Appendix 1~8.xlsx

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Tenant File Review IFB
Solicitation number
23-551HDA-ASSET-B-36140
Issued by
Illinois

About this file

This document is a government file related to a Tenant File Review Invitation for Bid (IFB) issued by the Illinois Housing Development Authority (IHDA). IHDA is seeking a vendor to perform tenant file reviews for occupied units in affordable multifamily rental housing developments in IHDA's portfolio. The IFB requires electronic submission only, with no paper responses accepted. The scope of work involves reviewing tenant files for compliance with program requirements such as household information, income and asset verifications, leases, inspections, and certification activities. The IFB does not specify a quantity of units or developments to be reviewed, but states the sample size will be based on a Federal Register Unit Table. The IFB does not provide a response deadline or award date.

The IFB provides detailed requirements for the tenant file review process, including maintenance and security of resident files, review of eligibility criteria, and procedures for rejecting applicants. Pricing terms and funding sources are not included. The IFB indicates this is an ongoing contract to monitor IHDA's affordable housing portfolio, but does not specify the contract term or any renewal options.

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File Type Posted
Tenant File Review IFB Final.docx DOCX document
Appendix 2.xlsx XLSX spreadsheet
Vendor Q and A~4.pdf PDF
ipg-active-registered-vendor-disclosure-formerly-forms-b-v.23.1.docx DOCX document
Pre-Bid Conference TEAMS Information~10.docx DOCX document
attachment-notice-of-electronic-submission-only-v-22-1~2.pdf PDF
Appendix 3.docx DOCX document
Utilization Plan Version 21.0 4.12.2021~5.pdf PDF
B36140 notice-of-award-form-v.23.1_2.pdf PDF
vendor-disclosure-formerly-forms-a-v.23.3.docx DOCX document
BEP ADDENDUM B-36140.xlsx XLSX spreadsheet
Appendix 4.xls XLS spreadsheet
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Summary

Illinois Housing Development AuthorityTenant File Review
111 E. Wacker Dr., Suite 1000Summary Sheet
Chicago, Illinois 60601
(312) 836-5200Tax Credit - Initial or Periodic Review - IAHTC only developments
Rev. 1/3/2023

Development Name & Address Owner Entity Since: (Mo/Yr)

Property / Site Manager's Name Since: (Mo/Yr)

Management Agent Organization Since: (Mo/Yr) No. of Units: Occupancy ERROR:#DIV/0!

Type of Program IHDA No. Loan Position(s) Total

Program

Purpose of Report:Initial ReviewTenant TypeVacant
Annual ReviewFamily
Review Date:ElderlyDate transferred
Mixedto AM:
SRO
SLF/AssistedSTC Exp. Date
Living
Special needsYear of
populationConstruction
A. Maintenance & SecurityACTCDD. File ReviewACTCD
1. General Physical Condition6. Resident File Maintenance and Security
I. Maintenance & Security Rating7. Household Information
SuperiorAbove AverageSatisfactoryBelow Average8. Verification
Unsatisfactory9. Leases
B. Leasing & OccupancyACTCD10. Inspections
2. Tenant Selection & Orientation11. Certification Activities
3. Vacancy, Turnover & Market Conditions12. Move-Out File Review
II. Leasing & Occupancy Rating13. Applicant Rejection Review
SuperiorAbove AverageSatisfactoryBelow AverageIV. File Review Rating
UnsatisfactorySuperiorAbove AverageSatisfactoryBelow Average
C. Training & Program ComplianceACTCDUnsatisfactory
4. Training
5. Program Compliance
III. Training & Program Compliance Rating
SuperiorAbove AverageSatisfactoryBelow Average
Unsatisfactory
V. Rating of Overall Management OperationSuperiorAbove AverageSatisfactory
Below AverageUnsatisfactory
Signatures:
Review prepared by:Review approved by:

Name / Title Date Title Date

Asset ManagerSupervisor - Rental Compliance
Item
No.

