A LEGAL COMPLIANCE GUIDE FOR THE LOW-INCOME HOUSING TAX CREDIT COMMUNITY A pr i l 2 013 inside this issue Q&A: Documenting Efforts to Rent Vacant Units. . . . . . . . . . . . . . . . . . . . . . 5 Dos & Don’ts. . . . . . . . . . . . . . . . . . . . . . 5 ➤ Don’t Perform Full Recertifications When They’re Not Necessary ➤ Focus on Resident Retention to Save Money, Paperwork Model Form: Use Maintenance Checklist for Quick Turnaround. . . . . . 7 HUD Issues Final Rule on Disparate Impact HUD recently issued a final rule to formalize the national standard for determining whether a housing practice violates federal fair housing law as the result of discriminatory effect. As the federal agency charged with enforcing the Fair Housing Act (FHA), HUD says it has long interpreted the law to prohibit housing practices with an unjustified discriminatory effect, if those acts actually or predictably result in a disparate impact on a group of persons, or create, increase, reinforce, or perpetuate segregated housing patterns because of race, color, religion, sex, handicap, familial status, or national origin. “Through the issuance of this Rule, HUD is reaffirming its commitment to enforcing the Fair Housing Act in a consistent and uniform manner,” HUD Secretary Shaun Donovan said in a statement. “This will ensure the continued strength of one of the most important tools for exposing and ending housing discrimination.” The agency said that the rule provides (continued on p. 8) fe ature How to Prevent Fair Housing Claims from Individuals with Nonobvious Disabilities While the IRS is generally responsible for the low-income housing tax credit program, in 2000 it entered into a Memorandum of Understanding with the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) to enforce fair housing laws. HUD is generally charged with enforcing the Fair Housing Act (FHA), and may refer cases to the DOJ. The FHA prohibits discrimination in housing and housing-related transactions, including the sale, rental, and financing of dwellings, based on race, color, religion, sex, national origin, familial status, and disability. Along with avoiding potential penalties imposed by the DOJ, site owners and managers have a further incentive to be mindful of fair housing laws: Their site’s tax credits may be jeopardized if fair housing laws are violated. Section 1.42-9 of the Income Tax Regulations says that the failure of a low-income housing tax credit site to comply with the requirements of the FHA results in the denial of credits (continued on p. 2) Maintenance How to Minimize Turnaround Times for Vacant Units With the beginning of spring, now is the optimal time to think about lease-ups and how you may turn over recently vacated units faster. That’s because spring and summer are the times when most sites experience their busiest leasing months. When a resident moves out, you shouldn’t let the process of turning around his empty unit drag on. The faster you turn the unit around, the sooner it will be presentable to new prospects and positive cash flow for the site can be restored. You can save time and money by scheduling turnaround duties that make the most efficient use of your maintenance staff. Here’s how one property management company, which makes orderly unit turnarounds a management priority, readies a unit in three days without overlooking a single item. (continued on p. 6) 2 T A X C R E D I T H O U S I N G M A N A G E M E N T I N S I D E R B O A R D O F A D V IS O R S George Caruso, shcm, nahp - e Edgewood Management Member, NAHMA Board of Directors Germantown, MD Douglas D. Chasick, cpm ® , caps , cas , adv. ram , clp, sle , cdei The Apartment Doctor Melbourne Beach, FL Charles J. Durnin Jr. Interstate Realty Management Co. Marlton, NJ Karen Graham, cpm, hccp Karen A. Graham Consulting, LLC Cincinnati, OH Margaret McFarland, Esq. University of Maryland College Pk., MD Elizabeth Moreland, ncp -e Elizabeth Moreland Consulting, Inc. Orange City, FL Denise B. Muha National Leased Housing Association Washington, DC Ruth Theobold Probst TheoPro Compliance Pewaukee, WI Greg Proctor, shcm, nahp - e Windsor Consulting Lexington, KY Steven L. Rosenblatt Sharon Harper Ivey, Spectrum Seminars, Inc. hccp, ncp - e , scs , fhc Concord Management, LTD Cape Elizabeth, ME Maitland, FL Johrita Solari, shcm, nahp - e , hccp A.J. Johnson, hccp Solari Enterprises, Inc. A.J. Johnson Consulting Orange, CA Services, Inc. Williamsburg, VA Gwen Volk, cpm, shcm, nahp - e , hccp Michael Kotin, hccp LBK Management Kay-Kay Realty Corp. Services Scottsdale, AZ Irving, TX Steven M. McDonald, cpm Westlake Realty Group, Inc. San Mateo, CA Editor: Eric Yoo Executive Editor: Heather Ogilvie Production Director: Kathryn Homenick Director of Operations: Michael Koplin April 2013 Fair Housing Claims (continued from p. 1) on a per-unit basis. Thus, an adverse final decision by the Secretary of HUD, a state or local fair housing agency, or a federal court could result in the