Form HUD-9834 Management Review for Multifamily Housing Projects

Management Reviews of Multifamily Housing Programs

HUD-9834

Management Reviews of Multifamily Housing Programs

OMB: 2502-0178

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Management Review for Multifamily
Housing Projects

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

OMB Approval No. 2502-0178
Exp. 09/30/08

Public Reporting Burden for this collection is based on the size of the project and the level of compliance and is estimated to average 8 hours per response, including
the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of
information. This form replaces form HUD-9838, Management Review for Unsubsidized Multifamily Housing Programs. This information is required by 24 C.F.R.
880.612, 24 C.F.R. 884.224, 24 C.F.R. 886.130, 24 C.F.R. 891.450, and/or the Regulatory Agreement. This agency may not collect this information, and you are not
required to complete this form, unless it displays a currently valid OMB control number. The information is used by HUD to evaluate the quality of project
management, determine the causes of project problems, and devise collective actions to stabilize projects and prevent defaults. The information is gathered and
recorded during a review of project operations. HUD does not ensure confidentiality to respondents.
PURPOSE: To assess management and oversight of multifamily housing projects.
INSTRUCTIONS: This form is to be completed by HUD staff, Performance Based Contract Administrators/Traditional Contract Administrators (CAs) and
Mortgagees of Coinsured Projects (Mortgagees). The Management Review form consists of three parts: Desk Review, On-site Review with Addendums, and Summary
Report. All Reviewers of subsidized projects must complete all Addendums (A, B & C). Reviewers of unsubsidized projects must complete Addendums 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”. 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, other documents, and contact the HUD
representative for any unavailable information needed to complete the desk review. This portion of the review will assist the Reviewer in identifying
potential problem areas. 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.
•
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 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.
•
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 checking Superior, Above Average, Satisfactory, Below Average, or
Unsatisfactory. If a section was not completed, indicate “Not Rated”. After rating the individual categories, an overall rating must be assessed. This rating
should be based upon the individual line items, the seriousness of the findings, and the ratings assigned in categories A through G. CAs will rate all sections
except Section D. Section D is for HUD staff/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 TCA 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 Real Estate Management System (REMS).
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 REMS.
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 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

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

Date of Report:

Project Number:

Contract Number:

Section of the Act:

Name of Owner:

Project Name:

Project Address:

Loan Status:

Contract Administrator:

Insured
HUD-Held
Non-Insured
Co-Insured

Type of Subsidy
Section 8
PAC
Section 236
Section 221(d)(3) BMIR

HUD
CA
PBCA

OMB Approval No. 2502-0178
Exp. 09/30/08

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

Type of Housing

Rent Supplement
RAP
PRAC
Unsubsidized

Family
Disabled
Elderly
Elderly/Disabled
Other (please specify)

For each applicable category, assess the overall performance by checking the appropriate column. Indicate A (Acceptable) or C (Corrective action required). Include target completion dates (TCD) for all corrective action
items. For those items not applicable, place N/A in the TCD column.
A. General Appearance and Security
C
TCD
General Appearance and Security Rating
A
Superior
Above Average
Satisfactory
Below Average
Unsatisfactory
Not Rated

1. General Appearance
2. Security
B. Follow-up and Monitoring of Project Inspections

3. Follow-Up and Monitoring of Last Physical Inspection and
Observations
4. Follow-Up and Monitoring of Lead-Based Paint Inspection
C. Maintenance and Standard Operating Procedures

TCD

Follow-up and Monitoring of Project Inspections Rating
Superior
Above Average
Satisfactory
Below Average
Unsatisfactory
Not Rated

TCD

Maintenance and Standard Operating Procedures Rating
Superior
Above Average
Satisfactory
Below Average
Unsatisfactory
Not Rated

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

TCD

Financial Management/Procurement Rating
Superior
Above Average
Satisfactory
Below Average
Unsatisfactory
Not Rated

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

TCD

Leasing and Occupancy Rating
Superior
Above Average
Satisfactory
Below Average
Unsatisfactory
Not Rated

14. Application Processing/ Tenant Selection
15. Leases and Deposits
16. Eviction/Termination of Assistance Procedures
17. Tenant Rental Assistance Certification System (TRACS)
Monitoring and Compliance
18. Tenant File Security
19. Summary of Tenant File Review
F. Tenant/Management Relations

TCD

Tenant Services Rating
Superior
Above Average
Satisfactory
Below Average
Unsatisfactory
Not Rated

20. Tenant Grievances
21. Provision of Tenant Services
G. General Management Practices
22. General Management Operations
23. Owner/Agent Participation
24. Staffing and Personnel Practices
Overall Rating:
Superior
Above Average

TCD

General Management Practices Rating
Superior
Above Average
Satisfactory
Below Average
Unsatisfactory
Not Rated

Satisfactory

Below Average

Unsatisfactory

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

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

Signature: _____________________________________________________________

Signature:______________________________________________________________

Date:

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 (12/01)

Page 10 of 22

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. 09/30/08

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

Finding

Target Completion Date

form HUD-9834 (04/07)
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. 09/30/08

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? 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
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/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 the previous management review, proceed to question 7.
4. Document year of construction for Lead-Based Paint compliance. (Obtain this information from the Physical Condition/PASS screen in REMS Open REAC
Inspection Report, then open the PASS Physical Inspection Report. The year of construction can be found under Buildings/Units .)
Date of Construction

(If constructed after 1977, proceed to question 7.)

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

6. What were the results of the Lead-Based Paint Inspection/Evaluation? 4B
Lead Found?
Yes

Information Not Available

Comments:

If yes, is there a HUD approved lead hazard control plan?
No
Yes
Comments

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

Page 1 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

8. What was the most recent Financial Assessment Subsystem (FASS) score? (This question applies only to HUD Staff)
Enter FASS Score
If financial reporting is not required determine why; and record in reviewer comments below.
Comments:

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. (This question applies only to HUD Staff/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. (9813c) Yes
Annual operating budget (cooperatives) Yes
No
N/A
If the reports have been submitted, were they received in acceptable form?

Yes

N/A

Comments:

10. Has owner corrected all findings on HUD financial and or Inspector General audits? (This question applies only to HUD Staff/Mortgagees)
Yes
No
N/A
List findings outstanding and determine whether remedial action is required to assure correction within established goals:

Comments:

11. Do project operating expenses appear reasonable compared with similar projects? (This question applies only to HUD Staff) D10
Yes
No
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.

12. Does annual financial analysis or FASS printout 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
$
$
$
13. If the owner/agent has taken unauthorized distributions, reimbursements, or supervision fees, have these been repaid? (This question applies only to HUD
Staff/Mortgagees)
No
Yes
If no, indicate amount due project.
14. If required, have all required deposits to the residual receipts fund been made? (This question applies only to HUD Staff)
Yes
No
Comments:

Page 2 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

15. Based on the last FASS submission, are accounts payable reasonably current? (This question applies only to HUD Staff/Mortgagees) D12
Yes
No
Indicate amount of accounts payable more than 60 days old

16. Does balance in security deposit trust account equal or exceed liability? (This question applies only to HUD Staff/Mortgagees)
Yes
No
If no, explain how deficit will be funded.

