Section 6.9 of the RAD relocation Notice requires PHAs to maintain detailed data on each household that will be relocated, including the key dates of notices and moves. HUD calls this the resident log. It is both a compliance requirement and the backbone of a well-run relocation.
What to track
At a minimum, build the log to capture for each household:
- Household identification, unit, size and bedroom need.
- Accessibility needs and existing reasonable accommodations.
- Language needs and preferred format for communications.
- Move category (on-site, temporary under one year, temporary over one year, permanent).
- Delivery date and method for each notice: RIN, GIN, Notice of Relocation, URA eligibility notice and Notification of Return.
- Move-out date, temporary address, and move-back date.
- Payments made and expenses reimbursed.
- Any alternative housing offer, decision date and outcome.
- Complaints, appeals and how they were resolved.
Why it matters
- Timing proof. The start-of-relocation rule depends on notice delivery dates. Without them you cannot show compliance.
- The 12-month clock. The log tells you which households are approaching one year in temporary housing, before URA rights are triggered by surprise.
- Right to return. It shows who has returned, who is waiting, and who chose an alternative.
- Reviews and disputes. HUD reviewers, investors, auditors and resident advocates will all ask for it.
Practical setup
Use one system of record, owned by one person, with restricted access because it holds personal data. Reconcile it monthly against payments and the construction schedule. Link each log entry to the household's file of signed notices, receipts and election forms.
After closing
Responsibilities can move from the PHA to the Project Owner at conversion. Agree in writing who maintains the log after closing and how long records will be retained, so nothing falls between the two.
Sources
Disclaimer: This content is for general informational purposes only and is not legal advice. Do not rely on it as a substitute for advice from a qualified attorney. Reading it does not create an attorney-client or consulting relationship. HUD guidance changes; confirm current requirements with your RAD Transaction Manager and counsel before acting. PHA Consultant is not a law firm and is not affiliated with HUD.