TENANT SELECTION AND ASSIGNMENT POLICY

TENANT SELECTION AND ASSIGNMENT POLICY EFFECTIVE NOVEMBER 1, 2010 Contents 1. ELIGIBILITY FOR ADMISSION 3 II. DETERMINATION OF ELIGIBILITY 5 III. INITIAL DETERMINATION VERIFICATION AND REEXAMINATION OF FAMILY INCOME AND COMPOSITION 6 IV. HOUSEHOLD COMPOSITION 6 V. HOUSEHOLD INCOME 6 VI. SELECTION OF APPLICANTS 7 VII. SELECTION OF SINGLE APPLICANTS 9 VIII. VERIFICATION OF PREFERENCE 9 IX. LEASING OF DWELLING UNITS 10 X. ELIGIBILITY FOR CONTINUED OCCUPANCY 10 XI. RENTS 11 XII. INTERIM ADJUSTMENT OF RENT 12 XIII. REGULAR REEXAMINATION OF RESIDENTS 13 1

XIV. SPECIAL REEXAMINATION OF RESIDENTS 14 XV. OCCUPANCY STANDARDS FOR STATE AND FEDERAL HOUSING 15 XVI. TRANSFER PROCEDURES 16 XVII. TENANTS RELOCATION COMPENSATION 19 XVIII. MOVE-IN INSPECTION OF THE DWELLING 19 XIX. RETURN OF THE SECURITY DEPOSIT 20 XX. APPLICATIONS 20 XXI. PROCEDURES FOR REJECTING INELIGIBLE APPLICANTS 23 XX11. REASONABLE ACCOMMODATIONS: 24 VIOLENCE AGAINST WOMEN ACT 25 VIOLENCE AGAINST WOMEN ACT POLICY 26 CERTIFICATION OF DOMESTIC VIOLENCE, DATING VIOLENCE OR STALKING 31 SOCIAL SECURITY NUMBER (SSN) REQUIREMENTS 34 2

1. ELIGIBILITY FOR ADMISSION It is the policy of the Housing Authority of the Town of Greenwich (HATG) to comply with all applicable laws relating to Civil Rights, including title VI of the Civil Rights Act of 1964, title VIII of the Civil Rights Act of 1968 (as amended by the Community Development Act of 1974 and the Fair Housing Amendments Act of 1988), Executive Order 11063, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, Title II of the Americans with Disabilities Act (to the extent that it applies, otherwise Section 504 and the Fair Housing Amendments govern), any applicable State laws or local ordinances and any legislation protecting the individual rights of tenants, applicants or staff that may subsequently be enacted. To assure a broad range of incomes in each HATG development (to the extent feasible) and to avoid concentrations of the most economically deprived families. The HATG has a procedure in place to monitor the existing Housing Programs for compliance with Section 504. A. Qualify as a family or as a single person as defined herein. A Family is defined as two or more persons who will live together in a stable relationship and share resources. A single person may be an elderly person (62 and over), a disabled person or any other single person or the remaining adult member of a tenant family. B. Family Income is not greater than the State or Federal income limits governing the housing subsidy program for which they applied. The Applicant s Annual Income for determining eligibility must not exceed the Income Limits for Admission as approved by the U.S. Dept. of Housing & Urban Development (HUD) or the Connecticut Department of Economic and Community Development (DECD). These Income Limits will be adjusted periodically. C. Whose family size does not exceed the occupancy standards set forth in Section XV of the document D. Who deposits the equivalent of one month s gross rent for senior and one and one-half month s gross rent for family with the Authority prior or at the lease signing. For residents at Town Hall Annex, the security deposit amount to be collected at the time of move-in is the greater of one month s Total Payment or $50.00. If payment of the security deposit will create a financial hardship on the new resident, the Deputy Director may permit the new resident to make partial payment of the security deposit over a period of time not to exceed ninety (90) days. E. Whose conduct in present or prior housing has been such as would not be likely to interfere with other tenants in such a manner as to diminish their enjoyment of the premises by adversely affecting their health, safety or welfare or to affect adversely the physical environment or the financial stability of the housing development. To include any criminal activity, especially involving violence. Have no outstanding debts to any other Public 3

