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© 2000-2016 Independent Management Services/Independent Management Services Procedures Manual Release 10/2016

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Chapter 1

OFFICE MANAGEMENT We are a team, which upholds a professional management profile serving our clients and positively enhancing our management skills and capabilities.

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Chapter 1, Office Management

NORMAL BUSINESS HOURS Normal business hours are from 8:00 a.m. to 5:00 p.m. Monday through Friday. A one-hour lunch period is provided for all personnel, normally from 12:00 noon to 1:00 p.m. Lunch hours should be scheduled so that the office is attended always during business hours. At the discretion of the Property Manager, an answering service may be used to accept and screen incoming telephone calls. The answering service may only be used between 5:00 p.m. and 8:00 a.m. weekdays, and on weekends and holidays. Site Managers are to seek approval from their Property Manager anytime a site office is to be closed during normal business hours. Property Managers and Site Managers must also report to IMS-Fenton whenever a site office is to be closed during normal business hours. Property Managers are responsible for arranging appropriate staff to cover offices so that they always remain open during normal business hours. Maintenance personnel should not be requested to cover site offices except in emergency situations and only if properly trained.

Reporting For Work

Any employee who is unable to report for work must contact the SITE MANAGER by 8:00 a.m. and not leave the message on the answering service. If the Site Manager is unable to report for work, he/she must contact the Property Manager by 8:00 a.m., at the IMS-Fenton office. All absences are to be reported to IMS-Fenton each morning. Site Managers are to personally contact their supervisor and IMS-Fenton if calling off or away from the site during normal business hours. Site Managers are to contact their supervisor and IMS-Fenton if ANY site staff are absent. Leave the name of the employee and reason for absence, as soon as you learn of the absence. Note that sick time will be paid ONLY if IMS-Fenton is notified of the absence ON THE DAY of the absence.

Leaving the Site

All site employees are required to obtain authorization from the Site Manager before leaving the site premises during normal business hours, except for lunch hours and emergencies. The Site Manager is required to notify the Property Manager if he or she is required to leave the site premises period during normal business hours.

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Tardiness or Absence Chronic tardiness and/or unscheduled absence will cause termination of employment. DRESS CODE The required dress code for IMS is one that will project an image of professionalism, and good taste. All office personnel are required to dress professionally. Jeans, T-shirts, shorts, athletic type shoes, etc. are not permitted. Maintenance, housekeeping, and other staff will be required to wear uniforms in conformity with the dress code requirements for each property as established by the Property Manager. OFFICE APPEARANCE

Office Cleaning

The following cleaning procedures are to be performed daily before the office opens for business:

Carpet vacuumed Floors swept and mopped Garbage containers emptied Kitchen area cleaned Bathroom(s) cleaned Furniture dusted

Work Space Organization

Office personnel are responsible for his/her desk appearance. Desks are to be dusted and neatly organized at the end of the business day. Maintenance personnel are responsible for maintaining a neat and organized maintenance shop. The floor areas are to be kept free of trip hazards and flammable materials are to be safely stored in covered containers.

No Smoking Policy With both the residents and employee's welfare being a primary consideration, IMS has adopted a "No Smoking" policy. Absolutely no smoking will be permitted in the leasing office, Site Manager's office, model apartments, garages, or any other area that would be visited by current or potential residents, or non-smoking employees. Site managers may designate an inconspicuous smoking area outside. Property staff personnel or representatives of IMS are prohibited from smoking in any vacant or occupied apartment on the property during business.

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GOVERNMENT AGENCIES AND OTHER OUTSIDE REQUESTS Do not contact any government agency without express permission from an IMS Corporate Officer. In the event that any government agency contacts you, then please direct them to the IMS-Fenton office at (810) 750-7000. No site employee is permitted to provide any reference information or personal information to any outside business or agency about any current or former employee. All such requests, including reference requests from prospective employers, are to be forwarded to the IMS-Fenton office. TELEPHONE TECHNIQUES

Phone Labeling All office phones are to have typed adhesive labels with the following information posted on each office telephone. 1. Length of waiting list for each size unit 2. How the amount of rent is calculated 3. Base rents for each size unit

4. The square footage of each size unit 5. Income Restrictions

When answering a call, it is important to answer it in way that conveys professionalism and carries a positive attitude at all times. This makes for a great impression to the caller. (Example: Thank you for calling “property name” this is “your name” how may I help you?). Always give your name so the caller knows with whom they are speaking.

Fair Housing Concerns

Always be courteous, patient, and professional with every applicant, resident, or visitor, whether on the telephone or in person ensuring that each receives equal and consistent treatment, adhering to the Federal Fair Housing Laws and the IMS Fair Housing Policy. See page FH-1. WORK ORDER PROCESSING Routine work orders should be scheduled for completion within twenty-four hours, except in emergencies that require immediate attention. The Work Order System is to be used. After a work order is generated with the resident’s information and request, it should be assigned to a maintenance person according to the procedures in Chapter 2 of this manual.

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Work Order Control WORK ORDER / SERVICE REQUEST PROCESSING Routine work orders should be scheduled for completion within twenty-four hours, except in emergencies that require immediate attention. The OneSite (Facilities) Service Request System is to be used. After a work order is entered with the resident’s information and complaint, the work order should be printed and given to the Site Manager to be distributed to the assigned maintenance person according to the procedures listed in Chapter 2 of this manual. Upon inspection/completion of the repair, the work order copy is distributed as follows:

Work Order Control

1. Original printed Work Order / Service Request returned to Office Manager for entry

into OneSite (Facilities) Service Request System. (Original printed Work Order / Service Request can be discarded once verified complete and entered in OneSite (Facilities) Service Request System.)

2. In the event that the resident is not home during scheduled / emergency maintenance the bottom portion of the service request should be signed and left in unit as indication that maintenance was performed.

Maintenance Follow-up

The OneSite (Facilities) Service Request System includes a ledger to record and control all work orders. The Site Manager is responsible for monitoring work order progress daily and reconciling work orders to the control ledger weekly. In addition, the site manager must randomly inspect completed work orders to ensure high quality service and to detect inefficiencies in the maintenance operation. A summary of work orders, completed and outstanding, is to be provided to the Property Manager monthly.

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FILING SYSTEMS AND ORGANIZATION

TRIPLECHAM

The TRIPLECHAM filing system is used for all documents and correspondence related to the property. Each property is required to keep copies of all documents (originals are sent to IMS) filed in the site TRIPLECHAM system. The TRIPLECHAM filing system was developed as a common sense filing system. Each letter in the acronym TRIPLECHAM represents a major area of interest: Tenant Information Reports Insurance Information Personnel Information Legal Documents and Proceedings Engineering and Maintenance

Correspondence and Memos HUD Related Information Annual Financial Information

Monthly Financial Information A detailed outline of the TRIPLECHAM filing system is found in Form 1.1.