disallowance of credits, recapture of credits, and preclusion of future credits on the affected units. And if the reduction in the number of the low-income units in the building(s) brings the project below the minimum set-aside requirement, all the site’s credits could be disallowed. In this article, we’ll explore the fair housing rules as they pertain to individuals whose disabilities may not be obvious or apparent. We’ll give you six rules to follow to help you avoid claims from these individuals. Because of the way that fair housing law defines “disability,” it’s sometimes difficult to know whether disability-related rules apply to a particular prospect or resident. For example, when the nature of an individual’s disability isn’t apparent, your staff may fail to recognize that a prospect’s request for an exception to your rules must be evaluated as a request for a reasonable accommodation. Or, if a leasing agent doesn’t realize a prospect or resident is considered disabled under fair housing law, you could be accused of discrimination if he doesn’t take the request seriously. Defining ‘Disability’ The FHA defines “disability” as a physical or mental impairment that substantially limits one or more major life activities. The definition involves three key phrases: Physical or mental impairment. HUD regulations broadly define physical or mental impairment to include any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more specified body systems, including neurological; musculoskeletal; special sense organs; respiratory, including speech organs; Tax Credit Housing Management Insider [ISSN 15272311 (print), 1938-307X (online)] is published by Vendome Group, LLC, 6 East 32nd Street, New York, NY 10016. Volume 14, Issue 14 Subscriptions/Customer Service: To subscribe or for assistance with your subscription, call 1-800-519-3692 or go to our Web site, www.vendomerealestatemedia.com. Subscription rate: $470 for 12 issues. To Contact the Editor: Email: [email protected] Call: Eric Yoo at (212) 812-8435. Fax: (212) 228-1308. To Place an Advertisement: Please email Erin Tyler, etyler @vendomegrp.com, or call (216) 373-1217. Disclaimer: This publication provides general coverage of its subject area. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional advice or services. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The publisher shall not be responsible for any damages resulting from any error, inaccuracy, or omission contained in this publication. © 2013 by Vendome Group, LLC. All rights reserved. No part of Tax Credit Housing Management Insider may be reproduced, distributed, transmitted, displayed, published, or broadcast in any form or in any media without prior written permission of the publisher. To request permission to reuse this content in any form, including distribution in educational, professional, or promotional contexts, or to reproduce material in new works, please contact the Copyright Clearance Center at [email protected] copyright.com or (978) 750-8400. For custom reprints, eprints, or logo licensing, please contact Donna Paglia at (216) 373-1210 or [email protected] C L A R I F I CATI O N In the March 2013 issue, errors needing clarification appeared in the article “How to Notify Households of Upcoming Rent Increases.” Special thanks to tax credit expert A.J. Johnson for providing the following clarifications: 1. Utility allowances may be derived from federal housing agencies, local public housing authorities, utility companies, state housing finance agencies, use of the HUD Model Utility Allowance, or professional engineers; 2. Raising the rent on an over-income unit may be possible, but management should ensure compliance with the Available Unit Rule and be careful to maintain the building’s required applicable fraction; and 3. Since 2008, as a result of HERA, income limits cannot drop below the current year and, therefore, neither can rents. In other words, decreases in HUD-published income limits won’t result in a decrease in income limits or rents for LIHTC projects, since tax credit sites are now held harmless from such decreases. The revised article incorporating these clarifications can be found online at www. taxcredithousing.com/article/how-notify-households-upcoming-rent-increases © 2013 by Vendome Group, LLC. Any reproduction is strictly prohibited. April 2013 T A X C R E D I T H O U S I N G M A N A G E M E N T I N S I D E R cardiovascular; reproductive; digestive; genito-urinary; hemic and lymphatic; skin; and endocrine. It also includes any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities. According to HUD regulations, examples of physical or mental impairments include, but are not limited to: orthopedic, visual, speech, and hearing impairments; cerebral palsy; autism; epilepsy; muscular dystrophy; multiple sclerosis; cancer; heart disease; diabetes; human immunodeficiency virus (HIV) infection; mental retardation; emotional illness; drug addiction (other than