Housing Authority or Section 8 Programs. To the extent that a past due balance is owed by the family at the time that the family vacates any of the rented units, that rental balance will need to be paid in full by any and/or all family members before any adult members of the household may reapply for admission to programs in the future. F. An ineligible family is one in which no adult member is a citizen, national or has eligible status. Mixed families receive prorated assistance. Each family member will be required to supply documentation of citizenship immigration status (prior to move-in). Additional requirement stating the timeframe for submitting evidence of how citizenship immigration status will be obtained will be implemented. If at least one member of the family has submitted the required documentation in a timely manner, the family will be offered a unit. G. Town Hall Annex and Quarry Knoll 11: Eligibility of Students for Section 8 Assistance: HATG must determine a student s eligibility for Section 8 assistance at move-in, annual recertification, initial certification (when an in-place tenant begins receiving Section 8) and at the time of an interim recertification if one of the family composition changes reported is that a household member is enrolled as a student.. This policy includes the following provisions: HUD released the final rule on June 25, 2001 on Screening For Drug Abuse and Other Criminal Activity to allow Housing Authorities to deny occupancy on the basis of illegal drug-related activities and alcohol abuse when such abuse leads to behavior that threatens the health and safety or peaceful enjoyment of the premises by other residents. The specific language requirements also will be the subject of a separate notice Eligibility Standards, approved by the Board of Commissioners. Any drug-related or criminal activity occurring on or off Greenwich Housing Authority property will be treated as a serious violation of the material terms of the lease. Criminal activity is cause for eviction even in the absence of conviction or arrests. Criminal activity includes: Anyone involved in the possession, sale, or distribution of controlled substances, including violations of liquor laws: Persons evicted for drug-related criminal. Alcohol abuse is grounds for termination of tenancy if the Greenwich Housing Authority determines that such abuse interferes with the health, safety, or right to peaceful enjoyment of the premises by other tenants. Anyone arrested for gambling or participation in illegal lottery and any other gambling offenses. 4

Any person who the Greenwich Housing Authority determines is illegally using a controlled substance, or whose illegal use of a controlled substance is determined by the Greenwich Housing Authority to interfere with the rights of the tenants. Discharge or possession of firearms. Anyone involved in fights, assaults, act of violence or disturbance of the peace on Greenwich Housing Authority property. Any household member who threatens or abuses (verbally or physically) an employee of the Housing Authority Staff on or off the property. The Dwelling lease indicates that the head of the household is responsible for the behavior of all persons in the household and their guests. Within this context, the head of household is to cause these persons to behave in such a manner not to create disturbances nor engage in activities which would impair the social and physical environment in which they live. The Greenwich Housing Authority may move to terminate any family s lease: For any members of the family or guests on the property with the consent of a family member engages in any violation which is determined to be either serious or repeated in nature. II. DETERMINATION OF ELIGIBILITY It is HA policy that all applicants should be screened in accordance with HUD s regulations and sound management practices. During screening HA will require applicants to demonstrate ability to comply with essential provisions of the lease as summarized below. In addition, the Housing Authority will aggressively administer these provisions for eligibility and selection in cooperation with the Final Rule policy for public housing residents. The HA will conduct comprehensive background checks that include screening for criminal activity. We will work with courts and State and Local law enforcement agencies to gain access to criminal records. 1) An applicant s past performance in meeting financial obligation, especially rent and utilities. 2) A record of disturbance of neighbors, destruction of property, or living or housekeeping habits at prior residences which may adversely affect the health, safety or welfare of other tenants; and 3) A history of criminal activity involving crimes of physical violence to persons or property and other criminal acts which would adversely affect the health, safety or welfare of other tenants. 5

4) Persons evicted for drug-related criminal activity. 5) Persons engaging in illegal use of a drug. 6) Persons convicted of methamphetamine production. 7) Persons subject to lifetime sex offender registration requirement. 8) Persons that abuse or show a pattern of abuse of alcohol. III. INITIAL DETERMINATION VERIFICATION AND REEXAMINATION OF FAMILY INCOME AND COMPOSITION In accordance with State and Federal requirements the HATG is responsible for determination of eligibility for admission, for determination of annual income, adjusted income and total tenant payment, and for reexamination of family income. IV. HOUSEHOLD COMPOSITION Prior to entering into a lease agreement for housing, the applicant must demonstrate to the satisfaction of the Authority that all persons listed on the application are available to occupy the apartment when the unit is ready for occupancy. If a dependent child is listed as a student attending school and temporarily not living in the household, the head of household will be required to provide documentation to substantiate the claim. Acceptable documentation to verify the household composition will include but not be limited to any one or more of the following: A) Birth records B) School enrollment certification C) Certified income tax return D) Marriage certificate E) Home visit interview record F) Court custody records G) Adoption papers H) Payment receipts for dependent care, etc. V. HOUSEHOLD INCOME 6

In order for HATG to determine eligibility the applicant must disclose on the initial application all sources or potential sources of income. After all income is verified and documented, HATG in accordance with the Federal and State allowances will adjust the income and determine if the adjusted income meets the program requirements. To the greatest extent possible, HATG will only accept third party (independent) verification to determine income eligibility. Such third party verification will include but may not be limited to any one or more of the following: Paycheck stubs W-2 forms Income tax return (State and/or Federal) W-9 forms and 1099 forms Pensions and annuities-latest check stub from issuing institution Social Security-current award letter Unemployment compensation-determination Letter form 2000, Form UC 30, or latest check stub Workmen s compensation-form DOL 203, recent check stub Alimony-copy of court order Child support-copy of court order Educational scholarships/stipends-award letter Trade union benefits-recent check stub Other public assistance-award letter Income from assets-credit union/bank/s&l statements, etc. Bank statements Stocks/bond certificates Mortgage note Income tax return Certificates of deposit VI. SELECTION OF APPLICANTS Applicants for assisted family housing will be selected from the waiting list and assigned the appropriate size apartment on a first-come/first-serve basis with preference given to eligible applicants who live or work in the Town of Greenwich or whose head or spouse has been hired to work in the municipality. Applicants for assisted senior housing will be selected from the waiting list and assigned the appropriate size apartment on a first-come/first serve basis with preference given to eligible applicants who live or can verify a former residency in the Town of Greenwich. Preference will be given to eligible applicants in family housing who live or work in the Town of 7

