HUD Handbook 4350.3 § 4-7

Screening for Suitability (HUD Occupancy Handbook 4350.3 REV-1 CHG-4)

HUD guidance — not codified law
In Force
Verified 9/24/2026 · Next check 10/1/2026
effective 9/24/2026FederalPermitted Screening Criteria

Operative Text

HUD Handbook 4350.3 § 4-7
Screening is used to help ensure that families admitted to a property will abide by the
        terms of the lease, pay rent on time, take care of the property and unit, and allow all
        residents to peacefully enjoy their homes. Information collected through the screening
        process enables owners to make informed and objective decisions to admit applicants
        who are most likely to comply with the terms of the lease. An effective screening policy
        will also ensure fair, consistent, and equal treatment of applicants. All screening criteria
        adopted by the owner must be described in the tenant selection plan and consistently
        applied to all applicants in a non-discriminatory fashion and in accordance with all
        applicable fair housing and civil rights laws.

        A.       Screening Versus Determining Eligibility

                 Screening for suitability of tenancy is not a determination of eligibility for the
                 program.

                 1.       Eligibility is a determination that an applicant family meets all of the
                          criteria for the type of subsidy in the property. To be eligible a family must
                          meet the income limits and provide specific information and
                          documentation of other family information (i.e., SSNs, and citizenship
                          information). Eligibility is discussed in detail in Chapter 3.

2.       Screening is a determination that an otherwise eligible household has the
                          ability to pay rent on time and to meet the requirements of the lease.

        B.       Key Requirements

                 1.       Owners are permitted to establish and apply written screening criteria to
                          determine whether applicants will be suitable tenants. If an owner's
                          review of information about the applicant indicates that the applicant will
                          not be a suitable tenant, the owner may reject the application for
                          assistance or tenancy.

                 2.       Owners must establish written screening criteria to prohibit the admission
                          of certain individuals who have engaged in drug-related criminal behavior,
                          or are subject to a State lifetime sex offender registration program, or are
                          individuals whose abuse or pattern of abuse of alcohol interferes with the
                          health, safety, or right to peaceful enjoyment of the premises by other
                          residents. Owners may choose to expand these requirements regarding
                          prohibition of admission to certain applicants [24 CFR part 5, subpart I &
                          J].

                 3.       *Owners must establish written procedures for using the EIV Existing
                          Tenant Search. See D below.*

                  4.      Screening criteria must be included in the tenant selection plan. (See
                          paragraph 4-4.C and Figure 4-2.)

                 5.       Owners must apply screening criteria uniformly to all applicants to prevent
                          discrimination and avoid fair housing violations.

                 6.       The screening of live-in aides at initial occupancy and the screening of
                          persons or live-in aides to be added to the tenant household after initial
                          occupancy involve similar screening activities. Both live-in aides and new
                          additions to the tenant household must be screened for drug abuse and
                          other criminal activity, including *State lifetime registration as a sex
                          offender*, by applying the same criteria established for screening other
                          applicants. In addition, owners may apply any other owner established
                          applicant screening criteria to new household members in order to
                          establish suitability for tenancy. Owner established screening criteria may
                          also be applied to live-in aides, except for the criterion regarding the
                          ability to pay rent on time because live-in aides are not responsible for
                          rental payments.

                 7.       Police officers and other security or management personnel that reside in
                          subsidized units are subject to the same screening criteria as other
                          applicants.

                 8.       The costs of screening must not be charged to applicants. Such costs
                          may be charged against the project operating account. A variation on this
                          rule applies to cooperatives.

                 9.       Certain types of screening are prohibited. See paragraph 4-8 below.

C.       Screening For Drug Abuse and Other Criminal Activity

                 1.       Tenant selection plans must contain screening criteria that include
                          standards for prohibiting admission of those who have engaged in drug-
                          related or criminal activity. The plan may, under certain circumstances,
                          include additional provisions that deny admission to applicants for other
                          drug and criminal activity.