17. If security deposits are invested in an interest-bearing account, is interest passed through to tenants or transferred to project account? (This question applies only to
HUD Staff/Mortgagees)
Yes
No
Comments:

18. Is the management fee paid to the agent in accordance with the management certification? (This question applies only to HUD Staff/Mortgagees)
Yes
No
Comments:

19. 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/Mortgagees)
No
Yes
If yes, please enter date of certification. Determine that the content of certification is consistent with present operations.

Comments:

20. Has the owner and management agent executed a management agreement in accordance with the management certification? (This question applies only to HUD
Staff/Mortgagees)
No
Yes
Comments:

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

22. Has management entity profile been submitted to HUD? (This question applies only to HUD Staff/Mortgagees)
Yes
No
If yes, is it relevant to the agent’s organization and how it operates?
Yes
No
Date of management entity profile
23. Do the Management Entity Profile and Management Certifications clearly describe the relationships and responsibilities of the owner and agent?
(This question applies only to HUD Staff/Mortgagees)
No
Yes
Determine if any are identity-of-interest contracts and compare the listing to the annual financial report.

Page 3 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

24. Have the principals and board members listed received HUD-2530 approval? (Request a list of all current principals and board members and check for HUD-2530
approval.). (This question applies only to HUD Staff.)
Yes
No
N/A
Comments:

25. Is agent charging project for expenses for which the agreement requires agent to pay? (This question applies only to HUD Staff/Mortgagees)
Yes
No
Comments:

Questions 26 –29 apply to OAHP restructuring. If not applicable proceed to question 30.
26. Has the project’s mortgage been restructured? (This question applies only to HUD Staff.)
Yes
No
No
If yes, is there a use agreement on the project? Yes
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

Comments:

27. Is the owner eligible for incentives? (This question applies only to HUD Staff)
Yes

If yes, has the owner calculated those incentives correctly? (i.e., Capital Recovery Fee (CRF) and/or Incentive Performance Fee (IPF))
No
Yes
Comments:

28. Does the HUD billing statement (HUD-92771) indicate timely and accurate payments toward the Mortgage Restructuring Note? (This question applies only to
HUD Staff)
Yes
No
Comments:

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

Questions 30 through 33 apply to Section 236 projects. If this is not a Section 236 project proceed to question 34.
30. Does the rental income generate excess income? (This question applies only to HUD Staff)
Yes
No
Comments:

N/A

31. Has the owner/agent received approval to retain excess income? (This question applies only to HUD Staff) D13
Yes
No
Comments:

32. Was an annual report submitted for usage of retained excess income? (This question applies only to HUD Staff) D13
Yes
No
Comments:

33. Are there any delinquent excess income payments due HUD? (This question applies only to HUD Staff) D13
Page 4 of 25

form HUD-9834 (04/07)
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

Yes
If yes, is there a payment plan? Yes

OMB Approval No. 2502-0178
Exp. 09/30/08

Comments:
34. Are rent increase requests submitted to HUD promptly when needed? (This question applies only to HUD Staff)
Yes
No
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.
No
Does owner/agent generally provide sufficient documentation for rent increases? Yes
Comments:
35 Are contract renewals submitted to HUD promptly when needed?
Yes

Comments:
36. Complete chart below. (This question applies only to HUD Staff/ Mortgagees)
Name of Reserve

As of
Per Unit
$
$

Total
$
$

/
Monthly Deposit
$
$

Replacement Reserve
General Operating Reserve
(Co-ops)
Residual Receipts
$
$
$
Other
$
$
$
a. Do balances in replacement or general operating reserve accounts appear adequate to meet future needs?
Yes
No
If not, what action is recommended?

Held in Interest Bearing
Account?
Yes
Yes

No
No

Yes
Yes

No
No

b. Is only one account (i.e., the appropriate reserve or operating expense account) being billed for repairs that are eligible for reimbursement from the reserves?
No
Yes
Comments:

37. Has the owner/agent performed analysis to determine future Reserve for Replacement needs when submitting a budget based rent increase?
Yes
No
Comments:

38. If there is a utility allowance, when was the last adjustment approved?
Effective date of last utility allowance adjustment:
If a utility allowance was approved was it implemented within 75 days as required by HUD? Yes

Comments:

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

40. Is current approved rent schedule sufficient to meet project needs? (This question applies only to HUD Staff)
Yes
No
Comments:

Page 5 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

OMB Approval No. 2502-0178
Exp. 09/30/08

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

Management Review for Multifamily
Housing Projects
41. Has a special rent increase been approved?

Yes
If yes, please check the appropriate box.

Insurance

Taxes

Utilities

Security

N/A

Service Coordinator

Comments:

42. Are monthly rental subsidy vouchers submitted on time?
Yes

N/A

43. Is the owner/agent submitting tenant certification data to TRACS to support the voucher billings?
Yes
No
Comments:

N/A

Comments:

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

45. List vacancy activity for the past twelve months and indicate the number for each month. (This information can be obtained from the TRACS Voucher Detail
Summary) C6.
JAN

FEB

MAR

APR

MAY

JUNE

JULY

AUG

SEPT

OCT

NOV

DEC

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

47. If yes to question 46, 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:

48. Are there any unresolved findings from previous management reviews? If yes, specify in the comments section.
Yes
No
Comments:

Page 6 of 25

form HUD-9834 (04/07)
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. 09/30/08

49. Review complaints, congressional inquiries, etc. received within the last 12 months regarding the overall management practices. Provide a general description
below or attach applicable documentation. G22
Issue/Complaint

Status

Page 7 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

Part II - ON-SITE REVIEW – Indicate by marking the appropriate box - Yes, No or N/A if not applicable. Provide comments as needed.

A. GENERAL APPEARANCE & SECURITY
1. General Appearance
1. Based on observation, are the project’s exterior and common areas (i.e., grounds, landscaping, parking lots, playgrounds, hallways, laundry room, elevator, garbage
area, stairwells, management office) clean, free of graffiti, debris and damage?
Yes
No
N/A
If no, provide location and describe condition(s).
Comments:

2. Security
a. Indicate whether any of the events below have been documented in the last twelve months and the frequency.