Development's Description

Non-IHDA HUD Subsidies

Unit Composition

Additional Addresses

Number and Type of Bldg.

Comments to Findings/Review Questions:

Item
No.
d. Does the development maintain a waiting list of prospective tenants? Is the
list updated annually as required? How many are now on list?

Questionnaire

Management Review
Questionnaire(Tax Credit - Initial or Periodic Review - IAHTC only developments)

Part A: Maintenance & Security

N/AYESNOFNDGSRemarks
1. General Physical Condition
a. Which type of physical inspection was completed?
UPCSPass or Fail?
When completed
HQSPass or Fail?
When completed
LTOSPass or Fail?
When completed
Rural DevelopmentPass or Fail?
When completed
REACREAC Score
When completed

1. General Physical Condition A C

I. Maintenance & Security Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part B: Leasing & Occupancy

N/AYESNOFNDGSRemarks
2. Tenant Selection & Orientation
a. Does the development have an executed TSP?
Date TSP was signed by owner/agent:
1.) Staff familiarity
2.) Preferences including State mandated
3.) Rent schedule attached
b. Is a copy of current approved (within the past 5 years) Affirmative Fair Housing Marketing
Plan (AFHMP) at rental office?Date of last approved AMP:

c. Is rental staff familiar with AFHMP?

d. Does site signage include the EHO logo?

e. Is the EHO poster displayed in offices and model units?

f. If there has been advertising,
1.) was the EHO logo included?
2.) was it the appropriate size?
g. Were the outreach efforts, as described in the AFHMP, performed annually?

Last outreach date:

h. Does advertising and/or outreach program comply with AFHMP?
Estimate racial mix of current tenants:

White %

Black/African American %

American Indian/Alaska Native %

Asian %

Native Hawaiian/Pacific Islander %

Other %

Estimate ethnic mix of current tenants:
Hispanic or Latino%

Not Hispanic or Latino %

i. Does the racial and ethnic mix breakdown reflect the target groups listed in the
current AFHMP?
j. What marketing efforts have been successful in attracting the target
populations (those "least likely to apply")?
k. How often is an evaluation made to measure the effectiveness of marketing
strategies to attract the "least likely to apply"?
l. If development is not reaching target marketing goals, what additional steps
have been taken?

m. What staff positions are/will be responsible for affirmative marketing?

n. Has the development's owner/agent/manager received complaints of
prohibited discrimination?

o. In accordance with the Fair Housing Act:

1.) Have policies & practices been modified so as not to discriminate
against persons with handicaps?
2.) Is there a transfer policy along with a lease addendum for residents
(not requiring an accessible unit) who reside in accessible units?
N/AYESNOFNDGSRemarks
Cont'd (2. Tenant Selection & Orientation)
p. How many units are accessible?
0BR1BR2BR
3BR4BR
Number of accessible units occupied by tenants with disabilities who require
the features of the unit?
How many units are adaptable?
0BR1BR2BR
3BR4BR

2. Tenant Selection & Orientation A C

3. Vacancy, Turnover & Market Conditions

a. Does the development maintain a wait list of prospective tenants?

Was annual update letter sent to applicants as required?

Date update letter was sent to applicant

Was wait list purged? When?

How many are currently on wait list?

Is the wait list currently open closed

Does the wait list include all required elements?

Were the applicants selected in proper order from the waiting list?

b. Is surrounding neighborhood market prosperous, average, or depressed?

c. Are surrounding neighborhood conditions improving, stable, or declining?

d. Are the market conditions affecting occupancy?

e. Is there saturation of affordable housing?

3. Vacancy, Turnover & Market Conditions A C

II. Leasing & Occupancy Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part C: Training & Program Compliance

N/AYESNOFNDGSRemarks
4. Training
a. Does owner/agent have an ongoing training program for its staff?
Check types of training used.

On-site (Frequency )

IREM NCHM HUD seminars Local colleges

Fair Housing training date

Energy conservation

Other (specify)

b. Does owner/agent have system to keep on-site staff informed of changes
in either HUD/IHDA policies or development operating procedures?