                 2.       Owners must establish standards that prohibit admission of:

                          a.       Any household containing a member(s) who was evicted in the
                                   last three years from federally assisted housing for drug-related
                                   criminal activity. The owner may, but is not required to, consider
                                   two exceptions to this provision:

                                       (1)     The evicted household member has successfully
                                               completed an approved, supervised drug rehabilitation
                                               program; or

                                       (2)     The circumstances leading to the eviction no longer
                                               exist (e.g., the household member no longer resides
                                               with the applicant household).

                          b.       A household in which any member is currently engaged in illegal
                                   use of drugs or for which the owner has reasonable cause to
                                   believe that a member’s illegal use or pattern of illegal use of a
                                   drug may interfere with the health, safety, and right to peaceful
                                   enjoyment of the property by other residents;

                          c.       Any household member who is subject to a State sex offender
                                   lifetime registration requirement; and

                          d.       Any household member if there is reasonable cause to believe
                                   that member’s behavior, from abuse or pattern of abuse of
                                   alcohol, may interfere with the health, safety, and right to peaceful
                                   enjoyment by other residents. The screening standards must be
                                   based on behavior, not the condition of alcoholism or alcohol
                                   abuse.

                 3.       Owners may establish additional standards that prohibit admission if the
                          owner determines that any household member is currently engaging in, or
                          has engaged in, the following activities during a reasonable time before
                          the admission decision:

                          a.       Drug-related criminal activity. The owner may include additional
                                   standards beyond the required standards that prohibit admission
                                   in the case of eviction from federally assisted housing for drug-
                                   related criminal activity and current drug use.

b.       Violent criminal activity.

                          c.       Other criminal activity that threatens the health, safety, and right to
                                   peaceful enjoyment of the property by other residents or the
                                   health and safety of the owner, employees, contractors,
                                   subcontractors, or agents of the owner.

                                   NOTE:. If an owner’s admission policy includes any of the
                                   activities above or similar restrictions that uses a standard
                                   regarding a household member’s current or recent actions, the
                                   owner may define the length of time prior to the admission
                                   decision during which the applicant must not have engaged in the
                                   criminal activity. The owner shall ensure that the relevant
                                   “reasonable” time period is uniformly applied to all applicants in a
                                   non-discriminatory manner and in accordance with applicable fair
                                   housing and civil rights laws.

                 4.       An owner’s screening criteria also may include the following provisions:

                          a.       Exclusion of culpable household members. An owner may require
                                   an applicant to exclude a household member when that member’s
                                   past or current actions would prevent the household from being
                                   eligible.

                          b.       Drug or alcohol rehabilitation. When screening applications, an
                                   owner may consider whether the appropriate household member
                                   has completed a supervised drug or alcohol rehabilitation
                                   program. The owner may require appropriate documentation of
                                   the successful completion of a rehabilitation program.

                          c.       Length of mandatory prohibition. The owner may set a period
                                   longer than required by the regulation (as described in
                                   subparagraph C.2 above) that prohibits admission to a property
                                   for disqualifying behavior. For those behaviors that would result in
                                   denial for a “reasonable time,” the owner must define a
                                   reasonable period in the tenant selection plan.

                          d.       Reconsideration of previously denied applicants. An owner may
                                   reconsider the application of a previously denied applicant if the
                                   owner has sufficient evidence that the members of the household
                                   are not and have not engaged in criminal activity for a reasonable
                                   period of time. The owner must define a reasonable period of
                                   time in the tenant selection plan. When the owner chooses to
                                   adopt this admission provision, the owner must require the
                                   household member to submit documentation to support the
                                   reconsideration of the decision which includes:

                                   (1)      A certification that states that she or he is not currently
                                           engaged in such criminal activity and has not engaged in
                                           such criminal activity during the specified period.

(2)     Supporting information from such sources as a probation
                                           officer, a landlord, neighbors, social service agency worker
                                           or criminal record(s) that were verified by the owner.