Greenwich or have been hired to work in the municipality. The working preference is for applicants that are currently employed. They are defined to be a working family whose head or spouse or sole member is employed. Applicants for assistance who at the time they are seeking housing assistance, are involuntarily displaced by natural disaster to include fire, flood and earthquake will be selected for housing before other eligible applicants. Any eligible applicant claiming the above preferences will be required to provide third party verification Applicants must be able to demonstrate the ability and willingness to comply with the terms of the lease, rules and regulations, either alone or with assistance which they can demonstrate they have or will have at the time of admission. The HA will check applicant s ability to comply with essential lease requirements. Residents who are evicted as a result of their own negligence from any programs under the HATG will not be given any preference status even if the deficiencies are corrected when they re-apply for housing assistance. A. Elderly applicants may move into family housing; any elderly applicant who chooses to do so may be notified in writing that they will not be transferred to senior housing for at least five (5) years. B. All applicants will receive a housing offer of appropriate size apartment; if the offer is rejected, the applicant s name will move to the bottom of the waiting list unless the Deputy Director determines that special circumstance prevented the applicant from accepting the offer. The applicant will have five (5) days to consider a unit offer. Refusal of the unit will drop the applicant to the bottom of the waiting list by changing the date and time of the application. A second rejection of an offered apartment will result in the applicant s name being removed from the waiting list. C. Applicant must attend a briefing scheduled by the Housing Manager prior to occupying the apartment. This briefing is to review the policies of HATG and responsibilities of residents. D. All family members must sign a declaration stating whether they are U.S. citizens or noncitizens eligible for housing assistance and provide the necessary documentation. E. Preference will be given to families that include person(s) with physical disabilities for units with special accessibility features. F. Persons with disabilities are defined as persons who: 8

Has a disability as defined in 42 U.S.C. Section 423 Has a developmental disability in the Development Disabilities Assistance and Bill of Rights Act (42 U.S.C. 6001 (8). Has a physical, mental, or emotional impairment that is to be expected to be of longcontinued and indefinite duration and substantially impedes his or her ability to live independently and is of such a nature that ability to live independently could be improved by more suitable housing conditions. G. Agnes Morley Heights is the only development designated for senior applicants. A senior applicant is one defined as being 62 years or older. In the selection of residents, there shall be no discrimination on the basis of race, sex, color, creed, national origin or handicap. As a general rule, applicants may be denied admission to housing for the following time frames: 1. Denied admission for a minimum of three (3) years and the completion of a court ordered or voluntary rehabilitation program as evidenced by the proper certification and six (6) months of unsupervised living without a repeat incident. a. Persons evicted or terminated from Federal or State assisted housing because of drug-related criminal activity for the personal use or possession from the date of such eviction/termination. b. Persons applying for public housing who have been involved in drug-related criminal activity for personal use or possession for personal use (exclusive of the illegal manufacture, sale, distribution, or possession with the intent to manufacture, sell, distribute) from the date of such activity. VII. SELECTION OF SINGLE APPLICANTS Section 573 of P.L. 101-625 amended the definition of families found in Section 3 (b) (3) of the 1937 Act by making any income-eligible single person eligible for assistance without regard to age, handicap, or percentages of occupancy by such single persons. The law also prohibits such single persons from being given units containing two or more bedrooms. All single persons are eligible if they meet other eligibility criteria. Single pregnant women are determined preliminary eligible as a single person. No allowance for unborn child. Income limit for one person is used. VIII. VERIFICATION OF PREFERENCE 9