How are updates communicated?

4. Training A C

5. Program Compliance

a. Was the Consolidated Certificate of Compliance received?

When:

b. Have the quarterly Occupancy/Wait List reports been submitted for the current
period?

c. Were the current and prior two utility allowance analyses submitted?

d. Was the IAHTC monitoring fee paid for the compliance year under review?

5. Program Compliance A C

III. Training & Program Compliance Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part D: File Review

Summary of Tenant File Review

Number of program units Number of files reviewed

Name Unit Name Unit Name Unit

N/AYESNOFNDGSRemarks
6. Resident File Maintenance and Security
a. Are the files locked and secured in a confidential manner with access limited
to authorized staff only?
b. Is the owner/agent maintaining tenant files according to IHDA's
documentation retention requirements?
Is the owner/agent properly disposing of tenant records (shred, burn,
pulverize etc.)?

c. Is there a file organization system?

Is it followed consistently?

6. Resident File Maintenance and Security A C

7. Household Information

a. Do the files contain all documentation, including application information, as
required by Program Handbook?

b. Does the application contain sufficient information to determine eligibility?

c. Was all move-in screening completed per the Tenant Selection Plan?

d. Does the file contain the ethnicity and racial data certifications required?

e. Were the unit sizes appropriate for the household composition at the time
of the file review and were household member(s) identified correctly?

If a household was ineligible at move in, were exceptions granted?

7. Household Information A C

8. Verification

a. Have all eligibility criteria been verified and properly documented?

8. Verification A C

9. Leases

a. Were the correct program leases used?

b. Were the leases signed and dated by all parties?

c. Were all applicable addendums/attachments added to the lease?

d. Were security deposits collected in the correct amount for the program type?

e. Were pet deposits charged according to the pet policy?

9. Leases A C

10. Inspections

a. Is the move-in inspection documented in the file and signed/dated by both tenant
and owner/agent?

10. Inspections A C

11. Certification Activities

a. Were certification notices and processes performed in accordance with the
Program Handbook?

b. Was the Tenant Income Certification form (TIC) in the tenant file?

c. Were income and assets calculated correctly?

Cont'd (11. Certification Activities)
d. Were the correct rent and income limits used?
e. If tenants are paying their own utilities, do the current certifications reflect the
correct utility allowance?

11. Certification/Recertification Activities A C

12. Move-Out File Review

a. Did the move-out files include the required documentation?

12. Move-Out File Review A C

13. Applicant Rejection Review

a. Did the applicant rejection letter include the required criteria?

b. If appealed, were criteria met?

13. Applicant Rejection Review A C

IV. File Review Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Instructions

Summary
For each item reviewed, mark a block in column A (acceptable), or C (management to correct within 30 days).
After discussing items with owner or management agent, enter the estimated completion date in the TCD (Target Completion Date) column.

Development name & address: include addresses for all buildings. Use summary page under Development Description if necessary for additional addresses.

If this is a scattered site, for example, use one address on the first page and list the remaining addresses in Development Description.

Owner entity: review management agreement, regulatory agreement, or audit. Use legal entity name.

Type of program: list all program types in senior loan position - i.e. HOME, Section 8 and/or Tax Credits. IHDA programs only - do not use abbreviations. Do not include LTOS, SRN or 811 here, as Rental Compliance does not monitor these programs. They are captured under Additional IHDA Program Units in the Development Description.

IHDA number: list all loan numbers by lien position (i.e. 17-2037-01), and IHDA TC number (federal & state). Use the Benedict numbering system, not the portfolio system.

Number of Program units: list for the highest IHDA position only

Transferred to AM: omit MLs. Obtain from DMS, Project Dates.

Year of construction: insert year built. Refer to project summary. If construction year is not indicated, ask owner/agent.

STC Expiration Date: the calendar year end, 10 years from the date of the last donation on the state certificate. If there is no certificate, use the date of the regulatory agreement

Signatures
Review Prepared By: insert the digital signature of the AM who completed the review.