Waiting List(s) A separate waiting list is to be kept for each unit size and also a combined waiting list for all unit sizes. Waiting lists are to be kept for up to 3 years. Two or more properties are not to be combined on one waiting list. An approval letter is sent to the prospective resident notifying them of their position on the waiting list. a. If your property has Section 8 or Section 236, refer to the Resident Selection Criteria for

your property for waiting list procedures. All approved applications must be updated every 120 days. Applicants must complete a new checklist and third party must verify income verifications.

b. If your property has tax credits only, all applications must be updated every 120 days.

Applicants must complete a new checklist and third party must reverify income verifications.

c. If your property is Conventional and does not have Section 8, Section 236, or Tax

Credits, all applications must be updated every 120 days.

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Current Resident Files IMS uses the six (6)-page legal size folder to compartmentalize resident information. This system is organized and enables the employee to find needed information quickly. Each six-page file folder is placed in a separate hanging folder. The placement of all information in a resident's file is detailed in the Unit File Placement List found in Form 1.3. A copy of Form 1.3 is to be placed in each unit file. If your property has tax credits, then the Placed-In-Service certification is to be placed on Page 6. This will include the Agency Cert From (if applicable), HUD Form 50059 (if applicable), income and asset checklist(s), and supporting verifications. A separate folder should be retained in the resident file for EIV Reports. (See Chapter 7)

Prior Resident Files

At the time of move-out, all resident information is to remain in the six-page folder This is a good time to make your copies of the documents needed for collection agency and special claim packages. All prior resident files are kept alphabetically in a bankers box with the period covered listed on the front of the box.

Record Retention All former resident files and rejected applications are to be kept on site forever. Do not dispose of any property documents without prior authorization from IMS. The retention period of most documents is detailed in the Record Retention Sheet found in Form 1.2.

Monthly Property Inspection Report All Property Managers are to complete a Property Inspection Report monthly using IMS Form 1.4 – Property Inspection Report.

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Notes:

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Chapter 2

MAINTENANCE PROCEDURES We believe in serving the needs of our residents by providing professional maintenance services of the highest quality. IMS promotes strict adherence to preventive maintenance schedules.

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Chapter 2, Maintenance Procedures

MAINTENANCE PROCEDURES Management of the physical asset is a crucial part of the overall management process for it can significantly affect the value of the property. The appearance and condition of the buildings and grounds help determine the type of residents attracted, resident satisfaction, turnover, and rent collection. The primary reasons given by residents who withhold rent are poor maintenance or inadequate response to service requests. Prompt, effective maintenance and courteous maintenance staff can turn resident dissatisfaction into resident cooperation, negative cash flow into positive cash flow. A focus is made on a comprehensive maintenance program. UNIT AND COMMON AREA INSPECTIONS

Grounds and Common Area Inspections Frequent physical property inspections are priority functions of the Site Manager. SITE MANAGERS ARE REQUIRED TO INSPECT AT LEAST A PORTION OF THE PROPERTY GROUNDS AND BUILDINGS EACH WORKING DAY, SO THAT 100% OF THE PROPERTY EXTERIOR AND COMMON AREAS HAVE BEEN INSPECTED BY THE CLOSE OF EACH BUSINESS WEEK. During inspections, managers must note: 1. Any maintenance problems 2. Rule violations 3. Inoperable or unlicensed vehicles 4. Weed growth 5. Safety or health hazards 6. Cleanliness and curb appeal. In addition, Site Managers should be looking for areas especially vulnerable to damage by vandals, and what steps should be taken to protect the property. Vandals tend to select locations where they run little risk of detection or identification by witnesses. Therefore, ensuring that exterior lights are always operable and sufficient is a primary concern during exterior and common area inspections.

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UNIT AND COMMON AREA INSPECTIONS (CONTINUED)

Vacant Unit Inspections Vacant unit inspections must be made within 24 hours after the vacancy occurs, and daily throughout the vacancy period. The manager must ensure that the vacant units are cleaned and repaired for renting as soon as possible to reduce lost income. Property staff or representatives of IMS are prohibited from smoking in any vacant or occupied apartment on the property during business hours.

Occupied Unit Inspections Occupied unit inspections must be performed at least 4 times per year (see IMS Form 2.11), unless you have written exception from the IMS Corporate Office. During these inspections, the Site Manager observes and records any items in the unit requiring repair, and gathers information necessary to decide needed replacement items due to age and deterioration. In addition, poor housekeeping habits, tenant damages, over-occupied units, and conformance to the property’s rules by the tenant is a primary concern. These deficiencies must be noted and resolved to prevent further deterioration of the property, and to inform the Property Manager the results of these unit inspections. Unit inspections are to be conducted by a manager only. The inspection form is to be signed and dated by a manager (IMS Form 2.11), and filed in the tenant file.

Pre-Move-out Inspections Pre-Move-out inspections should be performed within 30 days prior to the anticipated move-out, and with the resident present if possible. This gives the Site Manager an opportunity to inform the resident of the condition that he/she is to restore the unit at move-out. The resident is informed then of any charges that will be made to their account for damages etc., if the unit is not restored to a reasonable condition. The Site Manager then can begin planning the reconditioning process to reduce unit turnover time.

Move-Out Inspections Move-out inspections must be conducted within 24 hours of the move-out (when possible, in the presence of the vacating resident to follow up on the pre-move-out inspection items). The resident and the Site Manager are required to sign the Move-in/Move-out Inspection Form (See Form 2.1), to prevent possible misunderstandings regarding any charges for damages etc. Residents should not be charged for items worn by normal use and time. They should be charged for unusual wear and breakage, such as cigarette burns, broken mirrors etc. The Site Manager, having planned for the turnover process during the pre-move-out inspection, can now begin making the unit ready for occupancy. Reconditioning of a unit shall not take more than three (3) business days.

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UNIT AND COMMON AREA INSPECTIONS (CONTINUED)

Move In Procedures Once a unit has become Ready for Occupancy (RFO), a pre-move-in interview will be conducted to educate the applicant about the lease, rules, and the obligations of both the applicant and management. This process is discussed in detail in Chapter 4 of this manual. It is important, however, that until the unit becomes occupied, daily inspections are made to ensure the unit remains in RFO condition. The unit will then be shown to the applicant with an emphasis placed on the positive aspects of living in the development, and a reaffirmation of the staff's commitment to service. It must be understood that ONLY the Site Manager can designate a unit RFO, and this can only be achieved by the Site Manager inspecting the unit prior to granting the RFO status. Applicants and prospective residents are not to be shown a unit that is not designated RFO under any circumstances. Important: Do not move a person into the software prior to their possession of the unit.

