New HUD Management Review Form Proposed
June 14, 2011

Last week, HUD released a Federal Register notice requesting comments on revisions made to a new draft HUD Form 9834-Management Review for Multifamily Housing Projects that they will be submitting to OMB for approval. HUD has asked for public comment on the changes and modifications made to this form.

Summary of Form 9834 Changes

The majority of the changes in the draft form reflect recent updates to: Chapter 6 of the HUD Multifamily Housing Asset Management and Project Servicing Handbook 4350.1; the EIV system and its new requirements; and the TRACS security requirements.

In terms of the desk review, there are new questions regarding the status of accounts payable and security deposits in the draft form. There are new questions regarding the Management Certification status, management fees paid in accordance with the Management Certification, and if the management agreement reflects HUD’ regulations and guidelines. There are new Section 236 questions regarding excess income status and payments. There is also a new question regarding the promptness of rent increase submissions to HUD.

In addition, the desk review included new questions about additional explanations or resolution required for EIV reports by O/As in the draft form.

The HUD Form 9834 also makes changes to the on-site review questions. It asks if owners are adhering to repayment plans if they are in place at the project. The form also asks new questions about centralized accounting, assets, and credit lines at the properties. The form incorporates a several new questions in the leasing and occupancy section, which does not apply to mortgagees in terms of application processing and tenant selection. The form also incorporates a new section that asks about the existence of file deficiencies.

Addendums A and B of the form has been reformatted and updated to reflect changes to regulations, handbooks, and other guidelines. The Addendum C Checklist has been updated to reflect EIV and TRACS security requirements that need to be fulfilled. Finally, HUD Form 9834 would add a new Addendum D that would require the CA to submit information on state lifetime sex offender statistics for the property.

A copy of the Federal Register notice may be found here:

"Apartment management is more complicated than ever before. Between fair housing rules, green technology, lead paint, and bedbugs, employee training and certification is vital if you want to avoid liability."


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