0:06 hello and welcome to another episode of
0:08 Tuesday tips I'm Pam kowas and today as
0:11 part of our mastering the series we're
0:14 going to be looking at tenant files one
0:17 of the most common questions that we get
0:19 when it comes to tenant files is what
0:22 should my files look like what order
0:24 should be things be in the answer to
0:27 that is that HUD does not have a
0:30 particular order so that means that it's
0:32 up to you to decide what order your
0:34 files are going to be in there are a
0:36 couple of common options we generally
0:38 either see people using a divided file
0:41 so one of the files with a different
0:44 number of dividers in it and then they
0:46 section it off as per owner agent policy
0:49 or we see some people that put their
0:51 tenant files into a binder again divided
0:54 by
0:55 sections there is no right way to do
0:58 this some section by year some will
1:01 section by typee of document so they'll
1:03 have say all of the leases in one place
1:07 um all of the moving things in one place
1:10 so it's really up to the owner agent to
1:12 set the particular order of a
1:15 file what we do look at though is what
1:19 those tenant files should have so not
1:21 necessarily what order they should be in
1:23 but what needs to be in there so some of
1:26 the things that need to be in there
1:28 include your application screening and
1:33 movein information so everything from
1:36 the point that someone applied to the
1:38 point that they moved in including that
1:42 after moveing eiv
1:43 report you're also going to have in that
1:46 the most recent three years worth of
1:49 certifications so the current
1:52 year and then two full previous years
1:57 based on the tenants certification date
2:01 then again everything related to that
2:03 movein in the tenant file should be
2:05 anything related to any eiv
2:07 discrepancies that you found and
2:10 resolved and then any of your eiv income
2:14 and summary reports included as part of
2:16 movein annual and then interims if you
2:19 are currently doing those then there are
2:21 some things that should really not be in
2:23 your tenant file so the things that you
2:25 do not want in your tenant file are one
2:29 duplicate or conflicting information
2:31 this is a common source of questions and
2:34 potentially findings at your and what I
2:37 mean by duplicate or conflicting
2:39 information is for
2:41 instance let's say that the tenant gave
2:44 you their yearly e uh social security
2:47 statement and you also pulled
2:50 eiv if the social security benefit
2:54 letter says they're getting $1,000
2:57 and10 and the EI report says
3:01 $1,000 that's conflicting
3:04 information so as long as the
3:06 information is accurate in eiv that's
3:08 what you should be
3:10 seeing and then if you have gotten
3:12 anything in the process that conflicts
3:15 with that just by virtue of having
3:17 pennies you can get rid of
3:19 that another thing that should not be in
3:22 there is vawa information vawa
3:25 information has specific guidelines on
3:27 protection so you want to make sure that
3:29 that is either sealed in an envelope so
3:32 that people can't see it or preferably
3:35 in a completely different file so that
3:39 it's not in the active tenant file that
3:41 people are
3:43 reviewing you want to be very careful
3:45 about irrelevant information information
3:48 that we're not using you don't want to
3:50 have copies of actual Social Security
3:53 checks in the
3:55 file and you don't want to have things
3:57 like specific disability
4:00 diagnosis so I may need to know whether
4:03 somebody qualifies as disabled or
4:06 whether they have a need for the
4:07 features of an adapted unit but I don't
4:10 need to know what their specific medical
4:13 diagnosis
4:15 is and then you want to be careful of
4:17 information that is related to a
4:20 different regulatory body this is
4:22 particularly concerning with tax credit
4:25 properties so generally speaking you're
4:27 having two files you're having your tax
4:30 credit file and your HUD file if you
4:33 have both of those regulatory bodies you
4:35 can certainly to make your life easier
4:38 copy the information and then just place
4:40 a copy in each of those files but lihtc
4:46 reviewers really shouldn't be seeing
4:47 your HUD information and your HUD
4:49 reviewers really don't need to see your
4:51 tax credit information so be careful of
4:53 that when you're doing files as well one
4:55 reminder here is that when we are
4:58 looking to verify Social Security
5:00 numbers a common misconception is that
5:03 you have to get a copy of the social
5:05 security card you do not HUD actually
5:08 specifically says it's not mandatory
5:11 that the card itself be copied what you
5:14 need is something that verifies the
5:17 number and there are a few different
5:19 ways that you can do that if you take a
5:22 look at appendix 3 and the
5:24 4350.3
5:26 that will give you a number of different
5:29 ways that you can
5:33 verify so I do have a slide that shows
5:36 you that so here we go this is the
5:39 appendix 3 it's hard to read because