Name / Title: type the name of the AM who completed the review; adjust title for Senior AMs.

Review Approved By: the approving Rental Compliance Supervisor will insert their digital signature into the PDF version of the final report.

Name / Title: type the name of the Rental Compliance Supervisor.

Development Description
Non-IHDA/HUD subsidies: identify program type, number of units and monitoring agency.
Unit composition: indicate each unit size at the development and the number of each type of unit.
Please be thoughtful regarding the number format used, to avoid confusion. Examples of acceptable format are:
three 1-bedroom units
3 one-bedroom units
three 1BR units
Number and type of building: the type should be descriptive of the building style, i.e. high rise, townhouse, walk up, single-family home.
"Elevator building" does not give an indication of whether the building is low-, mid-, or high rise, for example.
Comments to Findings/Management Review Questions:
For each 'C' item checked, describe findings and give recommendation for correction. The corrective action should specify how the agent needs to correct the finding and what documentation or certification must be submitted to IHDA in order to resolve the finding. Explain any "Below Average" or "Unsatisfactory" rating.
For tenant file review findings:
1. Review your tenant files to create a summary of common findings, i.e. findings that occur in 50% or more of the files reviewed. Example: Most of the files reviewed did not have a move-in inspection signed by all parties.

2. Create a “general finding” definition for each common finding throughout your file audit. List them all general findings first. The definitions are to be separate and used for a reference for the O/A on your MOR report. Example: General Finding A: 5 out of 10 files were missing income verifications; General Finding B: most files were using incorrect rent/income limits.

3. For each file reviewed, document the MOR/File Audit summary pg. 2, in this manner. In the finding section:
Tenant first and last name
Unit #, Move-in date, Effective date of certification reviewed (if different from move-in vert)
List general findings. Example: General Findings A, B,C
Detail each non-general finding.
Detail how the finding is to be cured.
4. In cases where there were no findings in a file, identify the file in the same manner and indicate "No findings."
Format Example:
General Finding: A
In the majority of the files reviewed, the landlord verification was not completed. Management must either complete all screening as indicated in the TSP, or revise the TSP to reflect actual practices in place. Certify that a landlord verification will be completed for all applicants OR submit a copy of the revised TSP.
1. Josephine Smith, Unit #108, Move-In 1/8/18
General Findings: A, C

Finding a: The file does not contain the credit check, criminal background check, or sex offender screening for adult household member Dante, as required by the Tenant Selection Plan. Management must either complete all screening as indicated in the TSP, or revise the TSP to reflect actual practices in place. In response, certify that a credit check, criminal background, and sex offender screening will be obtain for all future adult applicants and retained in the tenant file.

2. John Jenkins, Unit #515, Move-In 5/17/18, Annual Recertification 5/1/19
No findings.
PART A: MAINTENANCE & SECURITY
1. General Physical Condition
a. All properties are required to have a physical inspection based on the program type. If there has been no inspection in the past three years, contact your field inspector. The appropriate inspection type should be selected based on the applicable program:
UPCS - All programs EXCEPT Section 8 & 236, Risk Share, FAF & LTOS. Every three years.
HQS - Mod Rehab, FAF
LTOS - Rental Housing Support
Rural Development - accepted in lieu of UPCS for RD properties with IHDA tax credits
REAC - Section 8 & 236, Risk Share. Accepted in lieu of UPCS for S8/236 properties with IHDA tax credits. Periodic based on prior score (90-100: three years; 80-89: two years; 79 and below: one year).

Check for pass/fail for the most recent physical inspection. Inspection date, type, and results can be reviewed in DMS under Monitoring > Project Monitoring > Program Inspection. Copies of the inspections, if needed, can be found in T:\Asset\Portfolio\Applicable Year\Inspection. If there has not been an inspection for the current year, review prior years and enter the most recent inspection date. If development failed their inspection verify current status with field inspector.

1. Make a comment if, at the time of the MOR, the physical inspection letter has been issued but the response is not due yet.
2. Make a finding if, at the time of the MOR, the physical inspection letter has been issued, the response is due, but the property has not responded or resolved the findings.

