Tuesday Tip
How long should you keep tenant files? What about applicant records, EIV reports, or HAP requests?
HUD file retention requirements cover several types of records at multifamily properties. However, not every document follows the same retention schedule.
In this week’s Tuesday Tip, we’re breaking down what to keep, what you can archive, and how to organize your records.
How Long Should You Keep Applicant Files?
Owners and agents must maintain records throughout the application process. This includes everything from the initial application to the final decision.
For applicants who never move in, keep records for three years after they leave the waiting list.
These records include:
- Original applications and supporting documents
- Waiting list updates and correspondence
- Application processing records
- Approval or rejection decisions
- Rejection letters and proof of delivery
If an applicant becomes a resident, those records become part of the tenant file. Therefore, you must keep them throughout the tenancy and for three years after move-out.
What Should Stay in an Active Tenant File?
HUD File Retention Requirements for owners and agents include retaining tenant records throughout the tenancy and for three years after move-out.
However, you don’t need to keep every document in the active file.
For long-term residents, consider separating records into active and historical files.
Your active file should include:
- Original application and move-in documentation
- Post-move-in EIV report
- The most recent three full years of certifications and supporting documents
For example, a resident who moved in during 2021 would have their original move-in documents on file. The active file would also contain certifications from 2024, 2025, and 2026.
Meanwhile, you could move older certifications into an archived file.
Remember: Archiving doesn’t mean destroying. You must retain those records for the required period, even if staff don’t use them daily.
Does HUD Require a Specific Tenant File Order?
HUD tells owners and agents which documents to maintain. However, it generally doesn’t require a specific physical file format or document order.
Instead, owners and agents can establish a filing system that works for their properties.
A consistent system also makes it easier to prepare for Management and Occupancy Reviews (MORs).
Consider these best practices:
- Stay consistent. Organize every tenant file the same way.
- Separate certifications. Use dividers or markers to identify each certification period.
- Secure documents. Avoid loose papers that staff could misplace.
- Create a file guide. Give staff and reviewers a simple reference explaining your system.
- Standardize electronic files. Use clear naming conventions to identify documents quickly.
Although HUD doesn’t require a written file guide, having one can simplify the review process.
What EIV Records Should You Keep?
Enterprise Income Verification (EIV) records include access documentation and reports.
For EIV coordinators, maintain:
- Original and most recent Coordinator Access Authorization Forms (CAAF)
- Most recent Rules of Behavior
- Most recent security training documentation
- Owner authorization letter
The authorization letter confirms that the owner permits the designated coordinator to serve in that role.
For active EIV users, keep the original and most recent User Access Authorization Forms (UAAF). Also, maintain their Rules of Behavior and security training documentation.
For non-users who handle EIV information, retain the applicable Rules of Behavior and security training records.
Additionally, organize periodic EIV reports so staff and reviewers can find them easily.
You can arrange reports by month or report type. The Tuesday Tip recommends keeping periodic reports at least back to your previous MOR.
However, always follow applicable HUD requirements and your property’s retention policies.
What About HAP Requests and Other Records?
Tenant files aren’t the only records that require attention.
HAP requests: Keep the most recent five years of Housing Assistance Payment (HAP) requests. You can store these electronically or on paper.
Tenant Selection Plans and EIV policies: Maintain applicable current policies and make required documents available for review. Keeping previous versions can also help explain when procedures changed.
Budgets, invoices, and correspondence: Follow applicable requirements and your owner-agent retention policies.
Employment records: The employer or central management office typically maintains these under its established policies.
Before archiving or destroying records, check your property’s retention schedule.
Protect Confidential Information
Many property records contain sensitive personal or financial information. Therefore, owners and agents must protect them from unauthorized access.
Keep paper records in locked cabinets, drawers, or offices. Likewise, restrict electronic access to authorized personnel.
Remember that Violence Against Women Act (VAWA) documentation must remain separate from standard tenant files.
When records reach the end of their retention period, follow secure destruction procedures.
Maintain a log showing:
- What records were destroyed
- When they were destroyed
- How they were destroyed
- Who destroyed them
Shredding is a common disposal method. You can also use a qualified shredding service.
Before destroying anything, confirm that you’ve met all applicable retention requirements.
Keep Your Records Organized and Review-Ready
Good record keeping makes daily operations easier and helps properties prepare for HUD reviews.
Start by reviewing your filing system. Then, make sure staff know which records belong in active files and which can move into archives.
Finally, confirm that your procedures address confidentiality, retention periods, and secure disposal.
The goal is simple: Keep the right records, make them easy to find, and protect them for as long as required.
Frequently Asked Questions
How Long Must HUD Tenant Files Be Retained?
Owners and agents must generally keep tenant files throughout the tenancy and for three years after move-out. Other applicable requirements may extend that period.
Can Owners and Agents Archive Older Tenant Certifications?
Yes. You can move older certifications into historical files. However, you must keep them accessible throughout the required retention period.
HUD generally doesn’t prescribe a specific physical file order. Owners and agents can establish their own consistent filing systems.
How Long Should Owners and Agents Keep HAP Requests?
The Tuesday Tip identifies a five-year retention period for HAP requests. Owners and agents can store them electronically or on paper.
Can You Shred Old Tenant Files?
Yes, once you’ve satisfied all applicable retention requirements. Use secure disposal methods and maintain a destruction log.
