:

CATEGORY G. GENERAL MANAGEMENT PRACTICES

25. General Management Operations

1. 

   

   Have the complaints, as noted on the Desk Review, been satisfactorily resolved? Yes No N/A
   Comments:

2. 

   

   Is the project staff able to adequately perform management and maintenance functions? Yes No
   Comments:

3. How does the owner/agent implement HUD changes in policies and procedures?
   Describe the process:

4. 

   

   Does owner/agent have a formal ongoing training program for its staff? Yes No
   If yes, indicate types of training used and the frequency.

Type	Frequency		Type	Frequency
On-Site			Industry/Association Training
HUD Seminars			Local Colleges
Energy Conservation			Other (please specify)

Comments:

5. 

   

   Are reports submitted to the owner from the management agent? Yes No N/A
   This question applies only to HUD Staff and Mortgagees.

Comments:

6. 

   

   Are there signs enabling persons to locate the office? Yes No Comments:

7. 

   

   Are after hours and emergency telephone numbers posted? Yes No 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:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 18 of 19

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. 02/28/2015

On-Site Review (Continued)

i. Does the owner/agent have a fidelity bond? Yes No N/A

This question applies only to HUD Staff and Mortgagees.

Comments:

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 N/A

Comments:

2. Review copies of the minutes. Does a review of the minutes indicate compliance with HUD’s business agreements?

Yes No N/A

Comments:

2. Does the owner/agent have a system or procedure for providing field supervision of on-site personnel?

Yes No N/A

Comments:

27. Staffing and Personnel Practices

1. Has management made an effort to employ tenants or other qualified local low­income or very low­income persons in accordance

with Section 3 of the Housing and Urban Development Act of 1968? Yes No

Comments:

2. 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?		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	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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 19 of 19

ADDENDUM A

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. 02/28/2015

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:	Certification/Recertification Corrections Other
Type of Review: Applicant Rejection Tenant Move-In Tenant Move-Out Effective date of certification(s) reviewed: If this is a Certification or Recertification, check the certification type: Certification Type Initial Annual Interim
Family Name:	Unit Number:	Move-in Date:
Bedroom Size: 0 Bedroom 1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom 5 or more Bedrooms

A. HOUSEHOLD INFORMATION					Comments
Is the application complete, including the date and time received by the owner/agent?	Yes	No
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
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
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
Is the unit size appropriate for household?	Yes	No
Was this household’s income eligible at move-in? This question applies only to a tenant file move-in review.	Yes	No	N/A
				Over income? Very low income?	Low income? Extremely low income?
If household was not income eligible at move- in, was an exception or waiver granted?	Yes	No	N/A
Does the file contain the ethnicity and racial Data Certification as provided to the owner/agent?	Yes	No
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

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 1 of 5

ADDENDUM A

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. 02/28/2015

Tenant File Review (Continued)

10. Is there an acknowledgement and/or signed document as required 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	Yes No N/A Yes No Yes No Yes No
Does the tenant file indicate that the owner /agent has taken necessary steps to address any EIV reported receipt of multiple subsidies?	Yes No N/A
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?	Yes No N/A Yes No N/A
B. VERIFICATION Have the following items been properly verified and documented?		Comments
Social Security numbers (except for those exempted by 24 CFR 5.216)? EIV Summary Report in file to validate SSNs? Exemption from SSN disclosure?	Yes No Yes No N/A Yes No N/A
Eligible immigration status or citizenship status?	Yes No N/A
Criminal and drug screening?	Yes No
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
Other screening as disclosed in Tenant Selection Plan?	Yes No N/A
Verification of: Disability status? Student status? Ages of occupants?	Yes No N/A Yes No N/A Yes No N/A
C. LEASE		Comments
Is the correct HUD model lease used?	Yes No
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
Are applicable attachments attached to the lease, e.g. house rules, pet rules, unit inspection report?	Yes No

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 2 of 5

ADDENDUM A

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. 02/28/2015

Tenant File Review (Continued)

