4-22 Record-Keeping

• A. The owner must retain current applications as long as their status on the waiting list is active.

• B. Once the applicant is taken off the waiting list, the owner must retain the application, form HUD-92006 completed by the applicant, initial rejection notice, applicant reply, copy of the owner’s final response, and all documentation supporting the reason for removal from the list for three years.

• C. When an applicant moves in and begins to receive assistance, the application and form HUD-92006 completed by the applicant must be maintained in the tenant file for the duration of the tenancy and for three years after the tenant leaves the property.

HUD Occupancy Handbook Chapter 4: Waiting List and Tenant Selection

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Section 4: Selecting Tenants from the Waiting List

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• D. All files must be kept secure so that personal information remains confidential.

• E. The applicant’s or tenant’s file should be available for review by the applicant or tenant upon request or by a third party who provides signed authorization for access from the applicant or tenant. EIV income data found in the tenant’s file has additional disclosure requirements (see paragraph 9-18).

• F. The owner must dispose of applicant and tenant files and records in a manner that will prevent any unauthorized access to personal information, e.g., burn, pulverize, shred, etc.

• G. Owners must keep records and submit reports and information as required by HUD to enable HUD and the owner to ascertain whether the owner has complied, or is complying with, nondiscrimination requirements. (See Chapter 2.)