C. Determining an Applicant’s Preliminary Eligibility

1. Owners should make a preliminary eligibility determination before putting a household on the waiting list.

   • a. The owner reviews the application to ensure that there are no obvious factors that would make the applicant ineligible.

   • b. If a preliminary screening indicates that a family is eligible for tenancy, but units of appropriate size are not vacant, the owner must place the family on the waiting list for the property and notify the family when a suitable unit becomes available. A final eligibility determination is made at the time the unit is available. (See discussion of unit size determinations in paragraph 3-23.)

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• c. Using this system, the owner avoids performing the eligibility determination twice before admitting the applicant to the property, but the result may be that applicants placed on the waiting list may ultimately be found to be ineligible.

2. If the preliminary screening indicates that a family is eligible for tenancy but SSNs have not been disclosed and verification of the SSN provided for the applicant and all of the applicant’s household members, the owner must place the family on the waiting list and notify the family when a suitable unit becomes available. However, the applicant must disclose and provide verification of a SSN for all household members before they can be admitted. See Chapter 3, Paragraph 3-9 for more information on disclosing and verifying SSNs.

3. Alternatively, owners may choose to place applicants on the waiting list after making a more in-depth eligibility determination. If a property’s waiting list is short, this approach can be a good practice to help place applicants quickly when they reach the top of the waiting list. However, if an applicant remains on the waiting list for an extended period of time, the owner will need to complete another full determination once the applicant reaches the top of the list.

4. If an applicant is otherwise eligible for tenancy but no appropriate size unit exists in the property, the owner must reject the application. (See paragraph 4-9 for more information about rejecting applicants.)

5. Applicants who are obviously not eligible for tenancy must be rejected. (See paragraph 4-9.)

• D. Creating Waiting Lists

To ensure that applicants are appropriately and fairly selected for the next available unit, it is essential for owners to maintain waiting lists with appropriate information taken from the application for tenancy.

1. Plan of list maintenance. In order to ensure that all applicants are treated fairly, the tenant selection plan must describe how the waiting list is maintained.

2. Updates of waiting list. Keeping the waiting list as up-to-date as possible will help reduce errors and minimize the administrative resources expended on processing information regarding applicants who are ineligible or no longer interested in residing in the property.

   • a. Owners may periodically update their waiting lists.

• b. Owners may require applicants to contact the property every six months in order to stay on the waiting lists.

3. Data included on the waiting list. The waiting list must include the following data taken from the application:

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• a. Date and time the applicant submitted an application;

• b. Name of head of household;

• c. Annual income level (used to estimate levels for income-targeting, i.e., extremely low-income, very low-income, and low-income) (See discussion of income limits in paragraph 3-6);

• d. Identification of the need for an accessible unit, including the need for accessible features;

• e. Preference status; and

• f. Unit size.

NOTE: See Figure 4-5 for a sample waiting list format.

4. Excluding data from the waiting list. While additional information, such as race/ethnicity, gender, and family size is collected on pre-applications and applications and retained in property files, it is good practice to avoid including these types of data on the property waiting list. This information

is not directly relevant to tenant selection and might result in discrimination against some applicants.

5. Applicant presence on multiple waiting lists. An applicant may be on multiple waiting lists (or waiting for more than one unit size). Based upon the application dates and times and qualification for preferences (if used), placement on these multiple lists may vary.

Figure 4-5: Sample Waiting List Format

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