Findings

Criteria – Cites the regulation that applies to the finding.
Condition – Describes the deficiency found; the unit number and certification (if applicable) or the unit number and area (if it is a physical deficiency)
Cause – Describes why the deficiency occurred
Effect – Describes what did, or may have occurred as a result of the deficiency
Corrective Action – Indicates the steps the Owner/Agent must take to correct the deficiency, the documentation Navigate requires to confirm mitigation, and the date by which the documentation must be submitted to Navigate.

• Due 30 Days From The Date On The MOR Rating Letter
• Must address all findings noted in the MOR
• Must include documentation of mitigation
• If the finding involves a correction to a HUD 50059, the correction must be made to the certification indicated in the finding.
• It is helpful to prepare a cover letter that addresses each finding, and lists the documents attached that confirm mitigation of the finding.
• You must perform all steps and provide all documentation requested in the Corrective Action for each finding.
• If your response to a finding contains documents or actions other than what Navigate requested, explain your response in the cover letter.
• If, while preparing your response, you need clarification or assistance in mitigating a finding, you may call Navigate for advice or help in completing the mitigation.
• If you need additional time to prepare a complete response, contact your Navigate Relationship Manager or the Assistant Director of MOR Compliance for your state.
• If all findings are not addressed as requested the MOR will remain open until Navigate receives the required documentation to confirm all findings have been mitigated.
• If the Owner does not respond to the MOR or does not submit all documentation required to close the MOR a referral to flag will be submitted to the HUD Office.

These must be the original signed forms:

1. Owner’s authorization for individuals to access EIV on their behalf
2. Multifamily Housing Coordinator Access Authorization Forms (Signed original copy and current copy- must be renewed annually.)
3. User Access Authorization Form (Signed original copy and current copy- must be renewed annually.)
4. Signed Rules of Behavior Form(s) (for individuals without access to the EIV system.)
5. Copy of written policies and procedures for using the EIV employment and income data and reports.
6. ISS Security Awareness Training Certificate (Annual)

The following documentation will be required as needed:

1. Documentation relating to the follow-up of failed Identification/Verification Reports.
2. Documentation relating to the follow-up of Multiple Subsidy Report.
3. Documentation relating to the follow-up of Deceased Tenant Report.
4. Tenant files must be properly documented in accordance to HUD Notice 11-21.
5. Record of training conducted for staff annually.

Download or view the HUD 4350.3.

Acceptable forms of verification can be found in Appendix 3 of the 4350.3.

Final Multifamily Mailbox: 4350.3 REV-1 Summary of Questions.

Initial Appeal
An appeal letter with specific examples explaining the facts supporting a change in the rating must be forwarded to the HUD Multifamily Program Center Director and/or CA and postmarked within 30 calendar days of the Summary Report date.
The appeal decision letter will be transmitted to the owner/agent by the HUD Multifamily Program Center Director or the CA within 45 calendar days from receipt of the appeal. (Refer to HUD Handbook 4350.1 Chapter 6).

Final Appeal
If the owner/agent does not agree with the initial appeal decision, the owner/agent may submit a final appeal to the Multifamily Hub Director within 15 calendar days of the date of the initial appeal decision letter for a final decision from HUD within 45 calendar days from receipt of the final appeal. (Refer to HUD Handbook 4350.1 Chapter 6).
The owner/agent may request a meeting with the Multifamily Hub Director to present verbal arguments. The meeting must be requested and scheduled during the 30 calendar day period following the transmittal date of the initial appeal decision letter.
Final appeal decisions will not be subject to further appeal.

Attachment 6 of HUD Notice 11-21

An owner or management agent must provide a complete response to MOR findings within 30 days of the date on the MOR report letter. Review the report carefully and submit all required explanations, corrective actions, and supporting documentation by the stated deadline.

I would avoid saying “within 30 days of receiving the report.” Your existing page specifically measures the deadline from the date on the report letter.

A complete response to all MOR findings is due within 30 days of the date on the MOR report letter.

The response should address each finding and include the requested explanations, corrective actions, and supporting documentation. Owners and agents should follow the instructions in the MOR report letter.

An owner or management agent may appeal an overall rating of Below Average or Unsatisfactory. The appeal must be submitted within 30 calendar days of the MOR report letter.

Keep the response deadline and rating appeal as separate questions. They are related, but they are not the same process.

Label each attachment with the corresponding finding number. Then place the documents in the same order as the findings in the report.

The reviewer evaluates the response and supporting documentation. The reviewer may request additional information before determining whether the findings can be closed.