How To Conduct Your Own Tenant File Audit Presented by Rose Dubin CPM COS C4P Disclaimer I am not a HUD Employee I am not an Attorney I am not a Contract Administrator I am a HUD and Tax Credit ID: 563082
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Slide1
MAHMA Conference Slide2
How To Conduct Your Own Tenant File Audit
Presented
by
Rose Dubin, CPM, COS C4PSlide3
Disclaimer
I am not a HUD EmployeeI am not an Attorney
I am not a Contract Administrator
I am
a
HUD and Tax Credit
consultant/contractorSlide4
Are
You Ready?
The PBCA Contract
Administrators
may be
scheduled to resume Management and Occupancy
Review (MORs)
this
year. Will your property be one of the ones chosen?
Are you currently being reviewed annually?
What are/will HUD and Contract
Administrators will be looking for? How to prepare your tenant files, to be in compliance with HUD’s rules & regulations. Slide5
What Are the Tools Needed to Begin?
HUD 4350.3 Manual
Manual or Electronic
Tenant File Review Worksheet
(In the 9834 Packet – Pages 29-33)
Internet Access
Document Checklist
Calculator with tape
Current Tenant FilesSlide6
HUD 4350.3 Manual Change 4
All other HUD Manual
All other HUD Manuals 4350.3 are obsolete
Can easily download to your desktop
Includes Chapter 9 for EIV
Be sure you have the November 2013 version
Includes all of the attachmentsSlide7
HUDCLIPS
Be sure to sign up for the RHIIP Listserv for the newest and latest information being disseminated by HUD
http://portal.hud.gov/hudportal/HUD?src=/
subscribe/mailinglist
Always check HUDCLIPS (or rely on your Compliance Director) for most current forms being used for content and expiration dates.
Once forms have new dates
discard the old forms.
Slide8
Tenant file review worksheet – In 9834 PacketSlide9
Applications
Do you review them for completion and accuracy?
Are you still placing the time and date received on the application and transferring that information to your waiting list?
Although no longer required by HUD, does your applicant sign to attest to the accuracy of the information?
Are you asking how the applicant came to your site? Best source of Marketing.Slide10
Move-In
Have you correctly identified all household members on HUD 50059? Unit size appropriate for the household?
If applicable, are you tracking income targeting? Based on your TSP?
HUD 92006?
Have you run the Existing Tenant Search
for all family members
and
printed out results prior to move in?Slide11
What is Considered Move-In DATA
Application 92006
SS# for each family member * Eligible Citizenship
Credit/criminal/sex offender
screening Student Certification
Landlord references Attachments
Addendums (HUD Approved) Disability
, if applicable
Verification of age
House
Rules/Manual
VAWA (Each 18 & up) Move-in InspectionPet Rules, if applicable Existing Tenant SearchRace and Ethnicity Form (voluntary) Security/Pet Deposit
Required company/state/city forms Move-in 50059 & Docs
HUD model lease OMB approval date 12/2007Slide12
Move-In Information
Is all of your tenant move-in
information stored on the
left side of your file folder?
How
many years of recertification's are you required to keep in the tenant file
?How long are you required to keep the tenant files after the tenant has moved out?What document does HUD not require you to retain after you have printed the EIV and viewed
Income Summary
Report that the tenant(s) are “Verified”?Slide13
File Order checklistSlide14
Documents Received Checklist
How are you listing the documents your tenants receive at move-in and recerts?
Are you sure you are giving them all of the correct documents?
Are you making copies of the first pages of the docs you are distributing?