                          e.       Consideration of the circumstances relevant to a particular case.
                                   In developing optional screening criteria for a property, and
                                   applying the criteria to specific cases, owners may consider all the
                                   circumstances relevant to a particular household’s case. Such
                                   considerations may not be applied to the required screening
                                   criteria described in subparagraph C.2 above. These types of
                                   circumstances include:

                                   (1)     The seriousness of the offense;

                                   (2)     The effect denying tenancy would have on the community
                                           or on the failure of the responsible entity to take action;

                                   (3)     The degree of participation in the offending activity by the
                                           household member;

                                   (4)     The effect denying tenancy would have on nonoffending
                                           household members;

                                   (5)     The demand for assisted housing by persons who will
                                           adhere to lease responsibilities;

                                   (6)     The extent to which the applicant household has taken
                                           responsibility and takes all reasonable steps to prevent or
                                           mitigate the offending action; and

                                   (7)     The effect of the offending action on the program’s
                                           integrity.

        D.       *Screening Using the EIV Existing Tenant Search

                 Owners must establish procedures in their Tenant Selection Plan for using the
                 EIV Existing Tenant Search to determine if the applicant or any member of the
                 applicant’s household are being assisted under a HUD rental assistance program
                 at another location See Chapter 9, Enterprise Income Verification (EIV) for
                 information on using the Existing Tenant Search.*

        E.       Considerations In Developing Screening Criteria

                 Specific screening criteria will vary from property to property. In developing
                 screening criteria, owners may want to consider the following factors:

                 1.       Length of the property’s waiting list. An owner of a property that has a
                          long waiting list may consider establishing relatively restrictive screening
                          standards, whereas an owner of a property with little or no waiting list
                          may want to have less restrictive standards. *Regardless of standards
                          established, the owner must screen for State lifetime sex offender

registration in all states where the applicant, or members of the
                          applicant’s household, have resided or using a database such as the Dru
                          Sjodin National Sex Offender Database that searches all of the individual
                          state sex offender registries. This searchable database is located at
                          http://www.nsopw.gov.* Setting standards involves balancing the need
                          to fill vacancies with the long-term effect of accepting higher risk tenants.
                          Thorough screening often makes the project more attractive to applicants,
                          thereby decreasing vacancies and turnover.

                 2.       Application and screening fees. Screening takes staff time and may
                          require funds to pay for credit reports and other information.

                                   Rental housing. Owners may not charge application fees or
                                   require applicants to reimburse them for the cost of screening,
                                   including screening for criminal history. Therefore, owners will
                                   want to carefully weigh the cost of various screening activities
                                   against the benefits. Screening costs may be charged as an
                                   operating expense against the property operating account.

                          a.       Screening criteria for assisted units in cooperatives.

                                   (1)     Application fees. Cooperatives may require prospective
                                           members to pay application fees if such fees are
                                           permissible under state and local laws. The cooperative's
                                           board of directors must approve the application fee. While
                                           the fee must be reasonable in amount and consistently
                                           applied, cooperatives need not submit the fee for Field
                                           Office approval. The cooperative must treat the application
                                           fee as an earnest money deposit. The application fee is
                                           not intended to cover the administrative expenses the
                                           cooperative incurs in processing applications. If the
                                           applicant is accepted for membership, the cooperative
                                           must apply the application fee to the purchase of the
                                           membership. If the applicant is rejected by the
                                           cooperative, the cooperative must refund the full
                                           application fee. The cooperative may retain the application
                                           fee only if the applicant backs out of the purchase
                                           transaction. While rental projects may not collect
                                           application fees, cooperatives may do so because
                                           application fees are traditional for homeownership
                                           transactions, and admission to a cooperative requires
                                           completion of more complicated paperwork than does
                                           admission to a rental. Collection of an earnest money
                                           deposit will minimize instances in which the cooperative
                                           spends time and money processing the application and
                                           then the applicant backs out.

(2)     Credit report fees. Cooperatives may charge applicants for
                                           the cost of credit reports. This fee is intended to cover the
                                           cooperative's out-of-pocket cost; these fees are not
                                           refundable and need not be applied to the applicant's
                                           purchase costs. Cooperatives are permitted to charge
                                           these costs to applicants because:

                                            Such charges are standard industry practice for
                                             homeownership;

                                            Costs of these reports for home purchase can be more
                                             expensive than those required for rental purposes; and

                                            During initial occupancy, HUD requires cooperatives to
                                             obtain credit reports on all applicants, and many
                                             cooperatives have continued that policy as
                                             memberships are resold in later years.