Mold Remediation Guidelines The following guidelines and procedures have been developed assuming the underlying cause of mold, the water accumulation, has been identified and repaired. In general, any water infiltration should be dried and cleaned immediately (24 to 48 hours) to minimize mold growth. However, should this not be done and mold growth is observed, the following mold remediation guidelines and procedures have been developed to allow IMS and/or their subcontractors to mitigate the mold encountered. Removal of mold and moisture impacted building materials should be completed in a manner that minimizes the spreading of fungal spores. Non-porous media (e.g. metal, glass, plastic, etc.) and semi-porous media (wood and concrete) can be cleaned and re-used. Cleaning of these medias should be completed using a quaternary solution or 5% bleach solution. In the case of wood, the wood should be seal with two coats of an anit-microbial/anit-fungal paint/sealer to prevent future mold and/or fungi development. When mold is encountered on porous media, such as dry wall, fabrics, carpets, etc., the following guidelines and procedures should be completed to minimize spreading of the mold spores. The guideline and procedures will be broken down into two categories small (< 30 ft2); and large areas (> 30 ft2). The separation is based on the premise that the small mold impacted areas would be encountered during routine maintenance, such as replacement of floor or ceiling tiles,

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dry wall repair, etc., while the large impacted areas may require more significant effort and not considered routine maintenance and repair. IMS’ recommended guidelines and procedure for completion of these remediation activities are presented below: Small Areas (< 30 ft2)

Document any specific complaints or physical irritations noted by tenants, including the date, time of day and area of complaint; Baseline air quality samples and photos/documentation of the impacted areas by a hygienist.

Remediation work can be conducted by regular building maintenance staff. Such person

should have awareness level training on proper cleanup methods, personnel protection and the potential health hazards associated with molds and fungi;

Respiratory protection in accordance with the OSHA protection standard should be

followed. In addition, glove and eye protection should be worn during remediation activities;

The work area (unit) should be unoccupied. Vacating people from the areas adjacent to

the work area is not necessary, but recommended in the presence of infants, persons recovering from recent surgeries, immune suppressed people, or persons with acute or chronic respiratory concerns;

Misting each item/area prior to disturbance so as to minimize the amount of airborne

mold spores;

Where drywall is impacted with mold or moisture, remove the material to a minimum of 16” outside of the visibly stained are;

Removal of mold impacted wood studs is recommended, however, depending on the

condition of the wood studs, you may opt to clean visible molds from the wood using a quaternary solution or 5% bleach solution and seal with two coats of an anit-microbial/anit-fungal paint/sealer;

Following removal of impacted materials the area should be cleaned, as appropriate, with

a quaternary solution or 5% bleach solution;

Following completion of remediation, the work area should be cleaned with a damp cloth and/or mop with a quaternary solution or 5 % bleach solution. All areas involved in the remediation should be left dry and visibly free from contamination and debris; and

Contaminated media, which cannot be cleaned, should be removed from the building in a

sealed plastic bag for subsequent disposal. There are no special disposal requirements for mold impacted materials.

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Air monitoring should be conducted prior to occupancy to determine if the area is fit to

reoccupy. Large Areas (> 30 ft2) Due to nature and potential expense involved with a large scale mold remediation, an environmental professional with significant mold experience should be consulted prior to initiating the project. In addition, the project should have professional environmental over-site and clearance sampling completed following completion of mold remediation activities. The following guidelines and procedures are recommended:

Document any specific complaints or physical irritations noted by tenants, including the date, time of day and area of complaint; Baseline air quality samples and photos/documentation of the impacted areas by a hygienist.

Remediation work should be completed by mold-trained personnel. Such person should

have training on proper cleanup methods, personnel protection and the potential health hazards associated with molds and fungi;

Respiratory protection in accordance with the OSHA protection standard should be

followed. In addition, disposable clothing (Tyvek suites), gloves and eye protection should be worn during remediation activities;

The work area (unit) should be unoccupied. Vacating people from the areas adjacent to

the work area is recommended;

Seal ventilation ducts/grills in work area areas directly adjacent work area with plastic;

The work area should be isolated including the use of an exhaust fan with a HEPA filtration system to create a negative pressure in the work area. Where the entire room is not the isolated area it may be necessary to plastic sheeting and duct tape to create an isolation zone to minimize the potential spread of mold impacted debris and dust;

Misting each item/area prior to disturbance so as to minimize the amount of airborne

mold spores;

Contaminated media, which cannot be cleaned, should be removed from the building in a sealed plastic bag for subsequent disposal. Prior to removal from the isolation zone, debris bags should be wiped down with a damp cloth with detergent, or cleaned with a HEPA vacuum to minimize the potential for spreading mold debris outside the isolation zone. There are no special disposal requirements for mold-impacted materials.

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Following completion of remediation, the work area should be cleaned with HEPA vacuum, followed by a damp cloth and/or mop with a quaternary solution or 5 % bleach solution. All areas involved in the remediation should be left dry and visibly free from contamination and debris;

Evaluate the HVAC system for potential presence of mold or mold/fungi impacted

debris. Clean as needed; and

Air monitoring should be conducted prior to occupancy to determine if the area is fit to reoccupy.

WORK ORDER / SERVICE REQUEST PROCESSING AND REPORTING To prevent accidents, demonstrate respect for the privacy and security of a resident's home, and avoid surprising residents. Maintenance staff should knock loudly, giving adequate time for response. If there is no answer, they should announce their presence and call out "MANAGEMENT" in a loud voice - both prior to and after opening the door. Once inside, they should check all rooms to make sure no one is home. This procedure must be followed for every service call. When the maintenance staff is working in an area, an "IMS Staff Inside" note should be visible at the entrance to the apartment. This prevents surprising residents who arrive home while maintenance personnel are inside. While inside, maintenance staff should note the condition of the unit and report anything unusual (e.g., pets, poor housekeeping, other maintenance needs, etc.) to the Site Manager. Special care must be taken not to disturb the resident's belongings, once inside the unit. Property staff or representatives of IMS are prohibited from smoking in any vacant or occupied apartment on the property. Maintenance staff should clean up the work area thoroughly before leaving, and lock the apartment. Employees are cautioned against making unrealistic promises of immediate service, however, routine work orders should be completed within twenty-four hours, and emergencies must be attended to immediately. Residents requesting service should be assured that problems will be attended to as quickly as possible. If a work order cannot be attended to when promised or within twenty-four hours, whichever is sooner, the resident should be kept informed of any problems or delays and be advised when to expect the work to be completed. All residents should be asked to report problems and maintenance needs to the management office, thereby eliminating the chance for maintenance staff to forget an oral work order received on the property.