Do you get the tenants signature
that they received them?Slide15
Acknowledgement of Documents
Tenant Acknowledgement of Documents for Move-in/Recertification of 1/1/16I, John Smith Unit 1234 have received the following documents
____
Lease
____
House Rules and Regulations
____
Bed bug policy____Resident Handbook ____How Rent is Determined____Pet Rules, if applicable ____The Fraud document____Violence Against Women Addendum ____Tenant/Landlord Summary
____Initial Notice
____Smoke
Detector____TIC (Tax Credit Properties only) ____Parking Agreement____EIV letter to resident’s ____Drug-free housing____EIV and You brochure ____Lead-based paint disclosure____Owners Notice #1 from Non-citizen packet ____Other attachments ____9887 Fact Sheet ____
Insurance release Agreement
____Residents Rights and Responsibilities
____
Move-in inspection
____Mold Attachment, if applicable
____
Security deposit interest information
____Emergency Response system for and
Release, if applicable
By signing below, the resident acknowledges that the above documents or copies have been received
______________________________________ __________________________
Residents Signature
Date
______________________________________ __________________________
Residents Signature
Date
______________________________________ __________________________
Residents Signature
Date
Mgr Int: ________Slide16
Recertification Activities
Do you send your initial recertification notice out 120 days prior to the effective date?Are your 2nd
and 3
rd
notices sent out on the 1
st
day of the following month(s)? Even for the unfinished recerts?
Are your recertification's
completed on time?Are they signed and dated by the appropriate parties?Did tenant receive a 30 day
notice of an increase?Slide17
Calculating Tenant’s Income
Verifications at Move-in and CertificationsWages: EIV Income Report 4-8 consecutive pay stubs/verification/tax
return/affidavit
SS/SSI: EIV? Printout?
Public Assistance/Contributions/Pensions
Child Support/Unemployment
IRA/Annuities/401K,403B,etc.
Savings/Checking/MM/CD/Whole Life/Real EstateDependent Allowance
Medical/Disability/Childcare Expense
Elderly/Disabled Allowance
Assets Disposed ofSlide18
Assistance Payments
Does the Assistance Payment listed on the 50059 match your HAP?Adjustments at Move-in?
Adjustments for Move-outs
50059A for rent/UA
change/signatures
When to reprint 50059’s
with new Assistance paymentSlide19
Move-outs
Did you receive Move-out notice?Did you complete a Move-out inspection?
Copy of the SD refund check in file?
(
if applicable)
Was SD refunded within required timeframe?
Itemized list of deductions to tenant/family?
Bill for any additional monies owed sent?
Move-out date on voucher match file?Applying for Special Claims for damages or vacancies? What other docs will you need?Slide20
Rejected Applicants
Was the applicant rejection criteria listed in your Tenant Selection Plan?
Is the reason for rejection clear in your letter?
Does your rejection letter allow for
the for the applicant to appeal?
If applicable
:
Did the applicant appeal and
meet with staff who was not a part of the initial
rejection?
Was applicant notified of appeal decision within 5 days of meeting? Is the letter with the packet?
Note: “HSG Notice 2015-10” – Arrest Record must not be sole basis for rejection of applicant.Slide21
Additional Documents
Are you required to have VAWA ?All new tenants fill out a 92006? Existing tenants?
Do your “owner
c
reated” forms contain Title 18, Section 1001 of the US Code?
(Penalties for Misusing this form language
Are you running annual sex offender/criminal searches?Slide22
Enterprise
Income verification
Are you giving out “EIV and You Brochure”?
Are you running and printing the Existing Tenant Search
prior
to move-in?
Move-ins after 10-1-10, running Income and Summary Report
90 days
after transmission?Income Summary Report in file? Income Report in File? (AR & IR)
Income Discrepancy Report and follow up?
Are you running your EIV reports based on your EIV P & P’s?Slide23
Enterprise I
ncome verificationEIV Questions on the Tenant File Worksheet
Does the tenant file indicate that the owner/agent has taken necessary steps to address any EIV reported receipt of multiple subsidies?
Does the file contain documentation to verify discrepant person identifiers, and/or subsidy paid as reported on: EIV Multiple Subsidy Report or EIV Deceased Tenant Report?
Were income discrepancies reported on EIV Income Discrepancy Report investigated and file documented with the resolution?
Is there a written Payment Agreement for monies due to the project ?
Does the file contain a recertification 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?Slide24
Questions
?
Rose Dubin
rosedubin@gmail.com
“How to Conduct Your Own Tenant File Audit”