Module 8
HUD Review & Common Deficiencies
Preparing for HUD reviews and avoiding common AFHMP mistakes
Lesson 1
HUD Review Process
HUD reviews AFHMPs both at initial submission and during property management reviews.
Initial Submission Review
- Submitted to HUD Regional Office (Multifamily Hub)
- Reviewed for completeness and compliance
- May require revisions before approval
- Approval letter issued when satisfactory
- Cannot accept applications without approval
Ongoing Monitoring
- Management and Occupancy Reviews (MOR)
- Physical Inspection (REAC)
- Financial audits
- Complaint investigations
- Random compliance reviews
What HUD Reviews
- AFHMP document completeness
- Marketing materials and advertisements
- Applicant and tenant demographic data
- Outreach documentation
- Staff training records
- Reasonable accommodation log
- Complaint records
- Application and denial documentation
- Waiting list management
HUD can conduct reviews at any time. Be review-ready at all times by maintaining current documentation.
🔑 Key Points
- Initial AFHMP requires HUD approval
- Ongoing monitoring occurs throughout property operation
- Keep all documentation organized and accessible
- Be prepared for review at any time
Lesson 2
Common AFHMP Deficiencies
Understanding common deficiencies helps you avoid them in your AFHMP.
Documentation Deficiencies
- Incomplete or outdated market analysis
- Missing demographic data
- Vague or generic marketing strategies
- No specific outreach activities listed
- Missing community organization contacts
- No marketing budget or timeline
- Insufficient detail on target populations
- No documentation of past activities
Marketing Material Issues
- Missing Equal Housing Opportunity logo
- Logo too small or unclear
- No fair housing statement
- Discriminatory language or images
- No accessibility information
- Missing TDD/TTY contact information
- Not available in relevant languages
Implementation Deficiencies
- Marketing started after accepting applications
- Tenant demographics significantly different from market area
- No documentation of outreach efforts
- Staff untrained or training not documented
- No partnerships with community organizations
- No tracking of marketing effectiveness
- AFHMP not reviewed annually
- Five-year update not submitted
The most common deficiency is lack of documentation. Even if you did the work, without documentation, you cannot prove compliance.
Record-Keeping Issues
- Applications incomplete or missing
- Denial reasons not documented
- Waiting list not maintained properly
- Reasonable accommodation requests not logged
- No demographic data on applicants
- Marketing expenses not tracked
- Outreach activities not documented
- Training records incomplete
🔑 Key Points
- Most deficiencies relate to documentation
- Market analysis must be specific and current
- Marketing materials must be fully compliant
- Implementation and tracking essential
Lesson 3
Corrective Actions
If HUD identifies deficiencies, prompt corrective action is required.
Responding to HUD Findings
- Take findings seriously - they can impact funding
- Review findings carefully
- Develop corrective action plan
- Implement corrections promptly
- Document all corrective actions
- Submit evidence of compliance to HUD
- Follow up to ensure issue resolved
Common Corrective Actions
- Revise AFHMP with specific details
- Update market analysis with current data
- Develop comprehensive marketing plan
- Establish community partnerships
- Conduct staff training
- Implement record-keeping systems
- Enhance marketing materials
- Increase outreach to underserved groups
- Submit progress reports to HUD
Failure to correct deficiencies can result in loss of HUD financing, penalties, or loss of good standing.
Preventing Future Deficiencies
- Conduct regular self-assessments
- Maintain comprehensive documentation
- Stay current with HUD guidance
- Seek technical assistance when needed
- Attend fair housing training
- Join industry associations for updates
- Consult with fair housing experts
- Review other properties' best practices
Example:
Sample Corrective Action Plan: Deficiency: Lack of documented outreach to Hispanic/Latino community Corrective Actions: 1. Establish partnership with Hispanic Chamber of Commerce (by 3/1) 2. Begin monthly Spanish newspaper advertising (starting 3/15) 3. Translate all marketing materials to Spanish (by 3/30) 4. Hire bilingual leasing consultant (posted 2/15) 5. Attend 4 Hispanic community events in next 6 months 6. Document all outreach activities 7. Submit progress report to HUD quarterly Responsible Party: Property Manager Completion Date: 9/1/2024 Evidence: Partnership agreement, ad copies, translated materials, attendance records
🔑 Key Points
- Respond to deficiencies promptly and thoroughly
- Develop specific corrective action plans
- Document all corrections made
- Implement preventive measures for future