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WORK ORDER / SERVICE REQUEST PROCESSING AND REPORTING (CONTINUED)

Work Order / Service Request Procedure The work order is a two-part form, consisting of one office copy for OneSite (Facilities) Service Request entry purposes and a detachable section to leave as indication that maintenance was performed inside the resident’s unit. The resident’s portion of the work order should be left in a conspicuous place for the resident's information. The Site Manager should review the completed work order and if the resident should be charged for the work, use the completed request to apply the charges to the resident's account. In addition, the Site Manager must at least randomly inspect the completed work orders to ensure high quality service is being provided, and to detect inefficiencies in the maintenance operation. All work orders are recorded in the OneSite (Facilities) Service Request System ledger. The Site Manager must monitor work order progress daily, and reconcile the work orders to the control ledger weekly. A summary of the completed and outstanding work orders is to be provided to the Property Manager monthly.

Appliance / Asset Log The Appliance / Asset Log is to be maintained by the Site Manager in OneSite. When a new appliance is purchased it will be logged by address, type and style of appliance, serial and model number. The Appliance / Asset Log is located under the (Facilities) tab in OneSite.

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UNIT RECONDITIONING PROCEDURES

Unit Reconditioning Log A Unit Reconditioning log is to be maintained by the Site Manager, and is to be kept current always. The log is designed to summarize the progress and timeliness of the reconditioning process for each unit turnover, keep track of scheduled move outs, move out dates, prospective residents, scheduled move-in dates and comments for additional items that maybe needed for completion of a vacant unit. Reconditioning of a unit shall not take more than three (3) business days. The log may be used together with, but may not be replaced by, any other scheduling mechanism designed by the Site Manager.

Vacancy Board

All Properties are required to have a vacancy board installed in the rental office set up in the same manner as the unit-reconditioning log. This board should be a dry erase board measuring at least 2' x 3', and placed in an inconspicuous location. The vacancy board provides an ever present reminder of the status of the vacant units, and serves to enforce timely unit turnovers. All vacant units, including expected vacant units is to be placed on the board. Once a unit becomes vacant, the name and scheduled move-in date of the new resident are placed on the vacancy board, and the new resident is contacted to arrange for the move-in interview. Reconditioning of a unit shall not take more than three (3) business days.

Ready-For Occupancy (RFO) Status

IMS maintains the highest possible standards with regard to the "market ready" condition of a unit. Prior to move-in, the Site Manager must inspect and approve the unit for move-in. The minimum standards for reconditioning a unit include the following:

Carpet cleaning

100 % repaint

Maintenance repairs

Unit cleaning

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It is important that a vacant unit be restored as close as possible to its original condition, unless otherwise directed by Property Manager. In addition, when reconditioning a unit, the most important factor in determining whether a unit is market ready, is cleanliness. Reconditioning of a unit shall not take more than three (3) business days. ASSESSMENT OF RESIDENT DAMAGES

1. Repairs shall be assessed at $20.00 per hour. 2. Fixtures shall be assessed at replacement cost. 3. Carpeting shall be pro-rated from installation dates, over a 5-year lifetime.

CONTRACTED SERVICES Maintenance staff will be required to report immediately to the Site Manager when contracted services are required. Upon report of such, the Site Manager will personally inspect the problem to verify the need. It will be the responsibility of the Site Manager to call in and schedule contracted services upon approval from the Property Manager. After approval, the Site Manager will fill out a work order for the work to be completed. When work is being performed by an outside contractor in a resident's unit, a staff member must accompany that contractor. Under no circumstances are master keys to be issued to Non-IMS Staff. Note: All contractors must supply proof of Liability Insurance, Workers Compensation and

Taxpayers ID

Bid Specifications IMS REQUIRES THAT ALL CONTRACTED SERVICES BE PLACED FOR BID USING THE FOLLOWING FORMAT:

A. Bid specifications must be designed for each service contracted, and approved by the Property Manager using the Bid Specification Worksheet, Form 2.4. The bid specifications must be completed prior to soliciting bids, and are to be given to at least 5 contractors for the service to be performed.

B. Once the bids are collected from the contractors, all bids are to be summarized on a Bid Summary Worksheet, Form 2.5, and submitted to the Property Manager together with Proof of Liability Insurance, Worker's Compensation and Taxpayer ID # for all contractors.

NOTE: A MINIMUM OF THREE BIDS ARE REQUIRED ON ALL BID SUMMARY WORKSHEETS. (Five bids are preferred)

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Proof of Insurance

All vendors who perform property services must provide proof of Workers Compensation and Liability Insurance, prior to starting work or pending services.

Contract Procedures All contracts entered into by properties managed by IMS must be written and/or approved by the central office. The leasing of equipment is not permitted under any circumstances. Under no circumstances are site personnel authorized to sign contracts. INVENTORY CONTROL Inventory will be tracked on an Inventory Control Log Form 2.18. All supplies will be separated in supply boxes labeled with stock number and amount of items to be kept on hand. Each time an item is removed to complete a work order the item used will be listed on Form 2.18 Inventory Control Log with the address in which the item is to be used. When the items fall below the amount to be kept on hand the item will be placed on an order sheet located in the maintenance office. In order to control the amount of purchasing the Site Manager will place an order on a monthly basis. SAFETY PROCEDURES

Employee Responsibilities EMPLOYEES SHALL:

1. Not operate any machine or equipment until trained in the operating procedures, hazards and safeguards.

2. Not operate machine or equipment until he/she has been assigned to do so. 3. Report any recognized hazard to the supervisor.

4. Use required personal protective equipment or devices as prescribed in this general

procedure or a specific procedure.

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Personal Protective Equipment The following equipment, where needed, will be provided:

Safety glasses (non-prescription)/goggles Respirators

Ear protection

Face shields Safety hat

Housekeeping

1. Materials, including scrap and debris, shall be piled, stacked or placed in a container in a

manner that does not create a hazard to an employee. All places of employment, aisles, passageways, storerooms, and garages shall be kept clean and orderly.

2. Garbage shall be placed in a covered container. Container contents shall be disposed of at

frequent and regular intervals.

3. The floor of a work area, passageway or aisle shall be maintained in a manner that does not create a hazard to an employee, free of accumulations of scrap, debris, water, oil, grease and other slip and trip hazards.

4. All storage areas shall be kept free from accumulation of materials that constitutes hazard

for fire, explosion, or pest harborage. 5. The maintenance workshop must be kept clean and organized at all times in a manner that

does not create a hazard to any persons entering that area.

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Clothing Proper attire and protective devices will be worn at all times and when a potential hazard exists, such as Gloves

Ear protection Safety hat

Respirator Face shields Eye protection

Operation and Use of Equipment 1. All tools and equipment shall be stored and used in a manner to prevent damage that would

make the equipment unsafe for use. 2. All tools and equipment shall be inspected by the employee before use and when found

defective; it shall be removed from service. 3. Safety devices and operation controls shall not be made inoperative. 4. All electrical equipment must be disconnected from the power source when not in use. 5. During maintenance of equipment, the equipment will be shut down with the spark plug

removed and the electrical equipment disconnected from the power source. 6. Prior to operation, all areas will be thoroughly policed for any object or bystander

presenting a safety hazard or problem. 7. A riding vehicle should not carry a passenger other than operator. 8. Equipment shall not be left running unattended if the operator is beyond vision or more than

25 feet away from the equipment. Before leaving the operators position, shift the transmission to neutral, set the parking brake and disengage attachment clutch. Keys must be removed anytime equipment is shut down.