Since any eligible applicant could claim a preference to expedite being housed, HATG will require third party verification from one or more sources that can verify the applicant s claim. IX. LEASING OF DWELLING UNITS A. A lease agreement shall be executed in duplicate by a responsible member of each family accepted as residents and by the Deputy Director or his/her designee prior to admission. The original lease will be retained by the HATG and an executed copy will be furnished to the resident. B. If a resident transfers from one dwelling unit to another, a new lease shall be executed. C. During the tenure of a lease agreement, requests for a change in family composition must be made in writing. Management will conduct an interview with the family before any approval is given and shall be made by notice to the resident dated and signed. Such notice shall become part of the lease. D. Lease shall be for the name(s) of all persons who are authorized to occupy the units. X. ELIGIBILITY FOR CONTINUED OCCUPANCY Only those occupants meeting all of the following requirements will be considered eligible for continued occupancy as defined by State and Federal Regulations. A. Qualify as a family, or the remaining member of a resident family as defined by State and Federal Regulations. To qualify as a remaining member, the person(s) must be listed on the current lease and residing in the dwelling unit. If the remaining adult member signed the lease, the person could continue in the program under that lease. If the remaining member did not sign the lease, the HATG will determine whether it would enter into a lease with that person. A child may remain in the unit as a remaining family member if the HATG permits an adult to move in as the new head of household. Rent payment history for the past twelve (12) months shows no legal action and the current family income is sufficient to pay the rent being charged. There is no evidence of drug-related or criminal activity by members of the household, or their guests and there are no records showing lease violations committed by members of the 10

household or their guests and maintenance records do not show a history of destructive behavior. The remaining members must designate a head of household for the purposes of executing a new lease. The remaining members will only be eligible for one apartment in accordance with the occupancy standards herein. B. Elderly Housing only: The remaining occupant (if eligible) will be considered for continued occupancy. A request to add an additional family member who is either elderly or disabled will be reviewed on an individual basis. C. Who meet the occupancy standards set forth in Section XV. D. Whose conduct does not interfere with other residents in such a manner as to materially diminish the enjoyment of the premises. Such interference must relate to the actual conduct of the resident. E. Who reside in the apartment on a regular basis. F. Who keep the apartment in a clean and sanitary condition, do not cause repeated damage beyond normal wear and tear, and who use the appurtenances in the normal manner including maintenance of common areas. XI. RENTS A. The rent for any dwelling unit in Federal housing shall be thirty percent (30%) of the monthly adjusted income, or ten percent (10%) of monthly income, whichever is greater. Resident families living in Federal housing who exceed the established income limits for their family size will be informed of such re-examination. If the private housing sector fails to have suitable and decent housing which does not exceed thirty percent (30%) of the family s monthly adjusted income, the Authority shall be required to renew the lease of the family in accordance with Federal requirements. Accordingly, the TTP in the Public and Indian programs must be the greatest of: 30 percent (30%) of family monthly adjusted income; 10 percent (10%) of family monthly income or; $50 or a higher minimum amount set by HATG. B. The rent for any dwelling unit in State housing shall be thirty percent (30%) of the monthly adjusted income or the base rent, whichever is greater.* Residents in State housing whose 11

adjusted income exceeds the continued occupancy limit for their family size will be required to pay a two percent (2%) surcharge in addition to the monthly rent. *Residents at McKinney Terrace I will pay base rent. If their adjusted family income exceeds the continued occupancy limit for their family size, they will be required to pay a two percent (2%) surcharge in addition to the monthly rent. C. Rents for Federally Financed developments are based upon anticipated income, deductions and exemptions. A statement of income is obtained by the paying agent reflecting actual income for the past four (4) weeks. The PHA has established for each dwelling unit in Federal Family Housing, a flat rental amount and is based on the rental value of the unit, as determined by the PHA. The PHA shall review the income of families paying flat rent not less than once every three years. D. Rent for State Financed developments are based on previous year s income. In accordance with the Connecticut Housing Finance Department regulations, there are no minimum income limits that would allow the refusal of admission to families solely because their income falls below a particular level(s). A determination that the family income falls below a particular income level does not automatically warrant a conclusion that the family cannot pay the base rent for the moderate development. However, the family must be able to verify through the satisfaction of the HATG that housing the family in moderate rental housing will not cause a financial burden to the family. HATG requires a family to demonstrate the ability to apply the base rent prior to admission. The admission decision will be based upon a detailed examination of the family s current financial circumstances as well as previous rental history for a period of no less than one year. XII. INTERIM ADJUSTMENT OF RENT A. The rent and income of a resident family will be reviewed and rent adjustments made as appropriate upon receipt of a written report of one of the following changes in family circumstances: 1. Loss of Lessee or addition of a person who should become the lessee Authority Policy; 2. Receipt or discontinuance of Public Assistance; 12

3. Receipt or discontinuance by wage earner of unemployment compensation or other compensation; 4. Loss or addition to the family of secondary wage earner; 5. Commencement of employment; 6. Income or change in income of person added to the lease; 7. Any other changes in family income or composition. 8. Increases in allowances including increased medical expenses and higher child care costs. 9. Other changes affecting the calculation of a family s income including a family member reaching 62 years old, becoming a full-time student, or becoming a person with a disability. B. Decreases in rent resulting from reports of such changes are to be effective the first of the month following the change, provided HATG has been given reasonable notice. All reported decreases in income are to be verified. C. Increases in rent resulting from reports of such changes are to be effective the first day of the second month following the change. D. If HATG determines that the resident has misrepresented the facts on how the rent was calculated, any increase in rent will be made retroactive to the appropriate date. E Changes in rent may be made by notice to the resident, dated and signed. Such notices shall become part of the existing lease. F. A late charge will be assessed to the rent if the monthly rent has not been paid after the tenant has been given at least nine calendar days as a grace period to pay the rent. The late fee will be $25.00 per month as approved by the Board of Commissioners. G. Other charges during occupancy will include checks returned for insufficient funds, damages caused by neglect on part of the tenant and Court filing, attorney and sheriff fees. A tenant residing at the Town Hall Annex will only be charged for insufficient funds on the second occurrence. XIII. REGULAR REEXAMINATION OF RESIDENTS A. The status of each resident is to be reexamined as follows: 13