addiction caused by current, illegal use of a controlled substance); and alcoholism. Substantially limits. HUD says that substantially limits means a limitation is “significant” or “to a large degree.” Major life activity. According to HUD, major life activity means an activity that is of central importance to daily life, including, but not limited to: seeing, hearing, walking, breathing, performing manual tasks, caring for oneself, and speaking. HUD also notes that reproduction is a major life activity for certain individuals. If an individual has a physical or mental impairment that substantially limits a major life activity, she is protected under the FHA’s disability-related provisions—even if the disability is not obvious or apparent. FOLLOW SIX RULES To avoid claims from individuals with nonobvious disabilities, follow these six rules. Rule #1: Don’t Make Assumptions Based on Appearances Don’t rely on appearances to determine whether a prospect or resident is—or is not—entitled to protection under the FHA’s disability provisions. Given the broad definition of disability under the FHA, appearances can be deceiving. HUD’s list of impairments includes many physical and emotional conditions characterized by few, if any, obvious symptoms to suggest that a particular prospect qualifies under the FHA’s disability-related provisions. You could get in trouble, for example, if you questioned the credibility of any prospect who says he’s disabled but shows no outward sign of an impairment. 3 Or you may recognize that a prospect has an impairment, but don’t know whether it’s severe enough to substantially limit a major life activity. You could trigger a complaint if, for example, you ignore a request for a reasonable accommodation from a prospect who shows no apparent difficulty walking but asks for an assigned parking spot due to a mobility impairment. If he has an impairment that substantially limits a major life activity—even if his condition is intermittent or characterized by some good days and some bad days—he could qualify as an individual with a disability under fair housing law. Rule #2: Curb Curiosity About Disability Another way to get into fair housing trouble is to ask the wrong questions. Under the FHA, it’s unlawful to ask applicants about whether they or a family member have a disability or about the nature and severity of such a disability. However, you may ask some questions—as long as you ask all applicants, regardless of whether they have a disability—to determine whether an applicant: ■ Has the ability to meet the requirements of tenancy; ■ Is a current illegal abuser or addict of a controlled substance; or ■ Has been convicted of the illegal manufacture or distribution of a controlled substance. Although you may ask applicants about current drug use, you may not screen out applicants with a past history of drug addiction, who are protected under the FHA’s disability-related provisions. For example, you may not reject an applicant simply because she lists a drug treatment facility as her current address. Rule #3: Listen for Accommodation Requests Keep your ears tuned for accommodation requests, particularly when the applicant doesn’t appear to be disabled. Anytime anyone asks you to make an exception to any of your policies or procedures, it should prompt you to think about fair housing rules governing reasonable accommodations for an individual with disabilities, advises fair housing attorney Robin Hein. The FHA doesn’t require an applicant or resident to mention fair housing law or to use the (continued on p. 4) © 2013 by Vendome Group, LLC. Any reproduction is strictly prohibited. For more information call 1-800-519-3692 or visit www.vendomerealestatemedia.com. 4 T A X C R E D I T H O U S I N G M A N A G E M E N T I N S I D E R Fair Housing Claims (continued from p. 3) words “reasonable accommodation.” According to HUD, an applicant is making a request for a reasonable accommodation whenever she makes clear that she’s requesting an exception, change, or adjustment to a rule, policy, practice, or service because of a disability. Furthermore, the FHA doesn’t require the request to come from the disabled person herself—HUD says that a site has notice that a request for a reasonable accommodation has been made if a person, her family member, or someone acting on her behalf makes the request. Once someone asks for an exception to your rules, follow your site’s policies and procedures regarding reasonable accommodations for individuals with disabilities. Hein says that you may ask the applicant to fill out a standard form for accommodation requests, although you may not ignore a request if the applicant refuses to use your form. Hein suggests explaining that the form will help you understand and communicate the request to the person evaluating it. HUD recommends that accommodation requests be put in writing to prevent misunderstandings about what’s being requested or whether the request is made. Rule #4: Ask for Information When Disability Isn’t Obvious When you get an accommodation request from an individual whose disability isn’t obvious, HUD guidelines state that you may ask for reliable disabilityrelated information to verify that the person meets the FHA’s definition of having a disability—that is, he has a physical or mental impairment that substantially limits one or more major life activities. But you may not demand a doctor’s note to verify the disability. HUD guidelines say that, depending on the circumstances, the information usually can be provided by the individual himself—either proof that he receives certain forms of Social Security disability benefits or a “credible statement by the individual.” Or verification can come from a medical professional, a peer support group, a nonmedical service agency, or a “reliable third party who is in a position to know about the individual’s disability.” According to HUD, the individual’s medical records or detailed information about the nature of the disability is not necessary in most cases. April 2013 Rule #5: Determine Disability-Related Need for Accommodation Once you’re satisfied that the individual has a disability as defined under the FHA, then you must evaluate whether there’s a disability-related need for the accommodation. There must be an identifiable relationship between the requested accommodation and the individual’s disability, according to HUD. If in doubt about the connection between an individual’s disability and the need for a requested accommodation, it’s best to consult with your attorney on how to respond. Under HUD guidelines, you may ask for more information if necessary to evaluate if the reasonable accommodation is needed because of a disability. Nevertheless, legal guidance may be necessary to respond properly. Rule #6: Evaluate Alternatives When Request Is ‘Unreasonable’ The law doesn’t require you to make exceptions to your rules for an individual with a disability when the requested accommodation is unreasonable. But that doesn’t mean you may reject the request simply because it’s inconvenient or might involve some expense, because the term “unreasonable” has a specific meaning under fair housing law. According to HUD, an accommodation is unreasonable when: ■ It would impose an undue financial and administrative burden on the site; or ■ It would fundamentally alter the nature of the site’s operations. Under HUD guidelines, the determination of undue financial and administrative burden must be made on a case-by-case basis involving various factors, such as the cost of the requested accommodation, the financial resources of the site, the benefits that the accommodation would provide to the requester, and the availability of alternative accommodations that would effectively meet the requester’s disability-related needs. If you believe a request is unreasonable because it either requires fundamental alterations of your operations or imposes an undue financial and administrative burden, then you should suggest an alternative accommodation that would effectively address the individual’s disability-related needs, says Hein. ♦ Insider Source Robin Hein, Esq.: Attorney at Law, Fowler, Hein, Cheatwood and Williams, P.A., 2970 Clairmont Rd., Ste. 220, Atlanta, GA 30329; www.apartmentlaw.com. © 2013 by Vendome Group, LLC. Any reproduction is strictly prohibited. For more information call 1-800-519-3692 or visit www.vendomerealestatemedia.com. April 2013 T A X C R E D I T H O U S I N G M A N A G E M E N T I N S I D E R 5 Q&A Documenting Efforts to Rent Vacant Units Q One of our tax credit units became vacant early last year. We advertised regularly in the newspaper and on the Internet and posted flyers at local shopping centers. But all the prospective households were ineligible. We’ve finally succeeded in renting the unit to a qualified low-income household. Will the fact that it took us nearly a year to rent the unit threaten the owner’s tax credits? A No. As long as you’ve properly documented your efforts to rent your vacant unit, the owner’s tax credits should stay fine. The IRS permits an owner to continue claiming credits for a vacant unit as long as management makes reasonable efforts to rent the vacant unit (or another unit of comparable or smaller size) to a qualified low-income household [IRC §42(g)(1); §42(c)(1)(B)]. The IRS rules don’t define “reasonable attempt,” but advertising in the newspaper and on the Internet and posting flyers as you did should be considered reasonable because you acted diligently. The fact that your attempt was unsuccessful for a while doesn’t make it unreasonable. Be prepared if your state housing agency asks you to prove that you made a reasonable attempt. Keep copies of all your advertisements and flyers. Also, organize the information about your efforts. List your ads with the dates and places they ran, and also keep track of the dates you showed your vacant unit to prospective households and any