        F.       Permitted Screening Criteria Commonly Used by Owners

                 1.       Overview. Owners are permitted to screen applicants for suitability to
                          help them to determine whether to accept or deny an applicant’s tenancy.
                          Owners should consider at least developing screening criteria related to
                          the following factors and may establish other criteria not specifically
                          prohibited in paragraph 4-8 below. All screening criteria adopted by the
                          owner must be described in the tenant selection plan and consistently
                          applied to all applicants.

                 2.       Screening for credit history. Examining an applicant’s credit history is
                          one of the most common screening activities. The purpose of reviewing
                          an applicant’s credit history is to determine how well applicants meet their
                          financial obligations. A credit check can help demonstrate whether an
                          applicant has the ability to pay rent on time.

                          a.       Owners may reject an applicant for a poor credit history, but a lack
                                   of credit history is not sufficient grounds to reject an applicant.

                          b.       As part of their written screening criteria, and in order to ensure
                                   that all applicants are treated fairly, owners should describe the
                                   general criteria they will use for distinguishing between an
                                   acceptable and unacceptable credit rating. Owners are most often
                                   interested in an applicant’s credit history related to rent and utility
                                   payments. A requirement for applicants to have a perfect credit
                                   rating is generally too strict a standard.

                          c.       Owners may determine how far back to consider an applicant’s
                                   credit history. Owners generally focus on credit activity for the
                                   past three to five years. It is a good management practice to give
                                   priority to current activity over older activity.

d.       Owners may have to justify the basis for a determination to deny
                                   tenancy because of the applicant’s credit rating, so there should
                                   be a sound basis for the rejection.

                 3.       Minimum Income Requirement. Section 236 and Section 221(d)(3) BMIR
                          applicants who receive no other form of assistance, such as Section 8,
                          may be screened for the ability to pay the Section 236 basic rent or the
                          BMIR rent. Owners may establish a reasonable minimum income
                          requirement to assess the applicant’s ability to pay the rent. In the
                          Section 8, RAP, and Rent Supplement programs, owners may not
                          establish a minimum income requirement for applicants. (See paragraph
                          4-8.A.)

                 4.       Screening for rental history. In addition to determining whether applicants
                          are likely to meet their financial obligations as tenants and pay rent on
                          time, owners are also interested in whether applicants have the ability to
                          meet the requirements of tenancy.

                          a.       Owners must not reject an applicant for lack of a rental history but
                                   may reject an applicant for a poor rental history.

                          b.       As part of their written screening criteria, and in order to ensure
                                   that all applicants are treated fairly, owners should describe the
                                   general criteria they will use for distinguishing between acceptable
                                   and unacceptable rental history.

                 5.       Screening for housekeeping habits. Owners may visit the applicant’s
                          current dwelling to assess housekeeping habits.

                          a.       As part of their written screening criteria, and in order to ensure
                                   that all applicants are treated fairly, owners should describe the
                                   general criteria they will use for distinguishing between acceptable
                                   and unacceptable housekeeping practices.

                          b.       Owners must establish reasonable standards which can be
                                   consistently applied to all families. Messy living quarters are not
                                   the same as safety and health hazards.

                          c.       In defining the home visit standards, the owner should establish a
                                   geographic radius within which home visits are made, and outside
                                   of which home visits are not made. It is impractical to establish a
                                   policy requiring home visits for all applicants, which might require
                                   the owner to visit units many miles from the property. For
                                   example, an owner may determine that 50 miles is the maximum
                                   distance that can be traveled to visit an applicant at home.

                 6.       Consideration of extenuating circumstances in the screening process.
                          Owners may consider extenuating circumstances in evaluating
                          information obtained during the screening process to assist in determining
                          the acceptability of an applicant for tenancy. If the applicant is a person

with disabilities, the owner must consider extenuating circumstances
                          where this would be required as a matter of reasonable accommodation.
Source: Legislative text reproduced verbatim

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Related Rules

§ 4-28
Ensuring That Screening Is Performed Consistently

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