HUD and Manuals and EIV! Oh My!!

Working in HUD subsidized housing is not easy!

People assume it’s like running a hotel with a few problematic tenants.

In reality, sometimes the tenants are the easiest part of the job. It’s everything else you have to manage that makes the work tough.

There is a huge amount of paper work and with each piece of paperwork you fill out there is a regulation that goes with it. A regulation you are not only supposed to know but must also understand.

There are more manuals than you care to name, but the two you may use the most are the Management and Occupancy manuals.

The Management manual has 9 chapters and 7 appendices, and is more than 600 pages. The Occupancy manual also has 9 chapters and several appendices and it too has more than 600 pages.  It is true that you will never know everything in these manuals, but you do need to know how to find important information, as you need it.

Don’t let the size of the books intimidate you. 

Take some time to review the ‘how-to’ section and be familiar with the titles of the chapters.  Learn how to write and use a citation to your benefit.  Your asset manager will confirm that the manuals (especially with the occupancy manual) are open to interpretation.  Still you need to review the information so you can begin to interpret it. Should you ever need to answer to HUD or management will need to defend your answer.

Learning the regulation will help you stay in compliance. 

For example, I would say pretty much everyone knows that 30 is a big number in HUD.  You need to give a tenant 30 days to review updated information in your Tenant Selection Plan or you need to give a tenant 30 days to review their new rent; especially if their rent goes up. These, of course, are not exclusive. .

Also, remember when you are doing a recert that if you can’t get all the information in time it is better to stay in compliance send the recert and you can then complete an interim when you get the information.  Not sending the information will put you out of compliance and you may find yourself paying back some money to HUD.

To keep the money flowing you must stay in compliance.

Last but not least MORs. 

By this point you have had or will shortly be having an MOR.  Let’s recap: this MOR (after a 5 yr. delay) was pretty much a trial run for the new reviewers and even the old reviewers.  Listening to our clients we have learned that some reviewers stressed one thing, some stressed other things.  The one thing they all stressed was management of EIV.  Do you have a policy and are you following it?  Are you running all reports appropriately and what are you doing about discrepancies?  Now is the time to go over your findings and look at your weak points, don’t make the same mistakes next year.  Yes, everyone will have an MOR next year, with reviewers who are much more knowledgeable.  Start preparing now.  Hopefully you made two information books one for the reviewer and one for your company. Don’t wait till the last minute to get started.

Several of you asked about attending an MOR class.  This is the time to look for one, especially now that you know what you are looking for. If you have any questions or concerns about these issues, give me a call at (216) 577-7430 or send an email to me at

Best of luck


Posted in Affordable Housing, Blog, Blogs, HUD, My Adventures in Affordable Housing

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