5:41 it's very small but if you go into the
5:44 4350.3 whether you have that
5:46 electronically or by paper and you look
5:49 for appendex 3 which is going to be in
5:50 the back of the
5:53 handbook you can see that HUD gives you
5:57 a list of all the different things you
5:58 can use to verify
6:00 it's not a bad idea to keep a copy of
6:02 this handy so that when you're looking
6:04 at documents that your tenant has given
6:06 you especially in those short time to
6:09 process
6:10 certifications you can look at the
6:12 different things that you can use to
6:14 verify one caveat on that though is that
6:17 hotma may change this so you do want to
6:20 be aware of that as well this right here
6:22 has drilled down into what the appendix
6:26 3 says about social security numbers so
6:29 you'll see there are a number of
6:30 different things that we can get we can
6:32 look at the original social security
6:35 card um an original document issued by
6:38 another agency that shows the social
6:41 security number or um some of the what
6:44 used to be called tpq benefit printouts
6:47 from Social Security will have the
6:49 number on it there are some drivers's
6:51 licenses that print Social Security
6:54 numbers on them depending on what state
6:55 you're in so if the tenant for any
6:58 reason does not want to give you their
7:00 social security number or card or if the
7:03 applicant doesn't want to do that you
7:05 can look for other methods of verifying
7:08 you just need to make sure that you have
7:09 something that verifies that social
7:11 security number when it comes to
7:14 verifying
7:15 disability you have to be very careful
7:17 about what specific information is in
7:19 the
7:20 file you need to know that somebody is
7:25 disabled and needs what they're asking
7:27 for but you don't necessarily need to
7:30 know their specific diagnosis or the
7:33 specific nature or extent remember of
7:37 disability so we all know that the
7:40 doctors and you know other healthc care
7:42 providers out there tend to provide us
7:46 with the notes if you get a note instead
7:49 of the verification form that will
7:51 contain information we don't need
7:53 they'll say things like Mary has been
7:55 diagnosed with multiple sclerosis and
7:59 has X Y and Z limitation and takes X Y
8:02 and Z medication we don't need to know
8:05 all that we need to know yes she has a
8:08 disability and yes she qualifies for an
8:11 adapted unit so should you get a healthc
8:15 care provider letter that has all sorts
8:17 of information that you don't need you
8:20 want to be careful to exclude that from
8:22 the file you can do that one of two ways
8:25 you can redact it which means you would
8:27 just black out the name of the specific
8:31 diagnosis or you know the information
8:34 that you don't need and then note the
8:35 file that you've redacted that specific
8:38 information or you can keep the specific
8:42 note in a separate file and make a note
8:46 in the tenant file that states physician
8:49 provided note that confirms that the
8:51 person has a
8:52 disability and go from
8:55 there so again what you need to know is
8:58 does the indiv idual meet the definition
9:01 do they either need what they're asking
9:03 for when it's an accommodation or
9:05 modification or do they qualify for a
9:09 specific unit there are some projects
9:12 where eligibility for the project or for
9:15 specific unit is tied to whether that
9:18 person has a disability or in some cases
9:21 has a particular type of disability so
9:25 the ideal way to get that is to send out
9:27 a set verification form that only
9:29 gathers the information you
9:31 need but you do often get those notes
9:34 and you just want to check
9:36 them you may need to ask is the
9:39 disability permanent or not um there are
9:43 sometimes where a person has a
9:45 disability but may get surgery to
9:47 correct it or you know for some other
9:50 reason may not remain disabled for the
9:54 rest of their life so you may need to be
9:57 asking if it's not perent how long is it
10:01 expected to last and again as long as
10:03 you're not asking for what is their
10:07 disability you know those are the
10:08 questions that you can ask and the
10:11 information you want the
10:13 file so here's an example of a
10:15 physician's note I've treated Janes SMI
10:18 for the last 10 years she suffers from
10:20 multiple sclerosis she can't ambulate
10:23 without assistance uses a wheelchair
10:26 Walker or cane and she requires an
10:28 accessible unit in parking space so
10:31 there's information I need there and
10:33 information I don't need in there so I'm
10:35 going to redact that I've treated jange
10:39 mitt for the last 10 years she suffers
10:41 from and I've taken out the
10:43 diagnosis she uses I don't need to know
10:46 what
10:48 specific uh equipment that she uses
10:51 therefore she requires an accessible
10:53 unit in parking space right so I know
10:56 she's disabled she needs a parking space
10:59 and then you'll see there's a note at
11:00 the bottom here this is the note that I
11:02 would put in the file it basically just