If security deposit is required, is it in the correct amount? If required, enter the amount here: $		Yes No N/A
If pet deposit is required, is it in the correct amount? If required, enter the amount here: $		Yes No N/A
If a pet deposit was paid in installments, was the payment schedule in accordance with the pet regulations?		Yes No N/A
Are there inspections in the file: Move-in (dated and signed by tenant and owner/agent)? Annual unit inspections?		Yes No Yes No N/A
D. CERTIFICATION/RECERTIFICATION ACTIVITIES			Comments
Are re-certification notices provided within the required timeframes?		Yes No
Are re-certifications completed on time?		Yes No
Is the certification signed and dated by the appropriate parties?		Yes No
Has a 30-day notice of increase in rent been provided to the tenant?		Yes No N/A
NOTE: If necessary, use additional sheets to complete applicable income information.
			Comments
All reported income and deductions verified and calculated correctly?	3rd Party Verification?		Amount Reported on 50059	Did income information on the 50059 agree with verified file information? If no, comment on discrepancies identified
Wages	EIV Income Report Traditional 3rd party Other Not verified N/A		$
Social Security benefits	EIV Income Report Traditional 3rd party Other Not verified N/A		$
Unemployment benefits	EIV Income Report Traditional 3rd party Other Not verified N/A		$

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 3 of 5

ADDENDUM A

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. 02/28/2015

Tenant File Review (Continued)

Other Income Welfare/Public Assistance/TANF Child Support Pensions Other	Yes No N/A Yes No N/A Yes No N/A Yes No N/A	$ $ $ $
Actual Income from Assets Checking Account Savings Account Certificates of Deposit 40lK/Keogh/Retirement Accounts Real Estate Other	Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A	$ $ $ $ $ $	Cash Value $ $ $ $ $ $
Imputed income when assets are greater than $5,000	Yes No N/A	$
Allowances/Expenses Dependent Allowance Elderly/Disabled Household Allowance Medical Expenses Disability Expenses Childcare Expenses	Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A	$ $ $ $ $
Are all expenses and allowances that are claimed eligible under the HUD Handbook 4350.3 REV-1?	Yes No N/A
Has the household certified whether or not they disposed of assets during the past two years?	Yes No N/A
Is the correct unit rent being used for subsidy determination?	Yes No
Enter the reviewer verified amounts for the following:	Amount Reported on the 50059	Did income information on the 50059 agree with the verified file information? If not, comment on any discrepancies identified.
Contract Rent $ Utility Allowance $ Gross Rent $ Total Tenant Payment $ Tenant Rent $ Utility Reimbursement $ Assistance Payment $	$
	$ $ $ $ $ $
Is the tenant paying minimum rent? If yes, was a hardship exception granted?	Yes No N/A Yes No N/A
Were income discrepancies reported on the EIV Income Discrepancy Report investigated and the file documented with the resolution?	Yes No N/A

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 4 of 5

ADDENDUM A

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. 02/28/2015

Tenant File Review (Continued)

Has tenant entered into a written repayment agreement for monies due to the project? If yes, does the plan contain the required information?	Yes Yes	No No	N/A N/A
Does file contain a re-certification as a result of new employment reported on the EIV New Hires Report? If yes, is the new employment income included in the reported annual income?	Yes Yes	No No	N/A N/A
E. BILLING				Comments
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
If required, have adjustments been made to the monthly billing?	Yes	No	N/A
F. MOVE-OUT FILE REVIEW ONLY				Comments
Is there a move-out notice from tenant? If yes, Date of Notice	Yes	No
Move-out date
Is there a move-out inspection? If yes, enter the date of the inspection	Yes Yes	No No
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
Was an itemized list of damages and charges provided to the tenant?	Yes	No	N/A
Were any additional charges paid by tenant?	Yes	No	N/A
Does the tenant move-out date on the voucher match the date the tenant vacated?	Yes	No
G. APPLICANT REJECTION REVIEW ONLY				Comments
Was the reason the applicant was denied admittance in accordance with the Tenant Selection Plan?	Yes	No
Was the reason for rejection provided in specific terms and in plain language?	Yes	No	N/A
Did the rejection letter provide the applicant the right to appeal?	Yes	No
If the applicant appealed, was the appeal reviewed by someone other than the person who made the original decision?	Yes	No	N/A
Was the appeal processed and applicant notified of the appeal decision within five days of the meeting?	Yes	No	N/A

form HUD-9834 (11/2012) 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. 02/28/2015