Residents will be reexamined at least once a year in accordance with an established certification schedule. Tenants must sign consent forms, and the HATG will obtain thirdparty verification for reported family income, the value of family assets, expenses relating to deductions from annual income and other factors that affect the determination of adjusted income. At each recertification, the HATG will provide the tenant with a copy of the HUD fact sheet describing how the tenant rent is calculated. B. In fitting recently admitted residents into the reexamination schedule; the first reexamination for any resident may be extended to not more than twelve (12) months from the date of admission for all residents. C. Families must be notified in writing of the results of the reexamination and effective date of the change. D. HATG should attempt to give families thirty (30) days notice of any rent increase. Families who fail to cooperate with HATG in providing the necessary information must be treated in accordance with HATG policy. E. Families should be notified in writing 90-120 days in advance of the scheduled effective date, so that reexamination can be completed in time to give the family reasonable notice of any rent increase. HATG uses the same procedures for obtaining and verifying information that were used at admission. HATG should compare the information the family reports to the family s most recent reexamination to identify any discrepancies and ask the family to explain them. HATG does not have to perform annual certifications for individual tenants who are paying contract rent. F. During the reexamination, the family size and composition will be evaluated based upon the occupancy standards in Section XIV. The name, address and family composition of families who are overcrowding or under-occupying units will be forwarded to the Deputy Director for action. The Housing Manager will meet with the family to discuss transfer to the appropriate size apartment. XIV. SPECIAL REEXAMINATION OF RESIDENTS A. If it is not possible at the time of admission or regular reexamination of a resident family to determine annual income with any reasonable degree of accuracy, a temporary determination 14

of income and rent is to be made and a special reexamination scheduled for within 30, 60, or 90 days, depending upon the family s circumstances. The resident is to be notified in writing of the date of the special reexamination. B. If annual family income can be determined at the time of the special reexamination, then the rent will be established. If a reasonable anticipation of annual family income cannot be made, another special reexamination is to be scheduled. XV. OCCUPANCY STANDARDS FOR STATE AND FEDERAL HOUSING As far as possible, the following standards will determine the number of bedrooms required to accommodate a family of a given size as recommended in Federal regulations: NUMBER OF BEDROOMS NUMBER OF PERSONS Minimum Maximum 0 1 1 1 1 2 2 2 4 3 3 6 4 5 8 The following guidelines based on the above are to be used: 15 Generally, two persons per bedroom. Generally, Persons of different generations, persons of the opposite sex (other than spouse) and unrelated adults should have separate bedrooms. Generally, husband and wife share same bedroom. Generally, children of same sex share a bedroom. Generally, children, with the possible exception of infants, should not share a bedroom with parents. Live-in attendant(s) who is/are not family member(s) may have their own bedroom. HATG will require proof of birth or relationship in determining the size of the apartment appropriate for the applicant. The family s need for a larger unit as a reasonable accommodation. Balancing the need to avoid overcrowding with the need to avoid underutilization of the space and unnecessary subsidy. If a family, based on the number of members, would qualify for more than one unit size, the HATG will allow the family to choose which unit size they prefer.

When an applicant requests an accessible unit or a unit preference the HATG will verify that the applicant is qualified for the unit, which is only available to persons with a disability or to persons with a particular type of disability. Verify that the applicant needs the features of the unit as an accommodation to his or her disability. Verify that the applicant is qualified to receive priority on the waiting list available to persons with a disability or to persons with a disability or to persons with a particular type of disability. While occupancy standards have established the size of the unit a family will occupy, the HATG will not make social judgments on a family s sleeping arrangement. If a family chooses a smaller size unit, HATG will require a signed statement that the family will not request a transfer unless family size changes in accordance with HATG transfer policy. The HATG will give tenants a written notice 30 days prior to implementing new house rules or changes in the resident selection plan. XVI. TRANSFER PROCEDURES Reassignment or transfer to other dwelling units shall be made without regard to race, color, sex or national origin as follows: A. Residents shall not be transferred to a dwelling unit of equal size either within a development or between developments, except for alleviating hardships as determined by the Executive or Deputy Director. Elderly residents without children who are occupying units in a family development will be given preference when a vacancy exists in an elderly development. In order to receive a preference, the elderly resident must apply for a transfer in writing. The HATG will move the tenant into an accessible unit in lieu of making the tenants existing unit accessible and usable. If specific accessible features are not needed, yet the disability requires the family to live on a particular floor, the tenant will be offered a transfer. B. Transfers shall be made to comply with occupancy standards. C. Residents occupying units which have become too large or too small will be subject to transfer within the development in which they reside. In the event that no suitable unit is available within the development, the resident will be transferred if a unit is available in another development. The occupancy standards in Section XV will be used to determine when units are not properly utilized. D. Elderly residents without children who are occupying units too large in a family development will be required to transfer to an elderly development so that remaining non-elderly single persons who are over-housed can be transferred within the development. 16