PART B: LEASING & OCCUPANCY

2. Tenant Selection & Orientation
a. Compare the owner's signature date on the TSP reviewed on-site with the TSP Approved Date indicated in DMS. If the TSP reviewed on-site has a more current date, Asset Manager must update DMS upon return to the office.

If the property is using the IHDA TSP, the initial plan must be signed by IHDA, the owner, and agent. Subsequent plans must be signed by the owner and agent.

If the property is using a TSP reviewed by HUD, the HUD approval memo/letter must be attached. The TSP must be signed by the owner and agent.

If the property is not using the IDHA TSP, the IHDA approval memo must be attached. The TSP must be signed by the owner and agent. You may see this with new deals that are Housing Authorities, RAD deals, 811 deals, etc.

b. List date AMP was approved. If plan is expired and no new plan has been submitted to IHDA or HUD, this is a finding. If the AMP was submitted to HUD and it has not been approved, it is a finding if the plan is expired.

c. Answer question.

d. Only the fair housing logo is required.

e-f. Answer questions.
g. Must be a finding if no outreach has been conducted within the 12 month period prior to closing the waiting list. Waiting list must be closed based on TSP requirements.

If the waiting list is managed by another agency, such as a housing authority, and 100% of applicants must come from that waiting list, mark N/A and make a comment in the remarks column indicating why outreach was not completed.

If less than 100% of units must be referred from another agency (such as SRN units), the agent must maintain a list & perform outreach for those units that do not require referral.

h. A development that provides affordable housing should keep track of race and ethnicity in their development. Tax Credit deals have to do the tracking to comply with HUD. Racial mix must equal 100%. Ethnic mix must equal 100%.

i. Detail the least likely to apply groups from the current approved AMP in the remarks section.

j. Add in remarks the successful outreach efforts such as local exhibits or other additional outreach efforts.

k. Answer question.
l. If no additional steps have been taken a recommendation is required.
m. Indicate staff person/position in the remarks.
n. Prohibited discrimination means based on race, age, sex, handicap, familial status. If yes, please make a note here and describe in Attachment A.

o2. Review IHDA TSP Exhibit B. A transfer addendum is required for developments with accessible units. The addendum must be signed only by tenants who move in to accessible units but do not require the features. This requirement does not apply to developments with no accessible units or when all units are accessible.

p. Review Management Plan, or TSP. An Accessible Dwelling Unit is a unit that is approached, entered, and used by physically-challenged people.

Accessible features include: Wide doors, sufficient floor space for wheelchairs, lower countertops, lever and loop type handles hardware, seats at bathing fixtures, grab bars in bathroom, knee spaces under sinks and counters, etc. Most accessible features are permanently fixed in place.

An adaptable dwelling unit is one constructed and equipped so it can be converted with minimal structural change for the use by persons with different types and degrees of environmental limitation.

Adaptable features include: An Adaptable unit has features that are either adjustable or capable of being easily and immediately added or removed to "adapt" the unit to individual needs or preferences.

3. Vacancy, Turnover and Market Conditions
a. Review copy of annual update letter sent to applicants and verify wait list was purged after updating (Compare to previous wait list).
See IHDA TSP, Exhibit H for guidance.
Required waiting list elements are found in Handbook 7465.1 (for Mod Rehab) or Exhibit H of IHDA's Tenant Selection Plan.
Identify the last three move-ins. Analyze the current wait list and the purged wait list to ensure that the applicants were processed in the proper order (i.e. chronological or preference).

b./c. Determination of neighborhood market conditions should be made through both a visual assessment of the area by the asset manager, and a conversation with site staff. If conditions are other than stable/improving, explain how.

d. Market conditions that negatively affect the property should be indicated, i.e. job loss, college town, economic depression, location, etc.

e. If there is a saturation of affordable housing, explain how, i.e. two new senior developments are being constructed in the immediate area with more amenities, etc.