reason they gave you for deciding not to rent. ♦ Dos & Don’ts ✗ Don’t Perform Full Recertifications When They’re Not Necessary The Housing and Economic Recovery Act of 2008 (HERA) eliminated the annual income recertification requirement for 100 percent buildings. Each state agency, however, may opt to tighten the rule and impose its own recertification requirements. In addition, some owners may still complete annual recertifications to meet compliance requirements for other funding sources such as bonds or HOME funds. But even with the changes imposed by HERA, there’s still a significant number of owners and managers who are performing full annual recertifications at their 100 percent low-income sites when full recertifications aren’t required. According to tax credit expert Karen Graham, force of habit and desire for consistency are the most likely culprits preventing a reluctant compliance professional from implementing a shortened recertification process. According to Graham, depending on the state, a shortened recertification process may include a brief form asking for household composition information, student status, and a demonstration that the rent is under maximum thresholds. More important, the shortened recertification process doesn’t require third-party verifications on income, which can take the most time. Some owners and managers also may be resistant to implementing this change due to concerns of not catching resident fraud at recertifications. If this is the concern, Graham recommends doing a full firstyear recertification with third-party verifications to catch any fraud at move-in and then implementing the shortened process for subsequent years. Eventually, adopting this reduction in paperwork that the law allows will save you time and effort and go a long way toward increasing efficiency at your office. ✓ Focus on Resident Retention to Save Money, Paperwork The paperwork associated with tax credit sites is formidable. Owners and managers must not only deal with paperwork generated from the application process, but also annual owner certifications and submissions of various compliance forms on an annual basis. To save time and minimize paperwork with the application process, tax credit expert Karen Graham recommends that owners and managers emphasize resident retention efforts. If a customer service-oriented staff can prevent a resident from moving out, you’ll avoid processing a whole new application package to fill the vacancy. According to Graham, on (continued on p. 6) © 2013 by Vendome Group, LLC. Any reproduction is strictly prohibited. For more information call 1-800-519-3692 or visit www.vendomerealestatemedia.com. 6 T A X C R E D I T H O U S I N G M A N A G E M E N T I N S I D E R Dos & Don’ts (continued from p. 5) average, the amount of paperwork for a recertification is about half of what it is for a new move-in. In addition to paperwork considerations, the financial costs associated with tenant turnover are high. An average turnover costs over $4,000 and at least 10 hours of an owner or manager’s time turning the unit and processing the application through move-in, says Graham. Owners and managers should focus on meeting residents’ needs with a courteous, professional, and April 2013 responsive staff to increase resident retention and save time and money in the long run. A recent SatisFacts study found that 54 percent of residents choose not to renew leases based on controllable reasons such as poor customer service, lack of responsiveness, and dissatisfaction with maintenance requests. So, it’s critical that managers and owners address these issues. ♦ Insider Source Karen Graham, CPM(R), HCCP, SHCM: President, Karen A. Graham Consulting, LLC; www.compliancesupport.com. Maintenance (continued from p. 1) Consult Your Records “We know 45 to 60 days before lease expiration whether a resident plans to vacate,” says Michael Pantzer, the firm’s chief operating officer. “We then look at the records for each unit being vacated to see when the carpeting and appliances were last replaced to determine how much preparation is needed to make the unit market-ready.” After reviewing the history of each vacated unit, you should have a good idea of which units will require more work. However, if a unit was particularly well cared for or, conversely, has “been through the mill,” this can alter the number of steps required to turn the unit around. So Pantzer instructs the managers and maintenance supervisors at the sites he manages to conduct a pre-move-out inspection of the units being vacated. Make Pre-Move-Out Inspection A pre-move-out inspection reveals what condition the unit is in and whether any major repairs or replacement will have to be done. “This way, you can plan the rehab of the unit in advance,” says Pantzer. This inspection should help you answer the following questions: ■ Do the walls or ceilings need substantial replastering and refinishing? ■ Is the tile or vinyl floor covering