Office of Fair Housing and Equal Opportunity

And

Office of Multifamily Housing

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP 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 or ADA 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/ADA Review – The reviewer must complete this section during the on-site management review for all federally-assisted projects and projects that are a program or activity of a state or local government.

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 or ADA violation.

Page 1 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP 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/PAC

Section 202 PRAC Section 811 Section 221(d)(3)BMIR Section 236 Other

Is the project a program or activity of a state or local government? Yes [explain]__________No_____

Number of Units of Each Size: 0 BR 1 BR 2 BR 3 BR 4 BR 5 BR

Other (Specify)

Resident Manager’s Unit: Yes No

Date of First Occupancy:

Service Coordinator Employed By Project? Yes No

	Reviewed by: Housing PBCA 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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 2 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP 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 (24 CFR Part 8)

Americans with Disabilities Act (ADA) (28 CFR Part 35).

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 and projects that are a program or activity of a state or local government, 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 that are not a program or activity of a state or local government, the owner/agent must complete the project information above and Sections I and II only. Section III consists of Section 504 and ADA compliance, which does not apply to projects that do not receive federal financial assistance that are not programs or activities of a state or local government. 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 Exclusively Disabled Elderly and Disabled Near Elderly and Disabled Family		2. Indicate the number of units currently occupied by client groups below Exclusively Elderly -
			Exclusively Disabled -
			Elderly/Disabled -
			Near-Elderly Disabled -
			Family -
3. Is there a use agreement or any other document that indicates that this project must serve only elderly tenants? Yes No Unknown If yes, specify type of document: Effective Date:
Please attach a copy of the document(s) indicated above.
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:
the number of units that must be reserved for occupancy by non-elderly persons with disabilities , and, the date used to determine the number of units reserved for non-elderly persons with disabilities
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)
Signature of Owner				Date:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 3 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP Reviews (Continued)

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	Other	Total
All units
Total units with project-based rental assistance
Mobility accessible units
Vision and/or Hearing accessible units
*5. (Total Accessible Units)
Number of persons on waiting list who have requested accessible units
Number of accessible units occupied by elderly or family tenants
Number of accessible units occupied by non-elderly tenants with disabilities who require the features of the unit
Number of accessible units occupied by elderly tenants with disabilities who require the features of the unit
Percentage of Total Units with Project-Based Rental Assistance Total line 2 Total line 1 x 100) %
Percentage of Total Units that are mobility accessible Total line 3 Total line 1 x 100) %
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. (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)
Signature of Owner	Date:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 4 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP Reviews (Continued)

Project Name:

FHA/Project#

Section 8/PAC/PRAC#

SECTION III – PROGRAM ACCESSIBILITY
SECTION 504 OF THE REHABILITATION ACT OF 1973 AND THE AMERICANS WITH DISABILITIES ACT OF 1990
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
   If Yes, answer Question 2.; if No skip to Question 3.

2. 

   

   Is at least one person designated to coordinate its Section 504 responsibilities? Yes No N/A

If Yes, provide the person’s name and telephone number below.

Name:

Telephone Number:

ADA Coordinator [28 CFR 35.107(a)]

3. Is the project a program or activity of a state or local government? Yes No

4. If yes, does the public entity employ 50 or more persons? Yes No

5. If yes, has the entity designated at least one employee to coordinate its ADA responsibilities? Yes No

If yes, provide the person’s name and telephone number below.

