Getting Ready for a HUD Relocation Review

Relocation records get reviewed more often than many agencies expect. HUD field offices, state housing finance agencies, tax credit investors, auditors and resident advocates may all ask for them. The URA regulations at 49 CFR 24.9 require agencies to keep adequate records, and the RAD relocation Notice requires a resident log for RAD conversions.

How long to keep records

Under 49 CFR 24.9, records generally must be kept for at least three years after each owner or displaced person receives the final payment. Program rules, grant agreements and state law may require longer. Check them all and use the longest period.

What a complete household file contains

• the needs interview and any updates;
• copies of every notice, with proof of delivery;
• a record of advisory contacts;
• the comparable units offered and inspection records;
• payment calculations, claims, receipts and proof of payment;
• reasonable accommodation requests and how they were handled;
• any alternative housing offer and the signed election;
• appeals and their outcomes;
• return or final move-out documentation.

What reviewers look for

• Notices issued on time and in the right order.
• Moves that did not start before they were allowed to.
• Payments that match the regulations and the files.
• Evidence that residents knew their rights, including the right to return.
• Consistent treatment of similar households.

Habits that help

• Use a standard file checklist for every household.
• Reconcile the resident log, payments and budget each month.
• Do an internal file review partway through the project and fix gaps while residents can still be reached.
• Protect personal information with limited access and secure storage.