9. No tools or equipment will be left on the grounds unattended.

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Fire Safety

1. All gasoline shall be placed in appropriate enclosure away from heat or electrical source.

2. Each garage/workshop should maintain a proper number of operative

extinguishers.

3. Extinguishers will be checked/charged annually, or after use. All employees must sign the acknowledgment form as receipt of this procedure. Refer to form 2.22 INJURY OR LOSS AND INCIDENT REPORTS Where damage or injury occurs, take immediate steps to preserve all document, electronic, photographic, or video surveillance evidence. If possible, take pictures to substantiate any claim for unit damage. Within 12-hours of an incident, make a copy of any video surveillance. The security video terminal preserves surveillance video for 30 days. After the 30-day period expires, the digital video data is “recorded over” in an effort to save and recycle computer memory. Do not delete or destroy any electronic information, including but not limited to computer files, electronic documents, or emails. IMS respectfully requests that its employees refrain from making any statements. All inquiries should be directed to IMS Corporate. Statements disseminated without prior approval do not represent the opinions or views held by IMS and its employees. INVENTORY & SHOP ORGANIZATION A current inventory of equipment for the Rental Office and the Maintenance shop is to be maintained always, with semi-annual revisions sent to the Property Manager. The maintenance staff at each property is required to maintain a clean and organized shop at all times. Site managers are expected to inspect the maintenance shop daily. PURCHASING PROCEDURES Purchase Orders are required for all operational expenses. The Site Manager is required to submit to the Purchasing Agent, for approval before incurring the expense, a purchase order including quantity, description, and prices of proposed items to be purchased. Under no circumstances are orders to be placed without prior approval by the purchasing agent.

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AFTER HOURS EMERGENCY PROCEDURES IMS is obligated to provide, through site employees, emergency services after normal business hours. Emergencies requiring immediate action are generally defined as follows:

• No heat • Plumbing leak or malfunction • Fire • Lock out • Electrical malfunction • Break-in, including broken windows/doors • Natural disaster

Residents make contact with the property answering service. The answering service will contact the person on call. If the on call person does not respond to the answering service within 30 minutes, then call will be forwarded to the Site Manager from the answering service for action. Upon the on call maintenance staff member’s arrival to the site, they should punch in and immediately proceed to the location of the emergency call (unless the call is of an extreme nature). Once the emergency call is resolved, then the maintenance staff member should immediately punch out. On the next business day, the on call maintenance staff member must report the call to the site manager. The Site Manager shall execute a work order and attribute travel time to the employee.

Snow Removal Policy: Every employee must adhere to the Independent Management Services, Snow Removal Policy. This policy must be signed by all maintenance staff and returned to your Site. Refer to form 2.20.

Answering Service and “On Call” The answering service is to be provided with emergency telephone/pager numbers. In the event of an emergency, the answering service is to contact the maintenance person on-call, who is required to respond within 30 minutes of initial contact to learn facts surrounding the emergency call, and to immediately take appropriate action. The answering service is to be instructed that, should the maintenance person on-call fail to respond within 30 minutes of initial contact, the Site Manager is immediately contacted. If the Site Manager is unavailable, the Property Manager is to be contacted. The Site Manager is responsible for ensuring that the answering service has, at all times, a listing of contact telephone numbers, including corporate officers in the even that this communication system fails.

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Whenever a maintenance person responds to an emergency after-hours call, he or she is required to record the nature of the INCIDENT in detail, and the time spent in corrective action. That information is to be reported to the Site Manager at one of the following times, whichever is appropriate:

1. First Business Day Following The Incident:

Lockouts, No heat, Plumbing, Broken doors or Windows. Under no circumstances is cash to be accepted by any IMS Staff.

2. Immediately:

Fire, Nature Disaster, or any other uncontrollable situations. Note: The Property Manager is to be immediately contacted.

Unforeseen emergencies may occur occasionally, which are not described herein. If there is any doubt how to handle an emergency, the Site Manager and/or Property Manager should be contacted immediately. DISASTER PLAN Fire safety can be improved through a comprehensive plan of action for use in emergencies. This plan includes provisions for the evacuation of a building(s). The plan is prepared to define IMS policies and procedures that are to be observed when challenged by that of a disaster. Become familiar with this plan and make necessary preparations so that a disaster does not become unmanageable.

Preparation

1. An emergency phone number list including;

Manager Fire Department Police Electric Company Gas Company Water Company IMS Property Managers

Note: A copy of the list should be kept in each: the management office, the maintenance shop (if

in remote location), the manager's home and the home office. This list should be reviewed monthly.

2. A list of potential emergency vendors. Contact them for specifics of their trade,

including; a. Hours available b. Prices

This is especially critical when a property needs immediate protection from weather or vandalism.


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3. All apartments should be secured immediately (when possible) after a forced entry.

4. The doors of all handicapped persons should be clearly identified and a list of those

residents including apartment number should be maintained in the office.

Training

Property staff should conduct a meeting once each quarter for the purpose of presenting a refresher course in disaster plans. The meeting should include:

Individual Responsibilities Limits of authority An evacuation plan.

1. Staff members should be prepared to call the fire department in the event a fire is detected.

The Site-Manager is in charge of:

a. Directing the evacuation of building(s), if necessary. b. Securing the buildings when needed.

c. Shutting off gas, if necessary. d. The Property Manager is responsible for coordinating action with the Fire

Marshal (or chief), police, building inspectors, Red Cross and the news media. 2. Staff members do not have the authority to make a commitment on behalf of the company to

pay for any lodging, personal assets or agree to rent concessions. No contracted work should proceed without specific authority from the main office, except in emergency situations. The Site Manager will coordinate restoration with the main office.

3. All personnel will be thoroughly acquainted with the "Evacuation Plan", which should be

reviewed at each quarterly staff meeting.


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DISASTER PLAN (CONTINUED) Emergency Procedures

1. The Property Manager should be contacted immediately in the event of an emergency. (Assuming the fire department has already been contacted and evacuation has begun.)

2. If possible, inform the staff of the scope of the disaster to enforce proper procedures.

3. Do not allow anyone in the area until after the fire chief has completed his

investigation.

4. Call the utility companies to shut off service if needed.

5. If any part of the alarm system has been rendered inoperable, call the Alarm Company for repairs. If it remains inoperable, secure a "fire watch" for maintaining fire security 24 hours per day.