E. It is the policy of HATG to give preference in filling vacant apartments to residents currently residing in overcrowded or over-housed conditions within HATG developments. For purposes of this Policy, residents currently residing within HATG developments are defined as those individuals described in and on the lease for a period of at least one (1) year. Visitors, lodgers or temporary guests, even though related to the residents, will not be considered as residents currently residing within HATG developments. Overcrowded conditions resulting from the occupancy of the leased premises by persons not listed in the lease will not be considered reason for preference. The HATG will not reduce or terminate the assistance associated with the original unit until the family has been offered a transfer to a unit of appropriate size and has been given sufficient time (30 days) to move to the new unit. HATG will transfer tenants to different nits as a reasonable accommodation to a household member s disability. F. Adult children of the lessee, who live with the lessee and have their own children, will be required to file an application in order to receive their own apartment. An adult child of a tenant will not be transferred to their own apartment. The entire household may be transferred to a larger apartment based on the Occupancy Standards herein. G. Elderly residents living with the lessee will be required to file an application in order to be considered for senior housing. H. Transfer request must be approved in writing by HATG. Transfer requests must be made in writing by the head of the household to HATG. A person with a disability need not personally make the transfer request. The request can be made by a family member or someone else who is acting on their behalf. No location preference will be honored. I. Families who are requesting permission to transfer shall be required to have all payment due HATG up to date and leave the premises in a broom-clean condition. Residents to be given first opportunity based on date of eligibility: 1) Household is currently under/over housed; and 2) Rent payment history for the past twelve (12) months shows no late payments, no evidence of summary process action; and 3) There is no evidence of drug related or criminal activity by members of the household or their guests; and 17

4) Maintenance records do not show a history of negligence or destructive behavior; and 5) An announced home visit to the unit shows good to excellent housekeeping habits. Persons may only be added to a signed lease in the cases of birth, marriage (to include additional minors), for medical reasons or family circumstances that will benefit the current family members as determined by the Deputy Director Newborns: A birth certificate will be required. Minors: Requests can only be made for children who were living out of the country at the time of admission, or who were living with one of the parents or other relatives. Birth certificates, passports or visas (if non-resident alien) and school verification will be required. HATG will not consider the addition of cousins and other child relatives unless the guardians first get legal custody. Foster Children: Addition of foster children is subject to the availability of space in the existing unit is accordance with occupancy standards. Foster children are counted for occupancy standards. They do not qualify for the $480 dependent allowance or a deduction for child care. Marriage: A marriage certificate or evidence of a stable relationship, social security number, verification of income and any other information necessary for admission will be required. A new lease will be issued and must be signed by both spouses. Medical Cases: For requests due to medical reasons, such as terminal illness of a child or elderly parent, medical proof or any other documentation pertaining to the circumstances is required before persons can be added on to the lease. Grandchildren: The circumstances (such as deceased parents, or placement by DCYS which feels that a close family member should be responsible rather than a foster home), as well as the apartment size will be considered prior to granting permission. Adult Relatives: Adult relatives may be added subject to the availability of space in the unit and after successfully meeting all eligibility criteria for admission. MEMBERS TAKEN OFF THE LEASE: When a resident reports a member of the family has vacated the home, the following requirements apply: 18

1. Adult Children: Proof of new address is required. Such proof may include a rent receipt from a landlord, a signed lease, or if they are not paying rent and are sharing housing elsewhere, a notarized statement verifying those facts. A change of address form from the post office, stamped and indicating the new address will also be requested. For persons with no forwarding address available, a notarized statement from the Head of the Household will be required. Such statement should include a request that the adult child be removed and the reason(s) for the request. 2. Husband/Wife: Should a spouse vacate the home, the same requirements as explained above regarding adult children will apply. In cases of divorce, a copy of the court decree, restraining order or separation agreement will also be required. If a rent adjustment is necessary, all documentation will be required with up to date income information. A new lease will be issued and must then be signed by the remaining spouse and/or adult family members. In an effort to avoid domestic disputes, confirmation by the vacating spouse that he/she wants to be removed from the lease will be required. XVII. TENANTS RELOCATION COMPENSATION If a tenant is required to relocate permanently or temporarily from a housing unit managed or owned by HATG in order to permit HATG to repair damage(s) to the housing unit not caused by the tenant or by the tenant s household guest, which if not immediately repaired would create a compromise to the health and/or safety of that tenant family if the tenant family were to remain in the unit, the tenant family is eligible for compensation as follows: The actual expenses incurred in moving the family and/ or other personal property. XVIII. MOVE-IN INSPECTION OF THE DWELLING HATG will inspect the unit with the new tenant prior to occupancy and provide an itemized list of repairs to the tenant within five (5) days of that tenant occupying the dwelling. The tenant has five (5) days to respond or the list is assumed to be correct. Inspection Checklist: If HATG does not supply a list of damages, a tenant should carefully inspect and note all damages (number of nail holes, missing fixtures, condition of appliances, 19