Event

Frequency

Event

Break-Ins
Vandalism
Auto Theft
Personal Assaults

Frequency

Arrests
Drug Activity
Other (please specify):
None

Comments:

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

Volunteer Organization
TV Monitor
Crime Prevention Plan

Paid Car Patrol
Drug Free Housing Plan
Community Policing
None

Paid on-site Guard
Security Cameras

Comments:

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

d. Has the owner/agent requested a rent increase based on increases in security costs?
Yes

If yes, indicate security measures taken.
Comments:

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

Comments:

Page 8 of 25

form HUD-9834 (04/07)
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. 09/30/08

b. Based on a sampling of units and common areas, for all other deficiencies noted in the REAC inspection (other than EH&S), 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:

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, indicated N/A for question a and b.
a. Is there a certification on file documenting the project has been certified to be free of lead-based paint or lead hazards?
Note: If there is a certification, obtain a copy for the project file.
No
N/A
Yes
Comments:

b. Is the owner in compliance with the HUD approved lead hazard control plan as noted on the desk review?
Yes
No
Comments:

N/A

C. MAINTENANCE & STANDARD OPERATING PROCEDURES
5. Maintenance
a. Indicate below to confirm that there is a schedule for preventive maintenance/servicing for the items listed that are applicable.
Heating and A/C Equipment
Water Heaters
Carpets and Drapes
Roof, gutter and Fascia Inspection
Major Appliances
Elevators
Motor Vehicles
Sewer lines
Exterior painting
Windows
Recreational equipment
Landscaping maintenance
Other (please specify):
Comments:

b. Is there a satisfactory inventory system for accounting for tools, equipment, supplies, and keys (serial numbers, bar codes, etc.)?
Yes
No
Comments:

c. Has the owner/agent secured inventory items, such as appliances and tools, to prevent theft?
Yes
Comments:

d. Does the owner/agent have a written procedure that explains the process for inspecting units?
Yes
If yes, review a copy. Identify employee responsible for conducting inspection: Name and Title:

Comments:

e. How often are units inspected? (At right, indicate the appropriate answer[s].)
Monthly

Quarterly

Semi-Annually

Annually

Move-In

Move-Out

Other (please specify):

Comments:

f. How are unit inspections documented?
Please Describe:

Page 9 of 25

form HUD-9834 (04/07)
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. 09/30/08

g. If deficiencies are noted during unit inspections, what is the procedure for correction?
Please describe:
h. What is the average number of days from move-out until the unit is ready for occupancy?
Average Number of Days:
Comments:

i. Is there a written procedure for completing work orders?
Yes

Yes

If yes, review a copy.
Comments:

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

k. Is there a backlog of work orders?
If a backlog exists, indicate the current number of work orders:
Number between 1-3 days:

Number between 4-7 days:

Number more than one week:

Comments:

l. Who is provided copies of completed work orders? (Below, indicate all that apply.)
Tenant

Tenant File

Maintenance Staff

Other (please specify)

Comments:

m. Is there documentation by unit that indicates the date of purchase, manufacturer, model, and serial number for appliance purchases (i.e., ranges, refrigerators,
furnaces, air conditioners, hot water heaters, etc.)?
Yes
No
Comments:

6. Vacancy and Turnover
a. How many units were vacant on the date of the on-site visit?
Number of Vacant Units:

Number Ready for Occupancy:

Average Length of time for unit turnover:

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

c. Based on the interview with on-site staff, are any of the factors listed below contributing to vacancy problems? (Below, indicate all that apply.)
Security Problems
Non-competitive Amenities
Inadequate Marketing
Project Reputation
Location
Lack of Demand
Tenant/Management Relations
Other (please specify)
Bedroom Mix/Size (If yes, indicate which bedroom sizes are hard to rent)

Poor Maintenance

Rents too High

Comments:

Page 10 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

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
(Indicate all that apply.)
Caulking and weather-stripping
Conversion to individual metering
Storm doors and windows
Water saver devices
Extra insulation
Assessment of Utility Rate Schedule
Other (please specify)
None

Consumer education

Comments:

D. FINANCIAL MANAGEMENT/PROCUREMENT
(This section applies only to HUD Staff and/or Mortgagees as indicated. CAs may proceed to Section E.)
8. Budget Management
a. Does the owner/agent’s staff have access to the current operating budget to monitor and control expenses?
Yes
No
Comments:

N/A

b. Is an operating budget prepared annually and approved by the owner?
Yes

N/A

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

c. Are monthly or quarterly reports prepared by the owner/agent indicating variances between actual income and expenses versus budgeted income and expenses?
Yes
No
N/A
Comments:

d. If this is a 202 or 811 project, does the owner/agent maintain a current annual budget? (This questions applies only to HUD Staff)
Yes
No
N/A
No
If yes, is it available on-site? Yes
Comments:

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

b. Are adequate controls over cash accepted?
Yes
Check controls used.
Pre-numbered rent receipts

Bank collections

Safe

Lock box

Comments:
c. Do different persons handle bank deposits and accounts receivable, or is an alternative safeguard used?
Yes
No
Indicate Names and Titles:
Comments:

d. Are all disbursement checks prenumbered, properly identified with account numbers and supported by vouchers or invoices?
Page 11 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

Yes

Comments:

e. Is the supply of unused checks adequately safeguarded or under the custody of persons who do not sign checks manually, control the use of facsimile signature
plates, or operate the facsimile signature machine?
Yes
No
Comments:

f. Are funds (i.e., 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 check signer and by one who has no cash receipt or disbursement function?
Yes
No
Comments:

10. Cost Controls
a. Are bills (including mortgage payment) paid in sufficient time to avoid late penalties?
Yes

N/A

Comments:

b. Are operating expenses (including taxes and utilities) periodically reviewed to assure that project is paying the lowest possible rate?
Yes
No
N/A
If yes, give recent example.

11. Procurement Controls
a. What is the procedure used to obtain and award contracts?
Describe procedure:

b. Are bids obtained prior to awarding contracts? (Review contracts and determine if bids were obtained and, if the lowest bids were not selected, obtain owner/agent
decision for selection).
Yes
No
N/A
Comments:

c. Is there a written procedure for checking the quality of work performed by a contractor prior to authorizing payment?
Yes
No
Comments:

d. Is there a procedure to assure that the individual authorizing contracted work/services is not the same individual authorizing payment?
Yes
No
Comments:

Page 12 of 25

form HUD-9834 (04/07)
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. 09/30/08

e. Who is the responsible person charged with inspecting the quality of work performed by contractors prior to payment?
Please indicate name and title:
f. Does the project maintain a list on outside contractors?
Yes

Yes

Comments:

g. Are vendor bills paid in time to obtain maximum trade discounts?
Comments:

h. Is there any indication that real or personal property has been subtracted from the mortgaged premises without the permission of the Department?
Yes
No
Comments:

i. Below, check services currently contracted with outside contractors and identify name of contractor and annual amount of contract. (Indicate (by asterisk) whether
there is an identify-of-interest relationship between the contractor and the owner/agent)
Service
Elevator

Name of Contractor

Annual Contract Amount
$

Exterminating

Apartment Cleaning

Heating and A/C

Plumbing

Security

Trash Collection

Decorating

Grounds

Other

Comments:

12. Accounts Receivable/Payable
a. Are tenant accounts receivable within acceptable limits?
Yes

Yes

% of monthly rents due from tenants.
Amount of receivable in No. 15K is
is more than 30 days past due.
Of this amount, $
Comments:

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

Page 13 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

c. Has annual “write-off of tenants’ accounts receivable for the last two fiscal years been less than 1% of gross rents due from tenants?
Yes
No
Comments:

d. Are accounts payable reasonably current?
Yes

Indicate amount of accounts payable more than 60 days old: $
What are the owner/agent plans to do to reduce outstanding payables?