6. If a city official or Fire Marshall renders the building unsafe due to not having a

proper alarm system, obtain a written notice to that effect.

7. Review current "Rent Roll" to ascertain where displaced persons may be located. Maintain a copy of the "Rent Roll" of the apartment(s) that cannot be occupied due to the disaster. The Property Manager must approve any rent concession(s). Keep accurate records of move-ins and move-outs during the reconstruction period so proof for the insurance claim will be available. Any resident relocating to a vacant apartment should execute a new lease and be changed in the computer. The same should be done when the resident returns to their original apartment.

8. Organize property restoration promptly. Remnants of the disaster should be removed

from view of the public as soon as the insurance representative has inspected the site and the main office has given approval.

9. Secure bids as directed by the Property Manager. All proposals must be in writing.

The property is in a vulnerable position when any disaster occurs and unfortunately some vendors will take advantage of the situation. No one should begin work without a signed contract.

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DISASTER PLAN (CONTINUED)

Emergency Evacuation Plan The evacuation plan is to provide information to residents (and all employees) with emergency procedures. This evacuation plan is an integral part of the indoctrination process for residents and employees of an IMS managed property. The objective is the safety of all persons who may be working, living, or visiting the building(s). The best form of protection from fire is prevention. Fires can be caused by a smoldering cigarette, portable heaters left unattended, or overloaded electrical outlets and extension cords, etc. These types of fires should be watched for and guarded against.

1. Once a fire is detected:

a. Call the Fire Department b. Attempt to extinguish fire c. Begin evacuation of building, if fire is out of control.

2. Locate exit doors:

a. Employees should be well acquainted with all fire exits.

3. Locate fire-fighting equipment:

a. Employees must be properly instructed in using fire extinguishers 4. Flow of traffic:

a. The only means of egress in an emergency shall be the stairwells. When evacuating, each person should proceed as quickly as possible to one of the exit doors opening into the stairwells. Before leaving the building it is important that doors be closed to prevent the spread of fire through open spaces. It is imperative that occupants evacuating the building through stairwells remain calm and proceed at a pace which will not create a hazard to others.

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DISASTER PLAN (CONTINUED)

5. Elevators:

a. Elevators will not respond once alarm is activated. DO NOT ATTEMPT TO

USE THE ELEVATORS IN CASE OF A FIRE. Upon receiving notice of a fire, the building engineer is to assess the severity of the fire and assist in the evacuation.

6. Fire Detection:

a. Damage by fire is best prevented through early detection and extinguishment. Extinguishing a fire in the early stages could be the difference between life and death to the occupants and visitors of the building(s).

b. Upon the discovery of a fire, smoke or a condition in which the possibility of fire

is eminent, one should immediately contact the fire department and then attempt to extinguish it to the extent practical without endangerment. If you suspect the fire to be serious, proceed to evacuate the building. Stifle panic among residents.

7. Emergency Evacuation Teams:

a. Residents are encouraged to set up emergency evacuation floor teams. The team's responsibility would be to see that all persons are instructed in evacuation procedures as explained in this manual and to keep a list of persons on that floor who may need assistance in descending the stairs. A responsible person should be designated the Floor Leader to coordinate the above functions and to maintain the proper updated lists.

Elevator buildings are required to produce two (2) Fire Safety Plans. One is to be issued to each of your residents with a map attached directing each resident from their homes to a prearranged meeting site. The second plan should be issued to your local fire department when necessary. Refer to the Sample Fire Safety Plan Form 2.21.

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INSECT AND PEST EXTERMINATION IMS requires all apartments to be exterminated on a regular basis. Such areas to be treated are:

Kitchen: All cabinets and drawers Bathroom: All cabinets, drawers and closets Closets Fish tanks and birdcages should be completely covered.

Extermination is required and cannot be refused. Housekeeping habits, which can cause or contribute to “pest problems”, will not be tolerated for the benefit of all residents. Failure to have the apartment treated will result in a $30.00 fine per occurrence. A sample extermination notice is found in Form 2.9 to aid in the extermination effort. The frequency and quantity of units to be exterminated on a monthly basis should be recommended to the Property Manager upon determining the extent of any pest problems through regular unit inspections.

Bed Bugs Procedures In a constant effort to combat bed bugs and ensure that your residents have safe, clean and comfortable housing, Independent Management Services requires to you follow several actions:

Continually inspect units for bed bugs by your professional pest control contractor as well as in-house staff.

When bed bug presence is discovered, treatment of the unit; and in some cases the units on either side, will need to be scheduled.

Treatments can consist of steaming all visible bugs, vacuuming visible bugs with a chemically-treated vacuum bag, liquid residual chemical treatment over the entire unit including all cracks / crevices and residual material placed in wall voids to help prevent re-infestation.

Treated units are to be inspected and/or re-treated regularly until the issue has been resolved.

Tenants will need to be given a date and time of service and a preparation checklist. As we realize tenant preparation is key to eradicating bed bugs, we strictly enforce lease violations and assess relevant fees to the residents for not properly preparing for treatment.

In an effort to control the spread and to more effectively treat bed bugs, supply residents with box spring and mattress covers as well as continue training on bed bug preparation and prevention.

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Notes:

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Chapter 3

PERSONNEL MANAGEMENT We are an Equal Opportunity and Equal Access Employer and do not discriminate regardless of race, color, religion, sex, national origin, age, disability or genetic information. We intend to build a team of individuals, who are self-motivated, willing to learn and grow with our firm. Your progress, training, experience, motivation, attitude and goals may create many possibilities for career opportunities with Independent Management Services. We progressively uphold a professional management team in order to serve our clients, enhancing our management skills and capabilities.

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Chapter 3, Personnel Management

© 2016 Independent Management Services/Independent Management Services Procedures Manual Release 07/2017

3-2

A. INTRODUCTION

101 Introduction 102 Other Applicable Polices 103 Open Door Policy 104 Communication & Staff Meetings 105 External Communications 106 Legal Notices & Local Counsel

B. LABOR LAW COMPLIANCE 201 Americans with Disabilities 202 Authorization under HIPAA 203 Conflict of Interest 204 Confidentiality & Proprietary Information 205 Equal Employment Opportunity 206 Unlawful Harassment 207 Social Security Privacy Act 208 Reporting Misconduct 209 Retaliation Prohibited C. EMPLOYMENT STATUS & RECORDS 301 At-Will Employment 302 Employment Classifications 303 Marketing & Advertisements 304 Employment Applications 305 New Hires 306 Orientation Period 307 Performance Reviews 308 Personal, Wage & Worksite Changes 309 Employment Information Requests/ Reference Checks D. WORK & PAY POLICIES 401 Business Hours, Rest & Meal Periods 402 Workweek & Pay Days 403 Payment Methods 404 Timekeeping 405 Overtime 406 Lactation Breaks 407 Payroll Deductions 408 Administrative Pay Corrections E. EMPLOYEE BENEFITS & TIME OFF 501 Benefits & Benefit Eligibility 502 Holidays 503 Vacation, Personal & Unpaid Time 504 401 (K) Participation 505 Health Insurance Benefits 506 COBRA Continuation 507 Workers’ Compensation Insurance 508 Off-Duty Activities

