Four Tips for Maintaining Effective Waiting Lists
Most tax credit sites keep some type of prospect waiting list. If your site participates in HUD-subsidized programs, such as Section 8 or Section 236, a written resident selection plan is mandatory and must follow HUD guidelines [HUD Handbook 4350.3., Ch. 4, Sec. 1]. But even if not required by HUD or your state housing agency, keeping detailed waiting list records helps to show that you've been actively marketing your units, and it offers evidence to dispel potential discrimination claims.
Waiting lists are easy to maintain, once you have developed a written policy, says tax credit management consultant Amanda Atkins.
Develop Waiting List Management Policy
What does a waiting list management policy cover? All of the processes for managing the information that will protect you at your next compliance review, says Atkins. Those should include:
How the list is maintained (that is, based upon your site's set-aside requirements and/or additional funding, such as HOME funds, Section 8, etc.);
The frequency of waiting list updates;
How electronic files (such as printouts, disks, offsite server, etc.) are backed up; and
Who on your staff has access to the list.
Your waiting list management policy also should be included in your resident selection plan, she adds.
Keep Electronic File with Hard Copy Backups
Atkins recommends maintaining the list in an electronic format and printing out copies on a recurring basis. “If it's a very active waiting list, it should be once a week; for less active lists, once a month,” she says. “This offers proof that the site is maintaining the list outside of the electronic base, which shows a compliance officer that no one is manipulating the list.”
Set up the waiting list in a manner that will not leave you open to any discrimination liabilities—for instance, keep the list in chronological order, with a date and time stamp of application receipt and any follow-up actions.
Atkins advises that only one person on staff have complete access to the site's waiting list if it's in an electronic format. “If it's on a computer, make sure that it is password-protected. If it is on a computer that also shares your sensitive resident information, I strongly advise keeping it within a locked room, such as an office within an office. Also, make sure that the waiting list backups are stored in a secure manner, as well,” she says.
Don't Include Information that Might Lead to Fair Housing Suit
Sites often include race and ethnicity data on waiting lists, “which is a fair housing suit just waiting to happen,” Atkins stresses. “Don't include any information on the list that could raise a fair housing complaint—for instance, information about a prospect's medical condition. You don't need to know that. If the prospect requested an accessible unit, you merely need to indicate that he requested an accessible unit.”
Update List Frequently
Time-constrained site staff sometimes neglect to update the waiting list as often as they should. Don't let that happen, Atkins says. “If information about when the applicant was contacted for the first offer or second offer isn't added to the list, it starts to appear as if some applicants are being given more offers than others, which could raise fair housing and compliance issues.”
If the waiting list is fairly long, Atkins recommends that site staff contact applicants annually to ensure that their information is up to date, they appear to be program eligible, and that they want to remain on the waiting list.
Most important, be consistent. “Apply the same standards for admitting persons from the waiting list,” she says. And be sure that every step is documented and the same information is reflected in both the applicant file and the waiting list.
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