Comments:

13. Accounting and Bookkeeping
a. Are books and records maintained as required by HUD Handbook 4370.2 (Chapter 4) and 24 CFR Part 5?
Yes
No
N/A
Check books of accounts 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 (
b. Are all required project accounts in the name of the project in a federally insured account?
Yes
Comments:

)

c. Are operating funds, security deposits, reserve funds, and flexible subsidy funds maintained in separate accounts and properly secured for authorized use?
Yes
No
Comments:

d. Does the mortgagor make frequent postings (at least monthly) to the ledger accounts?
Yes

Comments:

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

f. Is centralized accounting used for disbursements?
Yes

Yes

N/A

h. If centralized accounting is used, is it being operated in accordance with HUD’s approval?
Yes
Comments:

N/A

If yes, are only HUD-insured projects in the pool?

Yes

Comments:

g. If centralized accounting is used, has it been approved by HUD
Comments:

Page 14 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

i. 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:

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

E. LEASING AND OCCUPANCY (This Section does not apply to Mortgagees)
14. Application Processing/Tenant Selection
a. Does the application form contain sufficient information to determine applicant eligibility
Yes
Comments:

b. Is there an arms length procedure between the person who denies the applicant and the applicant appeal reviewer?
Yes
No
Comments:

c. 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
No
If yes, has HUD or CA authorized the admission? Yes
Comments:

d. Does the owner/agent have a written tenant selection plan?
Yes

If yes, does the plan include all required criteria as stated in the Handbook 4350.3 REV-1?
No
Yes
Comments:
e. Does the project maintain a waiting list of prospective tenants?
Yes

Yes

N/A

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

f. List number of applicants on the waiting list for the types of units below.
0 BR

1 BR

2 BR

3 BR

4 BR

Other:

Comments:

g. Were the applicants selected in proper order from the waiting list?
Comments:

Page 15 of 25

form HUD-9834 (04/07)
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. 09/30/08

h. Is documentation available to show that the owner/agent is leasing not less than 40% of the Section 8 units that become 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:
i. What steps has the owner/agent taken to market to extremely low-income families?
(If not applicable, proceed to question j.)
Please describe:
Comments:

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

k. Is the affirmative fair housing sign posted in the rental office?
Yes

Yes

Comments:

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

15. Leases and Deposits
a. Have changes have been made in the model lease?
N/A

If yes, has the lease in use been approved by HUD?
Yes
No
Comments:

b. Aside from rents and security deposits, what other charges are assessed (i.e., replacement keys, lockouts)?
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
Comments:

d. Are rents collected in accordance with the provisions of the lease?
Yes

Yes

Comments:

e. Is the policy for late fee assessment in compliance with the Handbook 4350.3 REV-1?
Comments:

Page 16 of 25

form HUD-9834 (04/07)
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. 09/30/08

f. Are damages properly identified and charged to tenants?
Yes

Yes

N/A

Yes

N/A

Comments:

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

b. Are eviction procedures initiated timely, when warranted?
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

Comments:

c. Are tenants notified of termination of assistance in accordance with HUD requirements?
Yes
Comments:

N/A

Yes

N/A

Yes

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

17. TRACS Monitoring and Compliance
a. Is the owner/agent using the TRACS queries to review and monitor their transmission?
Comments:

b. Is the owner/agent following up and correcting TRACS deficiencies?
Comments:

18. Tenant File Security
a. Are the files locked and secured in a confidential manner?
Comments:

b. Is access to tenant file information limited to only authorized staff?
Comments:

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

Page 17 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

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

e. Is the owner/agent properly disposing of tenant records (shred, burn, pulverize etc.)?
Yes

Comments:

19. 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 files for new move-ins, recertifications, at least one Reject Applicant file, and at least one Terminated/Move-out Tenant file. In order to
review specific functions (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.
Number of Files Reviewed =
Answer “No” if the files are not acceptable and note the number of files with
deficiencies utilizing the tenant file worksheet, Addendum A
(Please note: There is no maximum number of files to be sampled)
a. Tenant Files and Records
i. Are the tenant files organized and properly maintained?
Yes

Number of Files with Deficiencies:
Comments:
ii Do the files contain all documentation as required in Handbook 4350.3 REV-1? (At right, indicate the documents missing in the file.)
Yes
No
Documents Absent from File:
Comments:

b. Application/Tenant Selection
i. Were the applications in the files signed and dated by applicant?
Yes

Yes

Number of Files with Deficiencies:
Comments:

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

iii. Were the unit sizes appropriate for household composition at the time of this tenant file review?
Yes
No
Number of Files with Deficiencies:
Comments:

Page 18 of 25

form HUD-9834 (04/07)
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. 09/30/08

iv. If a household was ineligible at move in, were exceptions granted?
Yes

N/A

Yes

N/A

Yes

N/A

Yes

N/A

Yes

N/A

Number of Files with Deficiencies:
Comments:

c. Lease
i. Were the correct model leases used?
Number of Files with Deficiencies:
Comments:

ii. Were the leases signed and dated by all required parties?
Number of Files with Deficiencies:
Comments:

iii. Were the applicable attachments attached to the lease?
Number of Files with Deficiencies:
Comments:

iv. Were security deposits collected in the correct amount for the program?
Number of Files with Deficiencies:
Comments:

v. Were pet deposits within acceptable range and payment installments allowed?
Number of Files with Deficiencies:
Comments:

d. Certification/Re-Certification Activities:
i. Were re-certification notices issued in accordance with HUD requirements?
Number of Files with Deficiencies:
Comments:

ii. Were certifications completed on time?
Number of Files with Deficiencies:
Comments:

iii. Were all necessary verifications completed and properly documented?
Number of Files with Deficiencies:
Comments:

Page 19 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

iv. Were income and deductions calculated correctly prior to data entry?
Yes

N/A

Number of Files with Deficiencies:
Comments:
v. Did income information on the tenant certifications agree with verified file information?
Yes
Number of Files with Deficiencies:
Comments:

vi. 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:

vii. Were notices provided to tenants when their portion of rent increased in accordance with HUD tenant notification requirements?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:

viii. Were the correct contract rents used for determining subsidy paid on behalf of tenants?
Yes
Number of Files with Deficiencies:

N/A

Comments:

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

x. Were 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
i. Were there any deficiencies noted in the tenant file review that resulted in over payment or under payment of subsidy?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:

ii. For the move-in/ move-out tenant file review, did the owner/agent make the appropriate voucher adjustments?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:

Page 20 of 25

form HUD-9834 (04/07)
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. 09/30/08

f. Move-In Files
i. Were proper income limits used for determining eligibility at move-in?
Yes

