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  Asset Management > Performance Based Contract Administration


> 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:

bulletAffirmative Fair Housing marketing Plan
bulletManagement Agreement
bulletProperty’s current budget
bulletAny current policy and procedure in place
bulletResident selection criteria
bulletWaiting List and policy
bulletApplicant rejection letter
bulletSchedule of tenant damage charges
bulletRent collection procedure and late charge schedule
bulletProperty Rules
bulletMove In and Move Out sheets
bulletPet policy (if applicable)
bulletPreventive Maintenance policy
bulletResident request service logs
bulletPosted Tenant Compliant toll-free number (1-866-605-7467)

A random audit of resident files will be conducted to verify HUD compliance regarding:

bulletResident eligibility and selection
bulletIncome and assets
bulletThird party verification of resident income and assets
bulletHousehold characteristics
bulletAdherence to income limit guidelines
bulletLease and lease addendums
bulletDrug Free Housing Policy
bulletResident deposit
bulletCertification and recertification of family eligibility
bulletInitial notice of next recertification
bulletCitizenship documentation
bullet9887/9887A Consent Form
bulletLead Based Paint Addendum
bulletSocial Security number verification/documentation
bulletDisposal of assets

The physical inspection will include a general inspection of buildings and grounds including, but not limited to:


bulletRandom selection of occupied and vacant resident units to determine the level of maintenance and security
bulletWork and storage areas
bulletMechanical rooms
bulletLaundry facilities
bulletTrash storage

Particular attention will be paid to:


bulletAreas cited for exigent health and safety items noted in the latest REAC inspection to ensure problems have been remedied.
bulletAreas 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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