etc.). This checklist should be sent by mail to HATG within ten (10) days of occupancy, and a copy kept for the tenant s records. XIX. RETURN OF THE SECURITY DEPOSIT Move-Out Inspection of the Dwelling: HATG is required to make an inspection of the dwelling unit after it is vacated, in order to determine the amount of the security deposit to be returned to the tenant. The law gives the tenant the right to be present at the time this inspection takes place. If the tenant wishes to be present, he must make a request to HATG, who must notify the tenant of the time and date of inspection. Inspection by HATG must be made within 72 hours of the termination of the rental agreement. HATG must give the tenant an itemized list of all damages existing at the time of the inspection. It is important for both parties to be present at the inspection so that any disagreements regarding damages may be resolved. The checklist from the final inspection should be compared to the one completed at the time the dwelling was first occupied in order to determine the amount of damages for which the tenant be liable. Deposit Withholdings: HATG may make withholding from a security deposit for the collection of unpaid rent and damages caused by a tenant beyond reasonable wear and tear. A dwelling must be left clean and free of all items belonging to the tenant. Any cleaning costs which are made necessary by the condition in which the dwelling is left may be deducted from the security deposit. What constitutes wear and tear is a common cause for disagreement between landlord and tenants. Generally, wear and tear is defined as unavoidable deterioration. Tenant is properly liable for damages to the apartment caused by his or her intentional or negligent actions or those of someone on the premises with his or her consent and under his or her control. Return of the Deposit: HATG has up to thirty (30) days after a dwelling is vacated to return a security deposit and earned interest. An itemized list of withholding must accompany the amount returned. XX. APPLICATIONS Receipt of Application: Every application shall constitute the basis upon which HATG shall make determinations of eligibility status, rent and size of unit for which the applicant is qualified. The application for admission also constitutes the basis for establishing the applicant s preference status for selection. 20

Every application received by the HATG office will be stamped with the date and time of receipt. A formal receipt of application will be issued to the applicant, showing application date and time or receipt and program. The receipt will be signed by a HATG representative. The receipt shall clearly state that: 1) The receipt establishes the application date and does not assure eligibility. 2) The applicant must immediately report in writing to HATG any change of address. HATG is not responsible for the inability of the U.S. Postal Service to deliver mail to applicant. Applicants will be advised that the waiting time can vary depending on vacancy rate, family income and the apartment size needed and that a home visit, credit check and police check are required. All documents required must be verified and in the file before the applicant can be offered a unit. Misrepresentation by the Applicant: If an applicant is found to have made misrepresentations which resulted in applicant being classified as eligible when, in fact, he or she was ineligible, the application will be rejected. The applicant may not reapply for at least twelve (12) months from the date of rejection. If an applicant is found to have given false statements which result in the misclassification of the unit size required, the applicant will be reclassified according to the correct information, as long as the waiting list for the unit size was open to applicant when he or she applied. If said waiting list was not open to applicant at that time, the application will be rejected. Ineligible Applicants: Any applicant determined to be ineligible for admission to a program shall be promptly notified in writing of said determination and the basis therefore. The applicant will be provided the opportunity for an informal hearing on such determination in accordance with stated policy. An applicant in Public Housing who was evicted for drug activity will not be able to reapply for housing for three (3) years from the date of the eviction. Income-Targeting: For each project assisted under a contract for project-based Section 8 assistance, the owner HATG must lease not less than 40% of the dwelling units (assisted under the 21

contract) that become available for occupancy in any project fiscal year to extremely low-income families. The method used by HATG to achieve compliance was to determine that the composition of the current waiting list enables HATG to achieve the income-targeting requirement based on the significant number of extremely low-income applicants on this waiting list. Annual Purge of Waiting List: Once each year, all applicants on every waiting list will be contacted by mail to verify continued interest and continued eligibility. Disabled applicants can request (if noted on the application) the updated application can be sent to a local advocacy group. Failure to respond to this communication within the specified period of time will result in the deletion of the application from the waiting list. Withdrawing of applications can be through the applicant s request, no response to the purge letter (includes mail returned) or no response to HATG request for interview or additional information. No informal hearing is required for withdrawing of applications. Opening of Waiting List: Applications will be stamped with the date and time of receipt and placed on the waiting lists based on the established preferences stated in VI. The application must include an address and a signature from the applicant certifying the accuracy and completeness of the information provided. HATG advertisement will directed to all applicants regardless of race, color, religion, sex, disability, familial status or national origin. HATG will target advertising to groups other than the typical population of the neighborhood in the media most likely used by the applicants including minority publications. All advertising will include the HUDapproved Equal Housing Opportunity logo or statement. Closing of Waiting List: The waiting list may be closed for one or more unit sizes when the average wait is over one year. Potential applicants will be advised that the waiting list is closed and no applications will be accepted. A notice will be published in a publication likely to be read by potential applicants. The notice will state the reasons for no longer accepting applications. 22