11:04 references specific information on
11:07 disability has been redacted
11:09 physicians's confirmed she's disabled
11:11 and she needs what she's asking for sign
11:13 and date okay so that's an example of a
11:16 redacted
11:17 one if items are kept separately here's
11:20 the kind of note you could put in the
11:22 file uh tenant voluntarily provided a
11:25 copy of a letter but that indicates you
11:28 know a lot of information that I don't
11:30 need and after review we've decided that
11:33 yes it confirms the existence of a
11:35 disability yes it confirms the need sign
11:38 and
11:39 date so in this case that actual note is
11:42 going to be kept wherever I keep you
11:44 know personal correspondence things like
11:46 that and this note is going to be kept
11:49 in the file that way if somebody needs
11:51 to see that original note you have it
11:54 but in the file that's being reviewed
11:56 you don't have information that doesn't
11:58 necessarily need to be there so when
12:00 you're organizing that file there are
12:03 some helpful hints to to keep in mind
12:06 one file items promptly don't stick them
12:10 in there loose and intend to file them
12:12 later we all know that housing is a very
12:15 busy Arena and it's very difficult
12:19 sometimes to get back to things later so
12:21 file items promptly and file them
12:24 securely do not leave loose paperwork in
12:26 your file it's very easy for things to
12:29 missing and it makes your file more
12:31 difficult to
12:33 review make sure that you have a
12:35 consistent order for your files that's
12:38 generally sent by the management agent
12:40 who will say this is our file order this
12:43 is what sections we have but make sure
12:46 that you're following that order
12:48 consistently and secure your files
12:51 appropriately depending on what your
12:53 policies are that could mean a locked
12:56 drawer in a locked cabinet could just
12:58 mean a a locked cabinet a locked
13:02 office and you want to make sure that
13:04 you are limiting access to appropriate
13:07 personnel so you want to make sure that
13:09 only the people who should be in there
13:11 have access to those files further tips
13:14 cover sheets are very helpful or a file
13:17 guide they're not required but it does
13:20 help when we are reviewing your files to
13:22 have a general idea of what order we
13:24 should see things in some people do a
13:26 cover sheet for each section some just
13:29 have a file system guide that they will
13:31 give us but it does really help to have
13:33 that so we can get through your files
13:35 quickly and
13:37 easily another thing to note is that
13:39 depending on what file system you were
13:42 using you know the secured files with
13:45 the clips or a binder it may be more
13:49 helpful to have single sided copies
13:52 rather than double-sided I know that we
13:54 all want to save paper but double-sided
13:56 copies often make the file a little hard
13:59 to review and sometimes that can result
14:02 in things not being seen so you always
14:05 want to think of making that file easy
14:07 to navigate easy to find things that we
14:09 want to see one of the common questions
14:13 we also get too is what do we do with
14:16 rsc's who need to see eiv copies because
14:19 sometimes rsc's are helping with
14:20 benefits and need Social Security
14:22 information rsc's your resident services
14:26 coordinators may not see eiv printouts
14:30 unless that happens with tenant consent
14:33 the best way to do that is to provide a
14:36 copy to your tenant and let the tenant
14:39 provide it to the RSC generally you're
14:42 not going to use that third-party eiv
14:45 consent with your own staff so it is
14:48 always a safer bet to provide a tenant
14:50 with a copy that they can share to the
14:53 with the RSC if they want
14:54 to you want to make sure that you are
14:58 making notes and using consent forms if
15:01 you are providing any copies of anything
15:04 in the file to a third party um HUD does
15:07 not dictate anything other than the eiv
15:10 thirdparty form so anything other than
15:13 that you are going to be providing on
15:16 whatever the owner Agent form for
15:18 release
15:19 is and again we talked about multiple
15:21 regulatory bodies for files before USDA
15:26 lhtc Personnel none of them at present
15:29 can see actual eiv printouts unless a
15:33 tenant is discussing it with them and
15:36 wants to share that so you are going to
15:40 potentially put a note in the file let's
15:42 say I have a USDA property with a HUD
15:45 subsidy as far as Social Security
15:48 verification goes I am either going to
15:50 get an award letter and use that from my
15:53 USDA file or write a note in there that
15:58 I have used the IV system and I verified
16:01 that the social security amount is X um
16:04 some regulatory bodies will accept that
16:07 others may not be as willing to accept
16:09 that so you may need to get some other
16:11 proof like an award letter what do we do
16:13 about prior errors that we can't fix
16:16 either things that happened under
16:18 another management company or things
