how to Prevent Fair housing Claims

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;
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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)
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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)
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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)
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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.
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© 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.