Site Based Waiting List: The statute now permits site based waiting lists. The HATG will open a site based waiting list for the purpose of providing de-concentration of poverty and assure that applicants can make informed choices. De-concentration is a plan to admit families in our Federal Development in compliance with the Quality Housing and Work Responsibility Act of 1998. To achieve the goal of de-concentration and income mixing, the HATG will establish preferences for working families and skipping over certain families based on income. It is mandated that 40% of new admissions are to be 30% of median income (or less) and the other 60% of new admissions can be very low income or low-income. The HATG will accurately and timely submit data to HUD, disclose to applicants basic information about the selection of a development, including its size and amenities and the length of possible waiting time for admission. XXI. PROCEDURES FOR REJECTING INELIGIBLE APPLICANTS The purpose of the hearing is to: Rejection notices must be in writing and specifically state the reason(s) for the rejection. Families must be notified of their rights to a hearing in most circumstances in which the HATG makes a decision affecting eligibility or assistance. All hearings must be conducted by a non-involved person designated by the HATG who must be someone other than the person who made or approved the decision. HATG appoints hearing officers who are HATG Senior Management. Applicants may present oral or written objections to the decision. They may retain counsel or any other representative, if desired, at his/her own expense. Persons with disabilities have the right to request reasonable accommodations to participate in the hearing process. After the hearing is completed, the HATG will notify the applicant of the final decision and state the reasons for its determination. All requests for a hearing, supporting documentation and copy of the final decision will be retained in the family s file. The grievance procedures for public housing tenants do not apply to HATG determinations affecting applicants. The timeframe to request a hearing will be fourteen (14) business days. 23

The HATG will schedule the hearing within ten (10) business days from the date of the request. The HATG will have five (5) business days to issue a final decision following the hearing. After a hearing date is agreed to, the family may request to reschedule only upon showing good cause which is defined as an unavoidable conflict which seriously affects the health, safety or welfare of the family. XX11. REASONABLE ACCOMMODATIONS: Housing providers must make reasonable accommodations in lease and other policy requirements when requested by a qualified resident with disabilities. The concept of reasonable involves helping a resident meet essential lease requirements, it does not require the lowering or waiving of essential requirements. Accommodations are not reasonable if they require a fundamental alteration in the nature of the program or impose undue financial and administrative burdens on the housing provider. 24

Violence Against Women Act GREENWICH HOUSING AUTHORITY The Greenwich Housing Authority provides or offers the following activities, services, or programs that helps child and adult victims of domestic violence, dating violence, sexual assault, or stalking, to obtain or maintain housing. The Violence against Women Act protects tenants and family members of tenants who are victims of domestic violence, dating violence, or stalking from being evicted or terminated from housing assistance based on acts of such violence against them. Generally, the law provides that criminal activity directly relating to domestic violence, dating violence, or stalking, engaged in by a member of a tenant s household or any guest or other person under the tenant s control, shall not be cause for termination of assistance, tenancy, or occupancy right if the tenant or an immediate member of the tenant s family is the victim or threatened victim of that abuse. The law also provides that an incident or incidents of actual or threatened domestic violence, dating violence, or stalking will not be construed as serious or repeated violations of the lease by the victim or threatened victim of that violence and will not be good cause for termination of the assistance, tenancy, or occupancy rights of a victim of such violence. It is the Housing Authority s plan that future/current residents of the public housing program and participants of the Housing Choice Voucher Program will be given a copy of PIH Notice 2006-42. Residents of the Public Housing complexes will be provided this notice when the lease is executed, or upon recertification while participants of the HCV Program will be apprised during their briefing session or upon recertification. The contents therein will be explained to the family members that attend these appointments. The requirement contained in the law that precludes eviction based on domestic violence, dating violence, or stalking will be explained to new landlords and those currently involved in the program at time of recertification. During the lease period, the landlords will be advised of the VAWA requirements should tenant-eviction because of actions become a reality. Landlords of/and new participants to the Housing Choice Voucher Program or families relocating to a different unit will be required to complete the reissued Housing Assistance Payments Contract and Tenancy Addendum that incorporated the restrictions of the Act. Families currently residing in the Public Housing developments, as well as the HCV participants who have not submitted a Request for Tenancy Approval, will be notified of the safe-guards against eviction/termination, as well as the requirement for certification and verification. 25