Yes

iii. If the files contained move-in inspections, did the owner/agent and tenant sign and date?
Yes
Number of Files with Deficiencies:

N/A

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

Comments:

g. Move-Out Files
i. Did tenants provide written notice of intent to vacate in accordance with the HUD model lease?
Yes
Number of Files with Deficiencies:

Comments:

ii. Were move-out inspections conducted?
Yes

Yes

N/A

Yes

N/A

Yes

Number of Files with Deficiencies:
Comments:

iii. Were security deposits refunded in 30 days or less if required by state law?
Number of Files with Deficiencies:
Comments:
iv. Were tenants provided an itemized listing of charges against the security deposits?
Number of Files with Deficiencies:
Comments:

v. If charges exceeded the security deposits, were the tenants billed for the balances?
Number of Files with Deficiencies:
Comments:

h. Application Rejection Files
i. Were applicants denied admittance in accordance with the Tenant Selection Plan?
Number of Files with Deficiencies:
Comments:

Page 21 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

ii. Did rejection letters provide applicants the right to appeal?
Yes

Number of Files with Deficiencies:
Comments:
iii. If applicants appealed application rejections, were appeals reviewed by someone other than person who made the original decision?
Yes
No
N/A
Number of Files with Deficiencies:
Comments:

iv. Were appeals processed and applicants notified of appeal decision within 5 days of meeting?
Yes
Number of Files with Deficiencies:

N/A

Comments:

F. TENANT/MANAGEMENT RELATIONS (This Section does not apply to Mortgagees)
20. Tenant Concerns
a. Is there a written procedure to resolve tenant complaints or concerns?
Yes

Yes

If yes, review a copy.
Comments:

b. Does the procedure adequately cover appeals?
Comments:

c. Is there an active formal tenant organization at this project?
Comments:

d. Is tenant involvement in project operations encouraged?
Comments:

21. Provision of Tenant Services
a. What social services are provided by either project or neighborhood, which meet the tenants’ needs? (Below, indicate services available and identify entity providing
the service (i.e., city/county/state, church/school, community groups, etc. and any cost to project.)
Service

Provider

Financial Source

Child Care
Recreation
Health Care
Energy Conservation
Vocational Training/Job Training
Meals
Financial Counseling
Substance Abuse Counseling
Service Coordinator
Neighborhood Networks Center
Other (please specify)

b. Is there a Service Coordinator for the project? (If there is no Service Coordinator, proceed to question f)
Page 22 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

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

Management Review for Multifamily
Housing Projects

Yes

OMB Approval No. 2502-0178
Exp. 09/30/08

N/A

Comments:

c. Is the Service Coordinator’s office clearly identifiable and private?
Comments:

d. Are the Service Coordinator’s files kept secure and confidential?
Comments:

e. Does the Service Coordinator maintain a directory of service agencies and contacts and made available to all parties?
Yes
No
Comments:

f. If there is a Neighborhood Networks Center as indicated on the Desk Review, what is the status of operations?
(If there is no Neighborhood Networks Center, question h)
Open for Business
Temporarily Closed – State the date the center will reopen:
Permanently Closed – State the date the center closed:
Comments:

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

Job Training
Job Placement
Other (please specify)

Comments:

h. The Department allows owners and their agents to provide services related to renter’s insurance products. Does the owner/agent offer such services?
If the owner/agent offers no such service, proceed to Section 22.
No
Yes
Comments:

i. HUD policy prohibits an owner/agent from evicting tenants if delinquent in renter’s insurance payments.
How does the owner/agent deal with unpaid renter’s insurance?
Please explain the process:
Comments:

j. Review the renter’s insurance information provided to tenants. Does the information provided to tenants clearly indicate that purchasing insurance is optional and not
required as a condition of occupancy?
Yes
No
N/A
Comments:

G. GENERAL MANAGEMENT PRACTICES
22. General Management Operations
a. Have the complaints, as noted on the Desk Review, been satisfactorily resolved?
Yes
Comments:
b. Is the project staff able to adequately perform management and maintenance functions?

Page 23 of 25

N/A

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

Yes

Comments:

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

d. Does owner/agent have a formal ongoing training program for its staff?
N/A

If yes, indicate types of training used and the frequency.
Type
On-Site

Frequency

HUD Seminars
Energy Conservation
Industry/Association Training
Local Colleges
Other (please specify)
Comments:

e. Are reports submitted to the owner from the management agent? (This question applies only to HUD Staff/Mortgagees)
Yes
No
Comments:

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

Yes

Comments:

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

h. List 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/Mortgagees)
Type

Basic Coverage

Annual Premium

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

Comments:

Page 24 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

Management Review for Multifamily
Housing Projects

OMB Approval No. 2502-0178
Exp. 09/30/08

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

i. Does the owner/agent have a fidelity bond? (This question applies only to HUD Staff/Mortgagees)
Yes
No
Comments:

N/A

23. Owner/Agent Participation (This section applies only to HUD Staff/Mortgagees. CAs may proceed to24.)
a. If project is owned by a cooperative or nonprofit entity, does Board of Directors meet regularly and provide minutes?
Yes
No
N/A
Comments:

b. Review copies of the minutes. Does a review of the minutes indicate compliance with HUD’s business agreements?
Yes
No
N/A
Comments:
c. Does owner/agent have a system or procedure for providing field supervision of on-site personnel?
Yes
No
Comments:

N/A

24. Staffing and Personnel Practices
a. Has management made an effort to employ tenants in accordance with Section 3 of the Housing and Community Development Act of 1968?
Yes
No
Comments:

b. List all on-site staff charged to the project. (Use additional sheets if necessary).
Staff Person

Date Hired

% of Time Charged
to Site

Annual Salary

Unit Size

Is the Employee
Receiving Subsidy?

Yes

Is the Employee
occupying a NonIncome
Producing Unit?
Yes
No

Yes

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:

Page 25 of 25

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

ADDENDUM A
OMB Approval No. 2502-0178
Exp. 09/30/08

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

Tenant Move-In

Tenant Move-Out

Certification/Recertification

Effective date of certification(s) reviewed:
If Certification/Recertification, indicate certification type:
Certification Type:

Initial

Annual

Interim

Family Name:
Bedroom Size:

Other

Unit Number:
0 Bedroom

1 Bedroom

2 Bedroom

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

Move-in Date:
3 Bedroom

4 Bedroom

5 or more Bedrooms

Yes

Comments:

2. Are the household members identified correctly?
(head, spouse, dependent, co-head, other adult(s), live-in
aide)
3. Is the unit size appropriate for household?

Yes

Comments:

Yes

Comments:

4. Was household income eligible at move-in?
(This question applies only to a tenant file move-in
review.)

Yes

Comments:

Over income?
Very low income?
Comments:

5. If household was not income eligible at move-in, was
an exception granted?
6. Is the lead-based paint acknowledgement in the file?

Yes

N/A

Low income?
Extremely low income?