16:21 that happened with our staff but
16:23 happened 5 years ago and there's no way
16:25 to fix
16:26 them the best thing that you can do with
16:29 these is when you come across something
16:31 like that note the file put a note in
16:34 there that says what happened and what
16:36 you did to address it so for instance I
16:40 noticed that the existing tenant search
16:42 wasn't run for an applicant when I'm
16:45 looking at that file as the owner agent
16:49 I'm going to go into that file and go oh
16:50 we didn't run that check so I'm going to
16:53 put a note in the file that says noted
16:56 during a quality assurance review or
16:58 during you know processing an annual
17:00 research whatever it was we noted that
17:03 the existing tenant search was not run
17:05 for this applicant you're going to then
17:08 advise of the corrective action um if
17:10 I'm the regional I might say reviewed
17:12 eiv policies with existing staff and in
17:16 the future this is how we're going to
17:18 ensure that that doesn't happen again in
17:21 some cases when you do that you've noted
17:24 that there was an error you identified
17:26 it you fixed it it may mitigate or lower
17:30 the
17:31 the points if you will lower the
17:34 severity of a finding because you have
17:37 identified the problem and addressed it
17:40 so you always want to do that if you
17:41 come across prior
17:44 errors so I have a couple of examples
17:46 for you first one is you know owner
17:50 agent review noted that existing tenant
17:52 search was not run for this applicant's
17:54 move in we attended eiv training on a
17:58 particular date
17:59 eight we reviewed the requirements with
18:02 the staff and moving forward this is
18:04 going to be run for everybody sign and
18:07 date there's another one for a 90day eiv
18:10 report this report wasn't run for this
18:13 tenants mve in this movement occurred
18:15 under a prior management company sign in
18:19 date and as I said in some cases that's
18:21 going to either
18:23 mitigate or kind of temper that finding
18:26 because you've already noted it
18:28 addressed it corrected
18:32 it so in summary looking at these files
18:35 again the owner agent sets the order you
18:37 just want to make sure that the file
18:39 order is consistent for all your
18:41 files you want to have the most recent
18:44 three
18:45 years plus the movein and the move out
18:48 if it's a move out file with the move
18:51 outs make sure you have your final
18:53 account statement whatever your final
18:55 paperwork is that you hand out to 10
18:59 when they move out final account
19:00 statement a letter with security deposit
19:03 information on it whatever it is that
19:05 you do for a move out make sure that's
19:07 in your moveout
19:08 files ensure that you're filing your
19:11 paperwork promptly and securing any
19:13 loose
19:14 paperwork make sure that you're noting
19:16 any unusual situations or unfixable
19:20 errors remove any unused duplicate
19:24 conflicting information from the file if
19:27 there's conflicting information for a
19:29 legitimate reason let's say your tenant
19:32 has reviewed their eiv print out with
19:35 you and says no that's a not accurate my
19:38 benefit amount just changed so you asked
19:41 them to bring in a a benefit letter and
19:43 both of those are in the file for a
19:45 legitimate reason make sure you're
19:47 noting that tenant reviewed the eiv
19:50 printout said it wasn't accurate so I
19:53 asked for follow-up documentation and
19:55 this is what I got
19:58 you want to make sure your files are
20:00 secured so only those people who should
20:02 see them see
20:04 them and the best thing to keep in mind
20:07 when you're deciding how to do these
20:08 tenant files is your file should tell a
20:12 complete story anybody that is coming in
20:15 to look at your file or if you think of
20:18 somebody covering your office should be
20:21 able to pick up that file and know the
20:23 complete story why did you count what
20:26 you counted why didn't you count X y or
20:29 Z why are there two pieces of
20:31 information in here that say different
20:33 things you're having your file tell a
20:36 story that is this is why I did what I
20:39 did this is why I have the amounts that
20:41 I have and that kind of prevents any
20:45 questions on why something's in there
20:48 why you use this
20:50 number that's going to help you to have
20:53 your
20:54 reviewer get in your building through
20:56 your files and out of building as
20:59 quickly and efficiently as possible
21:02 which is all of our goals we don't want
21:04 to keep you away from your work any
21:06 longer than we have to to do this review
21:09 and we want to give you a chance to
21:11 shine at your review and show us how
21:13 well you're managing this very
21:15 complicated business that we're
21:18 in so that is going to do it for today
21:21 as always you can contact us you can
21:24 contact Vicky Bell our other trainer or
21:26 me with the information that's on the
21:28 screen thank you for joining us for this
21:31 Tuesday tip and we'll see you next
21:35 [Music]