The topic of electronic signatures has routinely come up in the COVID-19 conversation. The U.S. Department of Housing and Urban Development (HUD) released new guidance this morning.
HUD released Notice H 20-4 to give guidance “to HUD multifamily assisted housing industry partners on electronic signatures, electronic transmission, and electronic storage of documents and forms.” The agency defines “industry partners as:
Owners of HUD multifamily assisted housing properties;
According to the notice, HUD’s Office of Asset Management and Portfolio Oversight (OAMPO) permits but does not require industry partners to transmit and store files electronically. If you choose to use electronic signatures, transmission and/or storage, you “must do so in compliance with federal, state, and local laws.”
Should you choose to “adopt” the terms of Notice H 20-4, you “must provide applicants and tenants the option to utilize wet (i.e. original) signatures and paper documents upon request. When feasible, industry partners, applicants, and tenants should have the option of providing signatures and documents in wet or paper form.”
Notice H 20-4 stresses the fact it does not change “the nature or use of required documents.” That guidance remains the same. “Section VIII provides the regulatory requirements for wet signatures and use of paper documents. These requirements supersede the guidance in this program Notice and must be followed.”
You can read the full notice by clicking the button below.