Comments:

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

Yes

Comments:

8. Have the HUD-9887/9887-A Consent Forms been
signed by head, spouse, co-head regardless of age and
family members at least 18 years of age?
9. Was the HUD-9887 Fact Sheet provided to the tenant?

Yes

Comments:

Yes

Comments:

10. Does the file contain the Resident Rights and
Responsibilities acknowledgement?

Yes

Comments:

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 1 of 4

ADDENDUM A
OMB Approval No. 2502-0178
Exp. 09/30/08
B. VERIFICATION
Have the following items been properly verified and documented?
1. Social security numbers for all family members at least
Yes
6 years of age and older or certification, if no SSN

Comments:

2. Eligible immigrant status or citizenship

Yes

Comments:

3. Criminal and drug screening; sex offender registration

Yes

Comments:

4. Other screening as disclosed in Tenant Selection Plan

Yes

Comments:

5. Disability

Yes

N/A

Comments:

6. Student status

Yes

N/A

Comments:

7. Age

Yes

N/A

Comments:

8. Did the household certify whether or not they disposed
of assets during the past two years?

Yes

N/A

Comments:

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

2. Is the original lease and subsequent leases or
addendums signed by the owner/agent, head, spouse, cohead, and all other adult members of the household?
3. Are applicable attachments attached to the lease, e.g.,
house rules, pet rules, unit inspection report?

Yes

Comments:

Yes

Comments:

Yes

Comments:

4. If security deposit is required, was it correct?

Yes

N/A

Comments:

If required, enter amount here:
5. If pet deposit required, was it correct?

Yes

N/A

Comments:

Yes

N/A

Comments:

If required, enter amount here:
6. If pet deposit was paid in installments, was payment in
accordance with the pet regulations?
7. Is the move-in inspection dated and signed by tenant
and owner/agent?

Yes

Comments:

8. Are Annual inspections documented in file?

Yes

Comments:

D. CERTIFICATION/RECERTIFICATION ACTIVITIES
1. Were recertification notices provided within the
required timeframes?

Yes

Comments:

2. Were recertifications completed on time?

Yes

Comments:

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

Yes

Comments:

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 2 of 4

ADDENDUM A
OMB Approval No. 2502-0178
Exp. 09/30/08
3rd Party Verification?

All reported income and deductions verified
and calculated correctly?

Amount Reported
on 50059

4. Wages

Yes

5. Social Security Benefits

Yes

6. Welfare/Public Assistance/TANF

Yes

7. Other income

Yes

8. Actual Income from Assets

Yes

9. Imputed income when assets are greater than
$5,000
10. Dependent Allowance

Yes

11. Medical Expenses

Yes

12. Disability Expenses

Yes

13. Childcare Expenses

Yes

14. Elderly/disabled household allowance

Yes

15. Are all expenses/allowances claimed
eligible under the HUD Handbook 4350.3 REV1?
16. Was the correct unit rent used for rent
determination?
Enter the reviewer verified amounts for the
following:

Yes

Comments:

Yes

Comments:

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

Amount Reported on the
50059
$

Did income information on the 50059 agree with verified file
information? If no, comment on Discrepancies Identified.
Comments:

Comments:

17. Total Tenant Payment
$

18. Tenant Rent
$

19. Utility Reimbursement
$

20. Assistance Payment
$
21. Is the tenant paying minimum rent?

Yes

N/A

Comments:

22. Has a hardship exception been granted for
paying minimum rent?

Yes

N/A

Comments:

23. Was a 30-day rent increase notice provided
to tenant?

Yes

N/A

Comments:

24. If applicable, has tenant entered into a
written payment plan for monies due to the
project?

Yes

N/A

Comments:

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 3 of 4

ADDENDUM A
OMB Approval No. 2502-0178
Exp. 09/30/08
E. BILLING
1. Does the assistance payment requested on
the monthly billing (HUD-52670-A, Part 1)
agree with the assistance payment on the 50059
data requirements?
2. If required, have adjustments been made to
the monthly billing?

Yes

N/A

Comments:

Yes

N/A

Comments:

F. MOVE-OUT FILE REVIEW ONLY
1. Was there a move-out notice from tenant?

Yes

Comments:

2. Was there a move-out inspection?

Yes

Comments:

3. If there is a move-out inspection, is it dated?

Yes

Comments:

4. Was the security deposit refunded to tenant
within 30 days or in accordance with state/local
laws whichever is shorter?
5. Was an itemized list of the damages and
charges provided to the tenant?

Yes

N/A

Comments:

Yes

N/A

Comments:

6. Were any additional charges paid by tenant?

Yes

N/A

Comments:

7. Does the tenant move-out date on voucher
match the date the tenant vacated unit?
G. APPLICANT REJECTION REVIEW ONLY
1. Was the reason the applicant was denied
admittance in accordance with the Tenant
Selection Plan?
2. Did the rejection letter provide the applicant
the right to appeal?
3. If the applicant appealed, was the appeal
reviewed by someone other than the person who
made the original decision?
4. Was the appeal processed and applicant
notified of appeal decision within five days of
the meeting?

Yes

Comments:

Yes

Comments:

Yes

Comments:

Yes

N/A

Comments:

Yes

N/A

Comments:

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 4 of 4

OMB Approval No. 2502-0178
Exp. 09/30/08

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

ADDENDUM B
Multifamily Housing (Housing) staff or Performance-Based Contract Administrators/Traditional Contract
Administrators (CA) must complete this Checklist when conducting on-site management reviews of subsidized and
unsubsidized multifamily housing projects. The questions on this checklist cover topics that the Housing staff or
CA can be expected to answer and is not intended to cover the full range of civil rights concerns.
NOTE: This document does not require the Reviewer to make a determination of civil rights or Section 504
compliance.
The Checklist is divided into four parts.
Part A: Occupancy/Accessible Units/Program Accessibility (This section, along with
instructions, must be forwarded to the owner/agent for completion prior to the on-site review.
This document must be included in the Documents Reviewer Should Obtain from Owner. See
Part D)
Part B: Limited On-Site Monitoring Review (The Reviewer must complete this section during
the on-site management review of all projects.)
Part C: Section 504 Review (The Reviewer must complete this section during the on-site
management review for all federally-assisted projects.)
Part D: Documents Reviewer Should Obtain from 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/civil
rights/Section 504 violation.