4. Training
a. Check types of training used.
Suggested trainings: tax credit, HOME, Fair Housing, etc.

For Fair Housing, all properties must attend Fair Housing training. This should include office and maintenance staff. Recommendation is every 2-3 years.

Based on observations and conversation with staff during the review, make a finding or comment as necessary if extra training is needed for HOME, tax credits, etc.

b. Indicate in remarks column how management stays up-to-date with changes in HUD & IHDA policy.

5. Program Compliance
a. Obtain date from DMS. Certificate should be saved in Portfolio/Year/Correspondence.
b. Review occupancy & wait list reports due for the most recent quarter. Reports can be found at
T:\Occupancy & Waitlist Survey\YearQ#\Master Workbook. Make a comment if not submitted.

c. Utility allowance analysis & submission to IHDA is required annually. UAs must be implemented by the development within 90 days of the effective date. Backup for the UAs used for the compliance period under review must have been submitted to IHDA. If analysis has not been submitted in the last 12 months, list as a finding.

d. In DMS, review Project --> Fees to determine if the fees have been paid. Unpaid fees for the compliance year under review and any delinquent years must be listed.

PART C: FILE REVIEW
A random file selection will be made using the randomizer. The files are limited to move-ins from the prior calendar year.

Sample size: refer to the Federal Register Unit Table. Use the lesser of 20% or the table.

If there are less new move-ins than the sample requires, review all move-in files. If there are more new move-ins than the table requires, process the random selection.

The selection should also include a move-out and rejection file.

6. Resident File Maintenance and Security
a. Ask how tenant files are secured. Files should be in a locked file cabinet or locked file room. They should not be left on desks or in common areas that unauthorized staff, such as maintenance staff, can access them.

b. Federal LIHTC regulations require that Owners retain records for each building in the project for at least 6 years after the due date (with extensions) for filing the federal income tax return for that year. The records for the first year of the credit period, however, must be retained for at least 6 years beyond the due date (with extensions) for filing the federal income tax return for the last year of the compliance period of the building. (From 8823 Guide, 2011 revision)

Ask how the owner is disposing of records. Are they being shredded, burned, etc.?

c. If there is not an apparent filing system, or files are inconsistently organized, make a comment regarding organization.
7. Household Information
a. For all required documents, refer to the "What should be in the tenant file?" for both move-in and recertification.

b. Applications must be date and time stamped upon receipt. Application should ask for household composition, age, student status, sources of income and assets, assets disposed of for less than fair market value.

c. Refer to the TSP (section V) to determine which screening management has indicated. Make a finding if the file does not contain documentation of the indicated screening.

d. Answer question.

e. Refer to the occupancy standards in the TSP.

Eligibility exceptions would include extenuating circumstances, such as initially failing the credit or background check, VAWA victims.
8. Verification
a. Income, assets, student status, age, Social Security number, all criteria indicated in the TSP (credit check, landlord verification), etc.
9. Leases
a. LIHTC program does not have a specific required lease.
b. Management and all adult household members must sign and date the lease on or before the effective date.
c. Tax credit developments must use a tax credit lease addendum. Properties may use the sample addendum found on IHDA's website.
Developments must ensure that the VAWA Addendum is attached to the Lease Agreement.

d. The security deposit requirements, if any, vary. Discuss with the property to determine their deposit policy. Review the policy & compare to actual practice in place.

If a third party has paid the deposit on behalf of the tenant, the deposit amount must still be listed on the lease.

e. Answer question.
10. Inspections
a. The inspection must be jointly conducted prior to occupancy.
11. Certification / Recertification Activities
a. Verify dates the TICs & leases were signed, that income & assets, student status, etc. were verified prior to the effective date. Refer to 4350.3 Appendix 3 for items to be verified and acceptable verification methods.

