In December 2016, we published an article about HUD’s Final Rule implementing the Violence Against Women Reauthorization Act (VAWA) of 2013. Since then we have had hundreds of students take our VAWA webinar and start the steps toward compliance with the new requirements by providing the VAWA Notice and Certification Form to all existing tenants, new tenants, and rejected applicants.
It is important, however, not to miss the other requirements of the Final Rule. In addition to providing the notice and certification form, Owners/Agents (O/A) and PHAs are required to update their Multifamily Housing Tenant Selection Plan, their Public Housing Admissions and Continued Occupancy Plan and lease, or their Housing Choice Voucher Administrative Plan to reflect the VAWA policies and procedures. Contract Administrators and HUD reviewers will be looking for these updates when they come to evaluate the property/program. If you have House Rules attached to your multifamily lease, VAWA policies and procedures must be included there as well.
In addition, no later than June 14, 2017, all O/As and PHAs are required to adopt and implement an Emergency Transfer Plan that details both what a resident must do to request either an internal or external transfer due to their status as a victim of domestic violence, dating violence, sexual assault or stalking AND what the O/A or PHA must do to relocate the victim family. HUD has produced a model plan that can be used as a template, but it is important to note that this model plan is not comprehensive and is only meant as a starting point in this process. We encourage you not to wait until the last minute to create your plan.
VAWA regulations now cover both the IRS’s Low Income Housing Tax Credit program and the Department of Agriculture’s Rural Housing Program, but the HUD Final Rule does not automatically apply to these programs. Please check with your state agency to see if they have specific guidance on VAWA.
For further VAWA information, please join us for our VAWA Update webinar on May 11, 2017 at 2pm EDT.