EIV Report Retention Requirements
Review EIV report retention periods, file locations, and documentation requirements for owners and agents.
Enterprise Income Verification reports support accurate income determinations and help protect program integrity. However, generating the correct report is only one part of the process. Owners and agents must also know where to file each document and how long to retain it.
EIV report retention requirements vary by report type. Some reports belong in the tenant file. Others belong in a master file. In addition, certain supporting documents must remain with the applicable household record.
HUD Notice H 2010-10 provides instructions for the required use of EIV by owners and management agents. HUD Handbook 4350.3, Chapter 9, also explains EIV requirements for subsidized multifamily housing programs.
Owners and agents should use this overview with current HUD guidance and their written EIV policies and procedures.
EIV report retention requirements for tenant files
Several EIV reports must remain in the tenant file for the term of tenancy plus three years.
These reports include:
- Summary Report: Retain the report in the tenant file for the term of tenancy plus three years.
- Income Report: Retain the report in the tenant file for the term of tenancy plus three years.
- Income Discrepancy Report: Retain the report in the tenant file for the term of tenancy plus three years.
- No Income Report: Retain the report in the tenant file for the term of tenancy plus three years.
The retention period does not end when the household moves out. Instead, the property must retain the applicable record for three additional years.
This requirement supports future monitoring, audits, and reviews. It also allows reviewers to confirm how staff verified income and resolved discrepancies.
Owners and agents should organize EIV documents consistently. For example, staff should be able to identify the report, the review date, the action taken, and any supporting verification.
A clear filing process can also reduce misunderstanding during a Management and Occupancy Review. Therefore, written procedures should identify who runs and reviews each report and where and how staff retain it.
EIV report retention in master files
Some EIV reports serve a broader monitoring purpose. Therefore, owners and agents must retain them in designated master files.
- New Hires Summary Report: Retain the summary report in a master New Hires Report file for three years.
- Identity Verification Reports: Retain the reports in a master file for three years
- Failed EIV Prescreening Report
- Failed Verification Report
- Deceased Tenants Report: Retain the report in a master file for three years.
- Multiple Subsidy Report: Retain the report in a master file for three years
However, a master report may lead to tenant-specific follow-up. In that case, the relevant detail report and supporting documentation may also belong in the tenant file.
For example, HUD’s EIV report guidance distinguishes between the New Hires Summary Report and tenant-specific New Hires Detail Reports. The summary remains in the master file. Meanwhile, the applicable detail report and related documentation remain in the tenant file for the term of tenancy plus three years.
A master file should contain all required periodic reports for three years. The tenant file should contain all tenant-specific EIV reports and associated documentation and must show how staff resolved the issue. Relevant records may include correspondence, third-party verification, corrected certifications, or other documentation supporting the action taken.
EIV report retention for special report findings
Some reports require different handling based on the result and the household’s status.
Multiple Subsidy Report
When a Multiple Subsidy Report identifies a possible issue, staff should review the applicable Multiple Subsidy Detail Report, which identifies tenants who are receiving subsidy elsewhere. Retain the Multiple Subsidy Detail Report, along with documentation verifying the action taken, in the tenant file for the term of tenancy plus three years.
This report is not to be run for applicants – applicants must be screened using the Existing Tenant Search. Find HUD’s Multiple Subsidy Report training slides here.
Identity Verification (Failed EIV Prescreening, Failed Verification), New Hires and Deceased Tenants reports)
Retain the master reports for three years. Additionally, retain any tenant-specific detail report and documentation used to verify or resolve the discrepancy in the applicable tenant file.
Keep that tenant-specific documentation for the term of tenancy plus three years.
Existing Tenant Search
The Existing Tenant Search is used when processing an application for admission.
If the property denies the applicant, retain the appropriate documentation in the denied applicant’s file for three years. If the property admits the applicant, retain the applicable documentation in the tenant file for the term of tenancy plus three years
Strengthen EIV report retention procedures
Written EIV policies and procedures should clearly address both report use and record retention. HUD has required multifamily owners to update their EIV policies and procedures as part of HOTMA implementation guidance.
Owners and agents should review whether their procedures identify:
- Each required EIV report
- The frequency or point at which staff run it
- The employee responsible for reviewing it
- The required follow-up process
- The correct tenant or master file
- The required retention period
- The documentation needed to show resolution
- The safeguards used to protect EIV information
Staff training should also cover the difference between summary reports and tenant-specific detail reports. Otherwise, a property may retain the master report but miss the documentation needed in an individual tenant file.
In addition, owners and agents should periodically test their processes. Select several files and confirm that the required reports, review notes, verification documents, and corrective actions are present.
Finally, review current HUD guidance before changing a policy. HUD maintains EIV guidance through its multifamily housing notices, handbook materials, and EIV resources.
A consistent retention process supports more than recordkeeping. It helps owners and agents demonstrate that staff reviewed EIV information, addressed discrepancies, and followed established procedures.
Frequently Asked Questions
How long must EIV reports remain in a tenant file?
The Summary, Income, Income Discrepancy, and No Income reports must remain in the tenant file for the term of tenancy plus three years.
Which EIV reports must remain in a master file?
The New Hires Summary, Identity Verification Reports (Failed EIV Prescreening, Failed Verification), Multiple Subsidy, and Deceased Tenants reports must remain in master files for three years. Retain tenant-specific detail reports (with documentation regarding actions taken as a result of review of the information) in the applicable tenant file for the term of tenancy plus three years.
Where should New Hires reports be retained?
Retain the New Hires Summary Report in a master file for three years. Retain tenant-specific detail reports and related documentation in the applicable tenant file for the term of tenancy plus three years.
How long should Multiple Subsidy documentation be retained?
Retain the Multiple Subsidy Report Summary in a master file for three years. Retain tenant-specific detail (with documentation regarding actions taken as a result of review of the information) in the applicable tenant file for the term of tenancy plus three years.
Must supporting documents also be retained?
Yes. Retain tenant-specific detail reports and documents used to verify or resolve findings in the applicable tenant file for the required retention period.
Does the Existing Tenant Search have a three-year retention period?
Yes. If the property denies the applicant, retain the appropriate documentation in the denied applicant’s file for three years. If the property admits the applicant, retain the applicable documentation in the tenant file for the term of tenancy plus three years.