F. LEAVES OF ABSENCE 601 Family & Medical Leave Act 602 Military Leave 603 Maternity Leave 604 Bereavement 605 Voting & Jury Duty 606 Victims of Crime & Witness Leave

G. EMPLOYEE CONDUCT 701 Attendance and Punctuality 702 Corrective Action Policy 703 Company Property 704 Office Technology, Email & Internet Usage 705 Inspections, Searches & Seizures 706 Video, Audio & Electronic Surveillance 707 Relationships in the Workplace 708 Contracts, Monies, and Usages of Names 709 Emergency Closing 710 Outside Employment 711 No-Solicitation/No Distribution 712 Personal Appearance and Dress Code 713 Personal Property 714 Smoking in the Workplace 715 Working from Home H. EMPLOYEE SAFETY

801 Safety in the Workplace 802 Driving and Vehicle Usage 803 Drug and Alcohol Use 804 Workplace Violence Prevention I. SEPARATION OF EMPLOYMENT 901 Resignation, Termination and Discharge 902 Return of Property J. SIGNED ACKNOWLEDGEMENTS 1001 Video Surveillance Release 1002 Off-Duty Activities Release 1003 Release of Corrective Action Documents 1004 Acknowledgement/Receipt of Understanding



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SECTION A: INTRODUCTION

101 - Introduction Below we explain our procedures regarding employment. Every employee is employed “at-will.” This means, the employment relationship may be terminated at any time, by either the employer or employee, with or without cause, for any reason or no reason whatsoever. No employee is authorized to cause the company to assume any greater employment obligations, except only in a separate written agreement which specifies the terms of employment and is signed by the President after approval of the Board of Directors. Such a separate written agreement shall bind the company to employ a person for any given length of time and in accordance with other provisions set forth therein, the terms of which may only be modified through a similarly executed writing. We retain the right to unilaterally change, modify, suspend, interpret, or cancel, any policy or procedure without advance notice or cause. We may also issue workplace rules consistent with this Handbook. The Handbook supersedes any and all representations made to you about your employment and rescinds any and all prior employment procedures previously in effect. Recognition and observance of all the procedures herein is a condition of employment and continued employment. Please ask questions if you do not understand. A current copy of and any changes or updates to our procedures may be accessed through IMS Tools. 102 - Other Applicable Procedures Other office procedures are contained in Chapter 1 and Chapter 2. Please review these Chapters, as well as the entire Procedures Manual, to ensure familiarity with our office, safety, and compliance procedures. 103 - Open Door Policy When employees deal openly with each other and Management, the work environment is more positive. Please share your concerns, provide input, and feel free to resolve concerns through honest, open, and respectful dialog. Opinions may be expressed without fear of retaliation and will be kept confidential to the extent possible. 104 - Communication & Staff Meetings Site Managers are expected to communicate with all site employees daily. Informal meetings with the entire staff are required at the beginning of each day; typically, from 8:00 a.m. to 8:30 a.m. These meetings provide an opportunity to discuss problems, goals, productivity concerns, worksite safety hazards, accident investigations, inspection results, and work assignments.



3-4

105 - External Communications Only authorized agents may speak on our behalf. If you are asked to make a statement to any third party on our behalf, including media, government agency, law enforcement, employee references, etc., direct the requesting party to Corporate. Do not contact government agencies on behalf of the company. If you sign any legal documents related to your employment, you have an obligation to forward a copy to your Supervisor. Statements disseminated without prior approval do not represent the views held by our company and its employees. 106 - Legal Notices & Local Counsel If you receive a legal demand, immediately notify your Supervisor. All non-eviction legal work will be handled by Corporate. If there is a deadline for response, calendar the date and follow up to ensure the situation is being addressed. All legal questions should be first directed to your Supervisor. Legal proceedings may be referred to local counsel. You are expected to cooperate fully. If you have a concern regarding local counsel, contact your Supervisor. Changes in legal counsel must be approved by Corporate. SECTION B: LABOR LAW COMPLIANCE

201 - Americans with Disabilities We observe the Americans with Disabilities Act (ADA) and its amendments. We comply with all federal and state laws concerning the employment of persons with disabilities. We do not discriminate against qualified individuals with disabilities with regard to application procedures, hiring, advancement, discharge, compensation, training, or any other condition of employment. We are an equal opportunity/equal access employer. Request for Reasonable Accommodations We accommodate ADA-qualified individuals provided that such accommodations do not constitute an undue hardship or prevent performance of the essential functions of your position. Accommodations must be requested by notifying your Supervisor in writing. See ADA Request for Accommodations, Form 3.201(1). Failure to give timely or adequate notification may result in denial. For all non-obvious impairments, a medical provider must verify each impairment. See ADA Statement of Physician, Form 3.201(2). For eligibility information, consult the Workplace Notice Poster located in the office, break room, or other similar area. Michigan Worksites Only: You must advise the company in writing of your need for a disability-related accommodation within 182 days after the date you knew or reasonably should have known that an accommodation was needed.



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202 - Authorization Under HIPAA In accordance with the Health Insurance Portability and Accountability Act (HIPAA), authorization may be necessary to obtain Protected Health Information (PHI). See Authorization to Disclose PHI, Form 3.201(3). In response to any accident investigation, you must complete this Authorization, if requested. Refusal to do so may result in termination. In response to employee-requested benefits, refusal to release necessary PHI may delay or prevent authorizing the requested benefit. Comply with requests for medical information promptly. 203 - Conflicts of Interest Avoid situations in which the company’s loyalty is divided between you and another person/entity. Where a conflict may exist, or have the appearance of existing, promptly disclose the conflict to your Supervisor. A conflict occurs when you are in a position to influence a decision that may result in personal gain for yourself, a relative, or friend. Examples include:

Financial interest in or other relationship with a competitor, customer, or contractor. Working independently for or accepting gifts from a competitor, customer, or contractor. Personal discounts/special consideration from a competitor, customer, or contractor. Taking any job appointments in direct competition with our business objectives.