in the kitchen, bathroom, or foyer in need of repair or replacement? ■ Is the carpeting worn out or badly stained? ■ Are there any broken windows or torn screens? ■ Are there any major appliances in need of replacement such as the refrigerator, stove, dishwasher, washer, or dryer? ■ Are the glass doors on the shower or tub in need of replacement? Although the pre-move-out inspection can help you determine how to make the unit ready to show prospects, it doesn’t substitute for a thorough move-out inspection after the resident leaves to determine what money, if any, should be deducted from the resident’s security deposit for damages. Consolidate Orders for Items Needing Replacement After conducting the pre-move-out inspections of all the units being vacated during a given month, schedule the turnaround and immediately order the replacement items you’ll need after the move-out. If you have five moveouts scheduled for one month and three of the units require new carpeting, call your supplier and order it all together. By consolidating orders for supplies, you’ll save time in preparing purchase orders. More important, grouping orders together allows you to plan ahead for materials and can help you in negotiating a discount from your supplier for ordering items in bulk. Schedule any outside contractors such as painters well in advance so that you can be assured that the work will be done immediately after the resident moves out. “We try to turn the units around within three days,” says Pantzer. “This depends on the former residents’ living habits,” he says, “but most of them leave the units in pretty good shape.” Give the units that have already been re-rented the first priority. Day 1: Repair Before the unit can be cleaned, all repairs and maintenance must be completed. Pantzer Management arranges to have repairs made as soon as the resident leaves and the (continued on p. 8) © 2013 by Vendome Group, LLC. Any reproduction is strictly prohibited. For more information call 1-800-519-3692 or visit www.vendomerealestatemedia.com. April 2013 T A X C R E D I T H O U S I N G M A N A G E M E N T I N S I D E R 7 Model Form Use Maintenance Checklist for Quick Turnaround The staff member assigned to make repairs to a recently vacated unit should use a copy of this form to make sure that everything in the unit is intact and ready to use. He should then return the completed form, signed and dated, to the maintenance supervisor. UNIT TURNAROUND MAINTENANCE CHECKLIST Employee Assigned_ __________________________________________________________________________ Unit # ________________________ Date: _ ____________________________________ Time Work Began________________________ Time Work Ended: _______________________ KITCHEN ❏ Appliances: Make sure refrigerator, stove, exhaust fan, oven, washer/dryer, dishwasher, garbage disposal are in working order. ❏ Windows and Screens: Replace or repair cracked panels or torn screens; make sure windows open and close securely; make sure locks are functional. ❏ Light Fixtures: Make sure lights work, all bulbs are lighting, and globes are not cracked or missing. ❏ Sink: See that drain is not clogged, faucets are not dripping. ❏ Cabinets: Make sure doors are hung securely and ❏ Outlets and Covers: Make sure electrical points and switches have covers, check sockets to ensure that they are working. ❏ Floor Tile: Replace cracked or chipped tiles. ❏ Light Fixtures: Make sure globes are not cracked ❏ Carpet: Replace if necessary. ❏ Air Vents: Paint. ❏ Paneling: Check and note any holes or deep scars. ❏ Thermostat: Make sure it works. ❏ Fireplace: Check to make sure the flue and damper close correctly. and bulbs work. ❏ Caulking: Fill in chips or cracks. ❏ Doors, Locks, Stops: Make sure doors open and close securely. open and close. ❏ Windows: Replace cracked or broken windows. ❏ Caulking: Fill in any chipped or missing caulking around windows. BATHROOM ❏ Tub, Shower, Sink: Check for clogged drains, leaky faucets. ❏ Towel Racks and Paper Rollers: Check to see that they are in place and hung correctly. ❏ Floor Tile: Replace chipped or cracked tile. ❏ Light Fixtures: Make sure globes are not cracked, light bulbs work. ❏ Doors, Locks, Stops: Make sure doors are hung securely and locks work. ❏ Soap Dish and Toothbrush Holder: Make sure they are hung securely. GENERAL ❏ Check stairs and handrail to make sure they are secure. ❏ Check heating and air-conditioning; change filters in A/C if necessary. ❏ Make sure doorbell is working. ❏ Test intercom to make sure it works. ❏ Make sure foyer floor does not need replacement tile. ❏ Check front door to make sure it opens and closes properly. Paint front door. ❏ Toilet: Check toilet for leaks and make sure it flushes ❏ Make sure window dowels are in place. ❏ Make sure balcony railing is secure. ❏ Make sure heater and vents are working. ❏ Remove any decals that may have been put up on ❏ Window: Repair or replace if necessary. ❏ Replace batteries in smoke and carbon