Include in Remarks section if rents exceed maximum rent level, missing or incorrect information on TIC form.

b. The move-in certification must be retained in the active tenant file.

c. Include in Remarks section if income or assets were not calculated correctly.

d-e. Remark and make a finding if any income / limits / UAs are incorrect.
12. Move-Out File Review
a. Documentation includes move-out notice (file should be documented if no notice was provided), move-out inspection, security deposit disposition letter (move-out statement), a copy of the refund check, if applicable.
13. Applicant Rejection Review
a. Rejection letter must state the reason for the rejection, and advise applicants that the rejection may be appealed within 14 days.
b. Any appeal must be heard by someone other than the person who made the rejection decision.

TSP Checklist - Other

Illinois Housing Development AuthorityDevelopment Name:
Asset ManagementIHDA Numbers:
Tenant Selection Plan (TSP) ChecklistDate of Review:
Other Programs (Non-Section 8)Reviewed by:
FOR INTERNAL USE ONLYReview TSP to ensure all topics are included and filled out accurately
IHDA Required TSP TopicsReferencesIs it included?Comments
4350.3 Rev 1; IHDA LIHTC Manual; IHDA TSP Exhibits & Addendums; Notices; MemorandumsYesNoN/AWhat is missing, not completed or incorrect (include page #)? What date was it corrected?
I. Introduction
A. Development Description
B. Tenant Type3-2
C. Unit Distribution3-2
D. Rent Structure: Is current Rent Schedule attached?3-2; TSP Exhibit A
E. Civil Rights and Non Discrimination Requirements4-4
1-4. General, Fair Housing, Title VI of the Civil Rights Act of 1964, Age Discrimination Act of 1975.April 4, 2016 HUD Application of Fair Housing to use of Criminal Records
5. Section 504 (applies to Federal Programs)Section 504 HUD FAQ
6. Equal Access to Housing in HUD Programs Regardless of Sexual Orientation and/or Gender Identity (applies to Federal Programs)HUD Notice 2015-01 for Federal Programs Equal Access to Housing
7. Executive Order 13166-Limited English Proficiency (applies to Federal Programs)Executive Order 13166
8. VAWA (applies to HOME and LIHTC)VAWA 2005, & VAWA Reauthorizations in 2013 and 2019
* Military Status: It is illegal in Chicago to discriminate against veterans, active duty military personnel, members of the reserve and members of the National Guard.2016 Chicago Military Status Discrimination
* Cook County Just Housing Amendment: Cannot consider criminal history more than 3 years old, cannot deny a housing application based on juvenile or adult arrest records & requires landlords perform an individualized assessment prior to denying housing application.1/1/2020 Just Housing Amendment Cook County
II. Preferences4-1; 4-6
A. Establishing Preferences4-4; 4-6
1. Existing Tenant Preferences (unit transfers)4-4,; Is TSP Exhibit B attached?
2. State Mandated Preferences (required on all IHDA properties)4-6
3. Optional Preferences4-6, 4-26 List:
a.ii. If property has SRN or Section 811, this preference must be selected.
d. If the LIHTC property applied with the IHDA 2020-2021 QAP, Veterans preference must be selected.IHDA 2020-2021 LIHTC QAP
e. If there are multiple income limits at property, Existing Tenant Transfers must be selected.
B. Verification of Preferences4-26; TSP Exhibit C
C. Selection of Families for Program Participation based upon Preference4-15
D. When a Preference is Denied4-9; TSP Exhibit D
E. Exceptions to the Preference Rule4-6
III. Pre-Application Card Processing4-3
A. Distribution of Pre-App or Pre-App CardsTSP Exhibits E, F & G
B. Processing Pre-Apps or Pre-App Cards4-14, 4-15
IV. Waiting List Procedures4-16
A. Creation of Waiting List4-16; TSP Exhibit H
B. Changes to Income or Household Composition4-18
C. Contacting Persons on the Waiting List4-24
D. Updating the Waiting List4-19, 4-20, 4-21, 4-22; TSP Exhibit I, J & K
E. Closing and Re-opening the Waiting List4-16
V. The (Interview) Screening Process4-7, 4-24
A. Application Requirements/Move In Screening4-7
B. Home Visits4-7, 4-27; TSP Exhibit L
C. Completion of Application Process
VI. Eligibility Requirements4-4
A. Income4-4
B. Date of Birth4-4
C. Social Security Number4-4; TSP Addendum 2
D. Student Eligibility Requirements-Federal Tax Credits - LIHTCIHDA LIHTC Manual; TST-6 Form, Certification of Student Eligibility
E. Student Eligibility Requirements-applies to HOME and is same rule as Section 8HUD Summary of 2013 HOME Final Rule 8/23/2013; IHDA Annual Student Certification HOME Program Form
VII. Occupancy Standards3-23; 4-4; 4-19
VIII. Security Deposits (If applicable)6-2
IX. Rejection Criteria4-1, 4-9
A. Insufficient/Inaccurate Information on Application4-9; TSP Exhibit M
B. Credit and Financial Standing4-27
C. Criminal Convictions/Current Drug Use4-7; 4-27
1.a. 2014 HUD Memorandum: Use of Marijuana in Multifamily Assisted Properties. Medical Marijuana is illegal per Federal Gvmt.2014 HUD Use of Marijuana in Multifamily Assisted Properties
* HUD Office of General Counsel Guidance on Application of Fair Housing Act Standards to the Use of Criminal Records by Providers of Housing.April 4, 2016 HUD Application of Fair Housing Standards to the Use of Criminal Records
* Cook County Just Housing Amendment: Cannot consider criminal history more than 3 years old, cannot deny a housing application based on juvenile or adult arrest records & requires landlords perform an individualized assessment prior to denying housing application.1/1/2020 Just Housing Amendment Cook County
D. Household Characteristics4-4
E. Unsanitary Housekeeping4-27
F. Exception to Rejection Criteria -extenuating circumstances4-28
1. Applicants with disabilities-mgt must consider reasonable accommodations4-29, 4-30
2. HUD Guidance on use of arrest recordsApril 4, 2016 HUD Application of Fair Housing Act Standards to the Use of Criminal Records
X. Rejection Procedures4-9
A. Written Notification4-9; Exhibit M
B. Review of Rejected Applications (Right to appeal process)4-9
XI. Special Occupancy Categories (give priority to applicant with disabilities for an accessible unit)2-3; 4-4
XII. Amending the Tenant Selection Plan4-4
XII. Certification/SignaturesPer IHDA Legal Agreements
A. Initial-is it signed by owner and agent?What is the date signed?
B. Post-Initial Updates: is it signed by owner and agent?What is the date signed? Input date signed as TSP Approved date in DMS.
C. Are Exhibits attached?
D. Is TSP available for applicants & tenants to review upon request? (for on-site review)4-4
Revised 4/16/2021

