Two different cases in two parts of the country provide a good reminder for all of us in the professional apartment ownership and management arena. I am dealing with a HUD fair housing investigation at a conventional property in the south and a HUD compliance review at an affordable community in the northeast.
What links the inquiries is that management is being probed to prove what we did and how we documented our actions. While interviews from current and former employees are very helpful, HUD always wants to review resident files and they always look for notes detailing interaction between management and residents.
Even if your interaction with residents is benign, please make sure to note it in a log or in a resident’s file. Particularly if you issue a notice or even a warning letter, ensure it is dated and included in the file. While certain issues may not look at the outset like they will rise to the level of a housing discrimination complaint or HUD compliance review (and to be sure, most certainly do not) — if and when such an issue arises, management will be best served by detailed records and notes so we can demonstrate what was done and why it was done.
To illustrate, in one of my cases we are being asked why there was only one warning letter in a file before a non-renewal notice was issued. Notwithstanding that there was a series of incidents between the leasing office staff and the resident. For whatever reason, the file did not indicate to HUD’s complete satisfaction the level of distress caused by the resident. I think the case could have been closed with more detail in the file. For now, it continues on until I develop additional evidence to demonstrate why the notice of non-renewal was appropriate.
Just a thought.