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

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

ADDENDUM B
To be completed by the Reviewer
Name of the Owner/General Partner:
Address of Owner/General Partner:
Name of Management Agent:
Address of Management Agent:
Type of Development:
Elderly/Disabled

Cooperative

Elderly Only

Family

Disabled Only

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

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

Yes

2 BR

Section 236
3 BR

Other

4 BR

5 BR

Date of First Occupancy:
Service Coordinator Employed By Project:
Reviewed by:

Housing

PBCA

Yes

No
CA

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, Subtitle D of the Housing and Community Development Act of
1992
Possible noncompliance with Title VI, Subtitle 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, Subtitle D of the Housing and Community Development Act of 1992 - Not Applicable
Reviewed By: _________________________________________________________
(Name and Title)

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 2 of 13

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

ADDENDUM B
PART A
OCCUPANCY/ACCESSIBLE UNITS/PROGRAM ACCESSIBILITY
Authority:
Section 504 of the Rehabilitation Act of 1973 (24CFR Part 8)
Fair Housing Act/Title VIII Regulations (24 CFR Part 100.200)
Uniform Federal Accessibility Standards (UFAS) (24 CFR Part 40)
Regulatory Agreement
For this Section, the reviewer must forward the form along with the instructions for completion to the owner/agent prior to the on-site review. For
subsidized projects, the owner/agent must complete the project information above and the information in Sections I, II, and III below. (See
attached instructions.) For unsubsidized projects, the owner/agent must complete the project information above and Sections I and II only.
Section III consists of Section 504 compliance, which does not apply to projects that do not receive federal financial assistance. The reviewer
will obtain the completed form from the owner/agent during the on-site review.
SECTION I – OCCUPANCY
2. Indicate the number of units currently occupied by client groups
below
Exclusively Elderly
Exclusively Elderly Exclusively Disabled
Exclusively Disabled Elderly/Disabled Elderly and Disabled
Near-Elderly Disabled Family
___
Family 3. Is there a use agreement or any other document that indicates that this project must serve only elderly tenants?

1. This property was designed primarily for:

Yes
No
Unknown
Effective Date:
If yes, specify type of document:
(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, Subtitle D of the Housing and Community Development Act of 1992? (Refer to HUD Handbook 4350.3,
REV-1)
Yes
No
If No, proceed to question 5.
If yes, please indicate:
a. the date of the elderly preference:
b. the number of units that must be reserved for occupancy by non-elderly persons with disabilities
c. the date used to determine the number of units reserved for non-elderly persons with disabilities

, and,

5. Is there an occupancy restriction for the elderly in accordance with Section 658 of Title VI, Subtitle D of the Housing and Community
Development Act of 1992? (Refer to HUD Handbook 4350.3, REV-1)
Yes

6. Total Number of Units Exclusively for
the Elderly

7. Total Number of Units Exclusively for
Persons with Disabilities

8. Total Number of Units that must be
occupied only by 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 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 3 of 13

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

ADDENDUM B
SECTION II – ACCESSIBLE UNITS
Distribution of all wheelchair and other accessible units in the project.
Bedroom Size
1. All units

Other

Total

2. Total units with project-based
rental assistance
3. Mobility accessible units
4. Vision and/or Hearing
accessible units
*5. (Total Accessible Units)
6. Number of persons on waiting
list who have requested
accessible units
7. Number of accessible units
occupied by elderly or family
tenants
8. Number of accessible units
occupied by non-elderly tenants
with disabilities who require the
features of the unit
9. Number of accessible units
occupied by elderly tenants with
disabilities who require the
features of the unit
10. Percentage of Total Units with Project-Based Rental Assistance
(Total line 2 divided by Total line 1 x 100)
%
11. Percentage of Total Units that are mobility accessible
(Total line 3 divided by Total line 1 x 100)
%
12. Percentage of Total Units that are vision and/or hearing accessible
(Total line 4 divided by 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 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 4 of 13

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

ADDENDUM B
SECTION III – PROGRAM ACCESSIBILITY
SECTION 504 OF THE REHABILITATION ACT OF 1973
Section 504 Coordinator [24 CFR 8.53 (a)]
1. Does the recipient (as defined in 24 CFR 8.3) employ at least 15 employees?
Yes

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

N/A

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

YES

COMMENTS

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

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 5 of 13

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

ADDENDUM B
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, Subtitle D of the Housing and Community Development Act of 1992 (Title VI-D) to reserve a percentage of units for non-elderly
persons with disabilities in accordance with the provisions of Section 652, Title VI-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 needs 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 61 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 that references that the property must serve only elderly persons, answer “Yes”, indicate in the
space provided, and attach a copy of the document(s) listed. If there is no use agreement or other document that references 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 any 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.
(Do not leave blank).
4. Section 651 of Title VI-D permits an owner to give *preference 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.
*A “preference” allows an owner to give priority to elderly persons when selecting tenants for occupancy.
Section 651 of Title VI-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-D requires that the owner review the occupancy records on January 1, 1992 and October 28, 1992 (the date of enactment for
Title VI-D), determine the number of non-elderly persons with disabilities that occupied units on those two dates, take the higher of the two
numbers and then take the lesser of that number and 10 percent.
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 has to do is find the occupancy records for January 1992 and see how many units
were occupied by non-elderly persons or families with disabilities on January 1. In this example, it was 10 units.

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 6 of 13

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

ADDENDUM B
Then the owner must find the occupancy records for October 1992 and see how many units were occupied by non-elderly
persons/families with disabilities on October 28th (the date of the enactment of the Act). In this example it was 15 units.
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 (January 1, 1992 and October 28, 1992), which, in this example is 15.
Then the owner must compare that number with 10 percent of the total project units (in this example, it’s 10) and 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 the need exists in the community.
Answer question 4 as follows:
If there is an elderly preference in accordance with Section 651 of Title VI-D, answer “Yes”. If there is no preference provided
to elderly families, answer “No”. (Do not leave blank).
If yes, answer the following:
(a) If there is an occupancy preference in accordance with Section 651, indicate the effective date of the preference.
(b) If there is an occupancy preference in accordance with Section 651, indicate the total number of units that must be reserved
for non-elderly persons with disabilities based on the two dates above.
(c) If there is an occupancy preference in accordance with Section 651, indicate which date (see above) was used to determine
the number of units that must be reserved for non-elderly persons with disabilities.
5. Section 658 of Title VI, Subtitle D of the Housing and Community Development Act of 1992 (Title VI-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-D, answer “Yes.” If there is no elderly restriction and occupancy
is not limited to elderly applicants, answer “No.” (Do not leave blank).
6. If the property designates a number of units that can be occupied only by elderly persons, indicate the number of units. If the property does
not have units that can only be occupied by elderly persons, enter zero “0”. (Do not leave blank).
7. If the property designates a number of units that can be occupied only by persons with disabilities, indicate the number of units. If the
property does not have units that can only be occupied by persons with disabilities, enter zero “0”. (Do not leave blank).
8. If the property has units that must be occupied by non-elderly persons with disabilities, indicate the number of units. If the property does not
have units that must be occupied by non-elderly persons with disabilities, enter zero “0”. (Do not leave blank).
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. (Total must match numbers entered for each
bedroom size. Do not leave blank.)
2. Enter the total number of units (by bedroom size) that are receiving project based rental assistance. (Total must match numbers entered for
each bedroom size. Do not leave blank.)
3. Enter the number of mobility accessible units (by bedroom size) and enter total in the “Total” column. A mobility accessible unit is one that is
located on an accessible route, and when designed, constructed, altered, or adapted, can be approached, entered, and used by individuals with
physical disabilities, including those who use wheelchairs. (Although accessibility features include items such as grab bars, flashing fire alarms,
widened doorways, entrance ramps, etc, this question should be answered by stating the number of subsidized units that (when constructed) are
fully accessible in accordance with the Uniform Federal Accessibility Standards (UFAS) which is used to ensure compliance with Section 504 of
the Rehabilitation Act of 1973. These standards were jointly developed by the General Services Administration, the Department of Housing and
Urban Development, the Department of Defense, and the United States Postal Service, under the authority of sections 2, 3, 4, and 4a, respectively,
of the Architectural Barriers Act of 1968, as amended, Pub. L. No.90-480, 42 U.S.C. 4151-4157. Copies of the UFAS are available from the
Architectural and Transportation Barriers Compliance Board , 1331 F Street, NW, Suite 1000, Washington, D.C. 20004-1111, Telephone: (202)
272-0080, email address: info@access-board.gov. If the property is accessible in accordance with Minimum Property Standards (MPS), indicate
the number of units that are MPS accessible. Unsubsidized units are not required to meet the requirements of UFAS, however those units should

