Hello and thanks for joining us for another Navigate Tuesday tip. I'm Pam and today we're gonna take a look at what makes a compliant tenant file. When we're looking at what compliant files are, we are most concerned about the active tenant file, which means the one that you're in every day, the one that is presented for review.

In the tenant file, you must keep the application and essentially everything related to it. So screening, appeals, correspondence, all of that stuff related to the initial application, your move-in and information. So the certifications, leases, addenda, house rules, all of the things that go with your move-in.

and then the most recent three full years of certifications. Now that date is gonna change depending on when the person re-certifies It could be January to December or May to April. Whatever their certification here is, you need to keep the most recent three. So make sure your certification forms are in there, any EIV documentation and anything else that goes along with that certification.

everything else you can archive. So if they've been there for 15 years, you need the move-in, the most recent three, and all of those middle certs you can archive. So you're going to pull those things out of your active tenant file, but you need to keep them. And we'll talk about the timeline in a second. Make sure that your VAWA information is in a separate file and restrict access to that information.

Maintenance, you can keep that in a separate file and you could potentially keep a separate file for correspondence, but make sure that that's available in case it's needed. You want to keep everything related to your tenants' tenancy.

So from move in till move out and hold on to that file for three years after they moved out. With an applicant, you're going to keep everything related to an applicant until three years after they've come off the wait list. So you can archive it, you can pull it out of the active tenant file that you're handling every day, but you must keep all of those things in storage until three years has passed from the time they moved out.

or were removed from the wait list. If you destroy things, you need to keep a record of what you destroyed, how, by whom, and when. And it's in the 4350.3, it's paragraph 4-22 on how you destroy files and what records you keep.

So for an example, if we have a management company that's setting up their files, they might choose, say, a folder with two dividers. And so that makes a six section file. They could set it up where one section is all their leases, one section is all their inspections, one section is their certifications for this year and the previous years. The move in information is another section.

Correspondence is another section. And then they took all of those in between years and archive them. They keep maintenance in a separate folder. They keep VAWA in a separate file cabinet. All that would be okay as long as they're keeping what HUD requires that they keep. So again, this is just an example. There is no set file order. You just wanna make sure that what head says you should keep is kept.

It is up to the owner and agent to decide their file order. But there are some things to keep in mind. It should be organized and easily reviewable. It should be consistent tenant to tenant. A good idea to help make the MOR easier is to provide the reviewer with a copy of what your file order is because it is a little different. Property manager to property manager, at least companies.

and you may want to include in your files notes for anything that is unusual. If there's a reason you did three interims in six months, you may want to put a note to the file to explain that. The goal is to make your file easy to go through and to make sure that it tells a complete story. But again, HUD does not mandate a specific order, nor does navigate. With electronic files,

One of the recommendations that we have is that you make sure that the file naming convention that you use makes it clear what's in those files. So HUD and your contract administrator do not mandate that, but it's a good idea to make sure those are organized and to make sure that the file name is clear as to what's in that file. Make sure they're consistent, keep documents in the same order file to file.

and make sure that you're using reasonable measures to protect that. So encrypt electronic files, make sure you're following HUD's guidelines regarding what should be in there and what should be stored separately. And remember that you also have state and federal confidentiality laws that typically will cover things like credit reports and how they're stored. So your key takeaway is from this, HUD mandates what you have to keep, but not the specific setup of a file.

That's an owner agent thing. Files should be consistent, organized, and kept confidential. Electronic files are permissible by HUD. You do need to also keep them in a manner that's easy to review. And remember, your VAWA information always needs to be kept in a separate locked file. And you have to ensure that only the people that need to see it can access it.

Some of the resources that you can look at, the 4350.3 does talk about files and what to keep and how long to keep them. You're gonna be looking at the HUD 4350.3 Occupancy Handbook, chapters four, five, and nine.


Some contract administrators or professional agencies may have examples or suggestions. Navigate defers to HUD. We do not have a recommended file order, but I have seen some others that do. So if you're with another contract administrator, you may want to ask them if they have a preferred order. And that's going to do it for files. What would you like to see on the next Tuesday Tips? We would love to know your suggestions.

You can email those to me at my email address, which is on the screen. It's pkazlauskas at navigatehousing.com. You can also use our portal on the Navigate website if you'd like to send a suggestion in. Thanks for joining us and we'll see you on the next one.