Effective May 1, 2016, HUD’s Office of Multifamily Housing Programs has reinstated Management and Occupancy 
Reviews (MOR) to conduct management and occupancy reviews (MOR’s). MORs are a list dos and don’ts that need to be understood by property owners and fully complied with, in order to make sure that there will be a good report on the MOR. As this could result in findings not corrected, HUD may withhold voucher requests, or worse, decide to no longer work with the property owner.
A MOR finding could be risky business for property owners who handle tenant security deposits. Since security deposits provide owner/agents with some financial protection when a tenant moves out of the unit and fails to fulfill his/her obligations under the lease, being incompliance with HUD while charging tenants security deposit then become necessary.
To ensure that HUD’s multifamily housing programs are administered as intended by identifying deficiencies to eliminate fraud, waste, and mismanagement occupancy reviews are initiated. The documented monitoring activities also provide support for enforcement actions when owners/agents do not correct deficiencies. The Management and Occupancy Review is one of the integral mechanisms of project monitoring used to ensure that owners/agents comply with the requirements under the Regulatory Agreement, Mortgage, Management Certification, Housing Assistance Payments (HAP) Contract and/or other relevant business agreements. The MOR is completed by Compliance Managers and consists of:
- A scheduling letter which is sent at least 30 days in advance of the MOR that includes a request for relevant documents to be provided to NHC for review in advance of the MOR
- A desk review completed prior to and in preparation for the on-site review to analyze the Tenant Selection Plan, House Rules, Lease, Application, EIV Policies and Procedures
- An on-site review of a random sampling of resident files
- Follow up of the property’s most recent REAC inspection (Pending HUD directive)
- A report that is sent to the owner/agent and HUD within 30 days of the on-site Review indicating the results and rating of the Review
- Assisting the owner/agent in responding to any MOR findings within 30 days of the date of the report.
After the MOR, a report is sent to the Owner, Agent and the HUD Field Office. Owner/Agents have 30 days to remedy deficiencies identified in the MOR Report. If State Housing does not receive a compliant response, PBCA staff will continue to work with the Owner/Agent until full compliance is reached and the MOR can be closed.
For more on HUD compliance and preparing for MOR, join expert speaker Debbie Hixon in a Webinar on Wed, November 30, 2016. During this session Debbie will take attendees through the vital aspects of avoiding MORs, particularly while handing security deposits. This session will provide key learning on other associated charges to ask for from the tenant and other useful subjects related to MOR.