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 7 of 13

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

ADDENDUM B
be counted if they are fully accessible to persons who use wheelchairs.) (Total must match numbers entered for each bedroom size. Do not
leave blank)
4. Enter the number of units (by bedroom size) that are accessible for vision or hearing impairments and enter total in the “Total” column. (Refer
to UFAS. See instruction number 3 above) (Total must match numbers entered for each bedroom size. Do not leave blank)
5. Total the units from rows 3 and 4 for each bedroom size and enter total in the “Total” column. (Total must match numbers entered for each
bedroom size. Do not leave blank.)
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. Do not leave blank.)
7. Enter the number of accessible units (by bedroom size) that are currently occupied by elderly or family tenants and enter total in the Total
column. (Total must match numbers entered for each bedroom size. Do not leave blank.)
8. Enter the number of accessible units (by bedroom size) occupied by non-elderly tenants with disabilities requiring the features of the unit and
enter total in the “Total” column. (Total must match numbers entered for each bedroom size. Do not leave blank.)
(These tenants must have a mobility impairment as defined above.)
9. Enter the number of accessible units (by bedroom size) occupied by elderly tenants with disabilities requiring the features of the unit and enter
total in the “Total” column. (Total must match numbers entered for each bedroom size. Do not leave blank.)
(These tenants must have a mobility impairment as defined above.)
10. Self-explanatory (Do not leave blank.)
11. Self-explanatory (Do not leave blank.)
12. Self-explanatory (Do not leave blank.)
CERTIFICATION:
Self-Explanatory (Must be signed and dated by the owner)
SECTION III – Owner/Agent must respond to all questions in this section. (Not applicable to unsubsidized projects)
1.
The Section 504 Coordinator is required if the owner employs 15 or more employees in all its activities. This includes this project
combined with other projects they may own and/or manage. Answer Yes or No. If yes, proceed to Question 2; if no skip to Question 3.
2.
Answer Yes or No to this Question. If yes, please provide the name and telephone number of the coordinator for Section 504 related
activities at the project and go to Question 3.
3.Answer Yes or No to each item and provide comments as necessary.
CERTIFICATION:
Self-Explanatory (Must be signed and dated by the owner)

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 8 of 13

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

ADDENDUM B
PART B
ON-SITE LIMITED MONITORING REVIEW
Authority: 24 CFR 5, 108, 110

Questions 1 through 4 apply to owners of subsidized and unsubsidized projects.
YES

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) on
site?
If Yes, proceed to question 3.
If No, proceed to question 5.
3. Has the owner/agent reviewed the AFHMP
within the last 5 years to ensure that the
information is current and applicable?

4. Date of last AFHMP Update
Date:
5. Does the project maintain Project Profile Data
which shows the composition of the occupants
by the following categories (24 CFR 121):
a.
Race

National Origin/Ethnicity

Sex

Disability

Familial Status

6. Has the owner/agent developed and
implemented a written Tenant Selection Plan?

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 9 of 13

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

ADDENDUM B
YES

COMMENTS

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

(a) Name

(b) Bedroom size

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

(e) Preferences?

8. 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?
9. Does the owner/agent maintain a record of
fair housing complaints?

Unable to Observe

10. Is there a local residency preference?

If yes, was it approved by HUD?

Date of HUD Approval:

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 10 of 13

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

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

COMMENTS

1. Is there a formal, written grievance procedure
that provides for resolution of complaints
alleging discrimination based on disability, as
required by Section 8.53(b)?
Date:

If Yes, document date procedures were
adopted:

2. Does the owner/agent utilize a
telecommunications device for the hearing
impaired (TTY)?

If No: Is there an alternative procedure?
Describe under “Comments”

3. When necessary, are auxiliary aides used to
communicate with persons with disabilities?
Describe under “Comments”

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 11 of 13

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

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

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

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

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

d. The document is not
available.

For Part A
1. Accessible Units/Program Accessibility,
Sections I, II, and III (as applicable)
For Part B:
2. Most recent Affirmative Fair Housing
Marketing Plan (AFHMP)
3. Any of the following documents that are
used for outreach as specifically stated in
the project’s AFHMP or used for other
affirmative fair housing marketing.

Newspapers/Publications

Copy of Radio Ads and Announcements
Copy of TV Ads and Announcements
Photograph of billboards
Letterhead
Handouts
Brochures and Leaflets
Photograph and site signs
Other (Specify):
4. Project Profile showing occupancy data
(See Part B, Question 5).
5. Written Tenant Selection Plan

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 12 of 13

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

ADDENDUM B
Please Note: The information below only
pertains to Section 504 compliance. If this
project is unsubsidized, 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:
6. Written Grievance Procedure (Part C,
Question 3 and 24 CFR 8.53)
7. Application for Occupancy
8. Reasonable Accommodation Policy
FHEO requested that the reviewer observe the following:

The result of the observation is:

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2
Page 13 of 13

ADDENDUM C
OMB Approval No. 2502-0178
Exp. 09/30/08

DOCUMENTS TO BE MADE AVAILABLE BY OWNER/AGENT
Instructions: Reviewers should place a check mark next to those items that must be available for review.

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 (HUD-92458)
Procurement Files
Work Order Journals/Logs
Cash Disbursement Journal
Fidelity Bond
Property/Liability Insurance
Copies of the 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
Copy of Lease, lease addendums 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 Tracking Log
List of all current Principals and Board Members
Other

Civil Rights Front End Limited Monitoring and Section 504 Review Documents
Affirmative Fair Housing Marketing Plan
Tenant Selection Plan
Recent Advertising
Fair Housing Logo and Fair Housing Poster

form HUD-9834 (04/07)
Ref. HUD Handbook 4350.1, REV-1
and HUD Handbook 4566.2

File Type	application/pdf
File Title	Part A: Maintenance and Security Review most recent physical inspection report before responding to the items below
Author	Kimberly Sanford
File Modified	2007-05-02
File Created	2007-05-02