HUD Handbook 4350.3 § 4-18

A.       Overview

                 Whenever a change is made in the waiting list, an action is taken, or an activity
                 specific to an applicant occurs, a notation must be made on the waiting list.

        B.       Providing an Auditable Record of Changes to Waiting Lists

                 The goal of the annotation is to provide an auditable record of applicant
                 additions, selections, withdrawals, and rejections. Independent reviewers looking
                 at the waiting list should be able to:

                 1.       Find an applicant on the waiting list;

                 2.       Readily confirm that an applicant was housed at the appropriate time
                          based on unit size needs, preferences, and income-targeting; and

                 3.       Trace various actions taken with respect to a family’s application for
                          tenancy.

        C.       Maintaining Documentation of the Waiting Lists

                 Owners must develop a method to maintain documentation of the waiting list
                 composition, application status, and actions taken.

1.       The method adopted by an owner will vary based upon the level of
                          automation used at the property.

                 2.       Owners should periodically analyze their waiting list policies and
                          documentation procedures to determine whether an independent party
                          reviewing the list and its supporting documentation could follow the
                          actions taken, applicable preferences, and reasons why certain
                          individuals may have been selected ahead of others on the waiting list. If
                          not, the owner must make the waiting list format and associated practices
                          more transparent.

        D.       Maintaining Records of Manually Recorded Waiting Lists

                 An owner may keep a manual property waiting list.

                 1.       Manually maintained waiting lists must be maintained as a permanent
                          record.

                          a.       The list must not be “rewritten.”
                          b.       The list must be maintained in a manner that cannot easily be
                                   altered.
                          c.       The list must be kept in a manner that can be audited.
                 2.       The manual waiting list must provide an easily viewable record of the date
                          and time of application, and date and time of selection from the waiting
                          list.

        E.       Maintaining Records for Electronic Waiting Lists

                 Owners may maintain an electronic waiting list (instead of a manual property
                 waiting list).

                 1.       Electronic waiting lists must have a mechanism for maintaining the date
                          and time of each applicant’s placement on or selection from the waiting
                          list and a way to document changes made to the list. The following are
                          examples of methods that owners might use to track inputs to the
                          electronic waiting list and changes to it.

                          a.       Use a data backup function to record the time and date of entry of
                                   new applications and changes to existing records in the electronic
                                   waiting list.

                          b.       Print a record of the appearance of the waiting list as often as
                                   necessary (at least monthly) to show each applicant’s placement
                                   on and selection from the list. The time and the date of the
                                   printout should appear on the report. The owner can file this
                                   information in the tenant file and in a central waiting list selection
                                   file.

c.       Whenever status changes occur, such as changes in family
                                   composition and unit size, the change should be recorded with an
                                   explanation, and the re-sorted list should be printed.

                 2.       To the extent possible, the owner should use electronic safeguards, such
                          as assigning waiting list password access only to individuals responsible
                          for maintaining the system. Ideally, a system should record the user
                          name and the time, date, and action entered whenever a record is
                          changed or entered in the electronic waiting list.