Name: ____

Telephone Number: ______

Program Accessibility Under Section 504, a federally assisted Housing Development, and under the ADA, a program or activity of a state or local government, 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
6. Has the owner/agent taken steps to ensure effective communication using:
Qualified sign language and oral interpreters?
Readers?
Use of tapes?
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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 5 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP 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 non-elderly 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 non-

elderly 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 28^th, 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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 6 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP 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:

1. If there is an occupancy preference in accordance with Section 651, indicate the effective date of the preference.

2. 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.

3. 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”.

5. 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”.

6. 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”.

7. 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) or the Deeming Notice, 79 Fed. Reg. 29,671 (May 23, 2014), which are used to ensure compliance with Section 504 of the Rehabilitation Act of 1973. UFAS was 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 Access 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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 7 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP 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.

6. 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.

6. 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.

6. 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.

6. Self-explanatory

7. Self-explanatory

8. 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 that are not programs or activities of state or local governments.

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. An ADA coordinator is required if the project is a program or activity of a state or local government, and if the entity employs 50 or more people. Answer Yes or No. If Yes, proceed to question 4; if No, skip to question 6.

4. Answer Yes or No. If Yes, proceed to question 5; if No, skip to question 6.

5. Answer Yes or No to this question. If Yes, please provide the name and telephone number of the ADA coordinator.

6. 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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 8 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP 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):
Race
National Origin/Ethnicity
Sex
Disability
Familial Status
7. Has the owner/agent developed and implemented a written Tenant Selection plan?

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 9 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP 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:
Name
Bedroom size
Application date and time?
Requests for accommodations and/or accessible units?
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 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 10 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP Reviews (Continued)

Project Name:

FHA/Project#

Section 8/PAC/PRAC#

PART C

SECTION 504/ADA REVIEW

The reviewer must complete this section to ensure compliance with Section 504 of the Rehabilitation Act of 1973 (Section 504) and Title II of the Americans with Disabilities Act (ADA). Please note that unsubsidized projects that are not programs or activities of state or local governments are not required to comply with Section 504 or the ADA, therefore if the project is unsubsidized and not a program or activity of a state or local government, the reviewer may proceed to Part D.

	YES	NO	COMMENTS
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 the project is unsubsidized and is a program or activity of a state or local government, is there a complaint procedure as required by 28 C.F.R. 35.107(b)?
If Yes, document date procedures were adopted:			Date:
Does the owner/agent utilize a telecommunications device for the hearing impaired (TTY)?
If No, Is there an alternative method? Describe under “Comments”
Does the owner furnish appropriate auxiliary aids and services where necessary to afford persons with disabilities an equal opportunity to participate in the housing and related programs or activities? Describe under “Comments”

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 11 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP 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

Accessible Units/Program Accessibility, Sections I, II, and III (as applicable)

For Part B:

Most recent Affirmative Fair Housing Marketing Plan (AFHMP)

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):

Project Profile showing occupancy data (See Part B, Question 5).

Written Tenant Selection Plan

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 12 of 13

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. 02/28/2015

Checklist for On-Site Limited Monitoring and Section 504, ADA, and AFHMP Reviews (Continued)

Project Name:

FHA/Project#

Section 8/PAC/PRAC#

Please Note: The information below only pertains to Section 504/ADA compliance. If this project is unsubsidized and is not a program of a state or local government, the reviewer should not complete this section.	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.	The document is not available.
For Part C:
Written Grievance Procedure (Part C, Question 1 and 24 CFR 8.53 and 28 CFR 35.107(b))
Application for Occupancy
Reasonable Accommodation Policy

FHEO requested that the reviewer observe the following:

The result of the observation is:

form HUD-9834 (11/2012) Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2 Page 13 of 13

ADDENDUM C

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. 02/28/2015

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, ADA, and AFHMP 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 (11/2012)

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. 02/28/2015

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:

1. 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. How many were erroneously admitted?

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

2. 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.

form HUD-9834 (11/2012)

Ref. HUD Handbook 4350.1, REV-1 and HUD Handbook 4566.2