monoxide detectors. ❏ Vanity: Paint inside of vanity cabinet. ❏ Caulking: Repair/replace loose or rotted caulking around the tub. properly; replace seat if necessary. LIVING ROOM/DINING ROOM/BEDROOM(S) walls and doors. NOTE ANYTHING THAT REMAINS IN DISREPAIR. STATE REASON. ❏ Walls and Ceilings: Make sure there are no cracks or _________________________________________________________ ❏ Doors and Locks: Make sure doors are planed correctly and _________________________________________________________ holes in the drywall. that locks are in place and secure. ❏ Sliding Doors and Locks: Make sure doors slide smoothly and locks are secure. _________________________________________________________ _________________________________________________________ © 2013 by Vendome Group, LLC. Any reproduction is strictly prohibited. For more information call 1-800-519-3692 or visit www.vendomerealestatemedia.com. 8 T A X C R E D I T H O U S I N G M A N A G E M E N T I N S I D E R Maintenance (continued from p. 6) move-out inspection is finished. If tiles, window panes, or screens are broken or missing, they should be replaced now. If there are any lighting fixtures that are broken, they should also be replaced or repaired. The staff member assigned to make the repairs can use a copy of our Model Form: Use Maintenance Checklist for Quick Turnaround, to make sure that everything in the unit is intact and ready to use. He should then return the completed form, signed and dated, to the maintenance supervisor. Day 2: Clean; Prep for Painting After repairs are made, the unit is ready to be cleaned. All surfaces must be free of grease, dirt, and dust before painting begins. “We have our maintenance staff do the heavy cleaning first—scouring the tub, toilet, bathroom sink— and then concentrate on the detail work, such as cleaning the cup and toothbrush holder, soap dishes, and towel racks,” says Pantzer. He notes that more than one person may be assigned to clean a unit, depending on its size and the amount of work to be done. “After the unit is cleaned, have a maintenance man prep it for painting,” recommends Pantzer. Cleaning a unit shouldn’t take a full day; therefore, you can use the remainder of the day to remove any nails from the walls, fill in holes, and apply spackling compound. By having your on-site staff do the prep work, you’ll save time and money, particularly if you’ve hired a painter. Day 3: Paint; Replace or Repair Floor Covering/ Carpet “Depending on the size of the unit, we generally allocate a day or day and a half for painting,” says Pantzer. Again, try to coordinate the prep work and painting assignments so that when one unit is completed, the painters can report back to the maintenance super- April 2013 visor and begin work on another unit right away. If the vinyl floor covering or carpeting has to be replaced, it should be installed on the third day of the turnaround, as soon as the painting is finished. Last, if the carpet isn’t being replaced, it should be freshly shampooed. “The final phase is fine-tuning the unit,” says Pantzer. Using maintenance and cleaning checklists, the manager and maintenance supervisor should make a final inspection of all “turnaround” units to make sure they are in move-in condition. By planning ahead, you can make the process of turning around a unit efficient, organized, and thorough. A unit in move-in condition is far more attractive to prospective residents. ♦ Insider Source Michael K. Pantzer: Chief Operating Officer, Pantzer Properties, 540 Madison Ave., New York, NY 10022; www.pantzerproperties.com. HUD Issues Final Rule (continued from p. 1) clarity and consistency for individuals, businesses, and government entities subject to the federal fair housing law. HUD anticipates the rule also will make it easier for individuals and organizations covered by the law to understand their responsibilities and comply with the law. “HUD is maintaining well-established legal precedent and formalizing a nationally consistent, uniform burden-shifting test for determining whether a given housing practice has an unjustified discriminatory effect,” said John Trasviña, HUD’s Assistant Secretary for Fair Housing and Equal Opportunity. The review process for the rule was expansive, transparent, and inclusive, according to HUD. Since January 2012, the agency said it has solicited, received, and incorporated input based on comments from individuals, fair housing and legal aid organizations, Attorneys General, state housing finance agencies, public housing agencies, public housing trade associations, insurance companies, financial institutions, and numerous other entities. “The openness of this process allowed us to implement a rule that can be consistently and fairly applied,” noted Trasviña. ♦ © 2013 by Vendome Group, LLC. Any reproduction is strictly prohibited. For more information call 1-800-519-3692 or visit www.vendomerealestatemedia.com.
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