> Management and Occupancy Reviews
The purpose of a Management and Occupancy Review is to verify compliance
of the property with the terms of the Housing Assistance Payments (HAP)
Contract, Regulatory Agreement, Management Agreement and Management Plan
which is conducted on an annual basis. Owner compliance will also be
verified regarding civil rights regulations, including Title VI, Title VII,
the Americans with Disabilities Act, and Section 504 of the Rehabilitation
Act of 1973.
An on-site Management and Occupancy Review is scheduled with the owner/agent
at least two weeks in advance of the review. The owner/agent is responsible
for providing proper notice to residents advising them that their unit may
be chosen for inspection.
Before the actual inspection, compliance will be reviewed to determine
property status by referring to the latest REAC inspection and note any
exigent health and safety concerns sited. Review any MIO Plan or Plan of
Correction, prior Comprehensive Management Review, complaints from
residents, congressional inquiries and media reports to verify all concerns
were responded to in a timely manner. Any contractual violations and imposed
sanctions will also be reviewed.
The on-site Management and Occupancy Review begins with an interview with
the owner/agent to review the completed
Management Review for Multifamily
Housing Projects - HUD Form 9834
and determine whether existing policy conditions and procedures
are acceptable and if corrective action is needed. The following will be
discussed and reviewed, if applicable:
 | Affirmative Fair Housing marketing Plan |
| Management Agreement |
| Property’s current budget |
| Any current policy and procedure in place |
| Resident selection criteria |
| Waiting List and policy |
| Applicant rejection letter |
| Schedule of tenant damage charges |
| Rent collection procedure and late charge schedule |
| Property Rules |
| Move In and Move Out sheets |
| Pet policy (if applicable) |
| Preventive Maintenance policy |
| Resident request service logs |
| Posted Tenant Compliant toll-free number (1-866-605-7467) |
A random audit of resident files will be conducted to verify HUD compliance
regarding:
| Resident eligibility and selection |
| Income and assets |
| Third party verification of resident income and assets |
| Household characteristics |
| Adherence to income limit guidelines |
| Lease and lease addendums |
| Drug Free Housing Policy |
| Resident deposit |
| Certification and recertification of family eligibility |
| Initial notice of next recertification |
| Citizenship documentation |
| 9887/9887A Consent Form |
| Lead Based Paint Addendum |
| Social Security number verification/documentation |
| Disposal of assets |
| 50059 |
The physical inspection will include a general inspection of buildings and
grounds including, but not limited to:
| Random selection of occupied and vacant resident units to determine the level of maintenance and security |
| Work and storage areas |
| Mechanical rooms |
| Laundry facilities |
| Trash storage |
Particular attention will be paid to:
| Areas cited for exigent health and safety items noted in the latest REAC inspection to ensure problems have been remedied. |
| Areas or units where Replacement Reserves have been released in the past 12 months. |
A close-out meeting will be conducted upon the completion of the review to
discuss the results and any preliminary findings and concerns identified.
Within 30 days of the review a written report which provides a rating,
outline findings, cited and corrective actions needed. If the property is
rated below satisfactory, a copy is sent to the Multifamily HUB or Program
Center and mortgagee. An owner response is needed within 30 days from the
date of the report outlining corrective action taken. Once it is determined
that the owner has responded and taken all corrective action, the compliance
officer will notify the owner with a close-out letter.
All guidance was obtained from the HUD
Handbook 4350.3.
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