https://www.hud.gov/sites/documents/15-01HSGN.PDFhttps://www.cookcountyil.gov/content/just-housing-amendment-human-rights-ordinancehttps://www.cookcountyil.gov/content/just-housing-amendment-human-rights-ordinancehttps://www.hud.gov/sites/documents/HUD_OGCGUIDAPPFHASTANDCR.PDFhttps://www.justice.gov/crt/executive-order-13166https://www.hud.gov/program_offices/fair_housing_equal_opp/disabilities/sect504faqhttps://www.hudexchange.info/programs/home/home-final-rule/section-by-section-summary/subpart-a/https://www.hud.gov/sites/documents/HUD_OGCGUIDAPPFHASTANDCR.PDFhttps://www.hud.gov/sites/documents/HUD_OGCGUIDAPPFHASTANDCR.PDFhttps://df7qosnywqs6g.cloudfront.net/wp-content/uploads/2019/10/2020-2021-QAP-Final.pdfhttps://www.hud.gov/sites/documents/USEOFMARIJINMFASSISTPROPTY.PDFhttps://www.chicago.gov/content/dam/city/depts/cchr/AdjSupportingInfo/AdjFORMS/2016%20Adjudication%20Forms/2016MilitaryStatusDiscriminationFactSheet.pdf image1.emf image2.png

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