If you question whether your conduct creates a conflict, contact your Supervisor. Conflicts may be consented to upon written permission from a Corporate Officer. 204 - Confidentiality & Proprietary Information You will learn confidential information, including but not limited to customer and contractor information, industry specific techniques, financial data, addresses, social security or FEIN numbers, and non-public proprietary employer, customer, and contractor information. Do not disclose confidential information to unauthorized persons. Always handle confidential information with care. Inform your Supervisor immediately upon becoming aware that confidential information has been, or is in danger of being disclosed in an unauthorized or unlawful manner. You may be required to enter into a confidentiality agreement as a condition of your employment. 205 - Equal Opportunity Employer We are an equal opportunity and access employer committed to a culturally diverse workforce. All qualified applicants will receive consideration for employment without regard to race, religion, color, creed, age, height, weight, sex, national origin, sexual orientation, gender identity, genetic information, disability, marital or veteran status, or any other characteristic protected under applicable federal, state or local law.



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206 - Unlawful Harassment Harassment is conduct that denigrates or shows hostility toward an individual that has the purpose or effect of creating an intimidating, hostile, or offensive environment. Sexual harassment is defined as unwanted sexual advances or conduct of a sexual nature. Examples include:

Offering benefits in exchange for sexual favors. Making or threatening reprisals after a negative response to sexual advances. Sexual gestures or the displaying of sexually suggestive objects/images. Derogatory or racial comments, epithets, slurs, jokes, profanity, or foul language. Sexual or graphic verbal or written statements. Touching, assaulting, or impeding or blocking movements.

This policy applies to all applicants and employees as well as our customers, affiliates, and vendors. Prohibited conduct is unacceptable in the workplace and in any work-related setting, such as business trips, meetings and social events. Our anti-harassment/discrimination policies apply to all forms of technology.

Complaint Procedure Report any harassment or discrimination to your Supervisor or Superior. Do not wait. You are not obligated to disclose any information to your Supervisor before bringing the matter to the attention of another Superior. Management should forward any harassment or discrimination information to Corporate immediately. We will investigate all reports. Complaints may be made without fear of retaliation and will be kept confidential to the extent possible. 207 - Social Security Number (SSN) Privacy SSNs are confidential and must be disposed of in accordance with the following:

Disclosure: Do not use SSNs to identify employees. After use as required by applicable law, and if potentially visible to unauthorized persons, the first 5 digits of the SSN must be redacted using permanent marker.

Access: Access shall be limited to employees conducting business operations in which the SSN is required. Retained documents shall be kept in secure storage and not freely accessible by unauthorized individuals.

Disposal: If the document is a necessary business record, the first 5 digits of the SSN

must be redacted using permanent marker. All other documents baring SSNs shall be destroyed using a cross shredder.



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Exceptions to disposal include use authorized or required by a federal or state law, by a court order or rule, or pursuant to legal discovery or process and for administrative purposes, if in the ordinary course of business, to:

Verify identity related to an account, transaction, product, service, or employment; Investigate an individual’s claim, credit, or criminal or driving history; Detect, prevent/deter or identify a crime such as identity theft; Pursue a legal right, such as an audit, collection, investigation, transfer of a tax, employee

benefit, debt, claim, receivable, or account; Investigate, collect, or enforce a child or spousal support obligation or tax liability; or Provide or administer employee, health or membership benefits, claims, or retirement

programs or to administer the ownership of shares of investment such as stocks. All equipment shall be cleaned and SSN information shall be rendered irretrievable before the equipment is discarded. Employees found violating this policy may be subject to corrective action including termination. 208 - Reporting Misconduct We will not discharge, threaten, or discriminate against you for reporting a violation or suspected violation of law to local, State, or Federal officials. Nothing in our policies or procedures is intended to curtail protected communications about or criticism of management, labor policies, or working conditions. You will not be terminated, demoted, or penalized, provided that your report is not recklessly or knowingly false. 209 - Retaliation Prohibited

If you report or participate in an investigation of any kind, you will not be subject to retaliation. We ensure that a person against whom an allegation of wrongdoing is made will be treated fairly and a thorough investigation is conducted. Complaints or participation in an investigation shall be treated with the maximum degree of confidentiality to the extent possible. SECTION C: EMPLOYMENT STATUS & RECORDS

301 - “At-Will” Employment Every employee is employed “at-will.” The employment relationship may be terminated at any time, by either the employer or the employee, with or without cause, for any reason or no reason whatsoever. 302 - Employment Classifications These classifications do not alter the “at-will” employment relationship. The right to terminate the employment relationship at will at any time is retained by both the employee and employer.



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FULL-TIME employees are those that have successfully completed 90 days of full time employment and who regularly work a minimum of 40 hours per week. PART-TIME employees regularly work less than 40 hours per week. Unless otherwise mandated by federal or state regulation, part-time employees receive legally mandated benefits (e.g., Social Security and worker’s compensation insurance). Employees who average 30 or more but less than 40 hours per week are eligible for benefits after 90 days of continuous employment. Part-time employees are subject to the limitations of each benefit program including earning of paid time off based on a pro rata rate of average hours worked. Such employees will also receive other company benefits at a prorated rate where applicable.

INACTIVE employees are on any form of an unpaid leave. Fringe and other leave benefits terminate after 30 days of continuous inactive employment. For certain qualifying leaves of absence, we will preserve your insurance benefits and employment position. Thereafter, if you are still unable or unwilling to perform your job duties, and your position is unable to be held open, you will be discharge and all benefits will terminate. INDEPENDENT CONTRACTORS are not employees, but provide services. For example, plumbers, electricians, security guards, landscaping, and snow plow contractors. Independent Contractors are ineligible for benefit programs, insurance, or employment benefits.

303 - Marketing & Advertisements Contact your Supervisor if you would like to recruit applicants. All ads for marketing, including apartment rentals and help-wanted, must have prior approval from your Supervisor and a Corporate Officer. That is, the exact language you intend to publish must be written into the Purchase Order, and be signed by a Corporate Officer. 304 - Employment Applications All applicants must review and/or complete:

Employment Application Form 3.304(1) General Job Descriptions Form 3.305(2)

Applicants must be endorsed for hire by Management prior to hiring. Final selection for hiring is a joint decision based primarily upon the Supervisor’s recommendation confirmed by Management. Once a candidate is selected for contingent employment, a copy of the Driver’s License shall be obtained and forwarded to Corporate for background check purposes. Applicants will have an opportunity to explain any criminal history. For positive background checks, we must conduct an individualized (case-by-case) assessment considering the nature and gravity of the history, the time that has elapsed, and the nature of the position sought in light of the position applied for and our business necessity.



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For certain positions, an aptitude test may be used to gauge knowledge and experience (e.g., Maintenance Test, Form 3.304(2)). Although tests cannot be relied upon as an ultimate determination of employment, it is an accurate representation of an applicant's knowledge gained through experience. To encourage the growth and continued education of all our team members, employees may be eligible for financial assistance for training and certification after 1 year of continuous service. In support of each request, the applicant must have recommendations from each supervisor responsible for the employee’s performance including any direct supervisor, regional manager, and corporate manager. See Training Agreement Policy, Form 3.304(3). Drug testing, criminal history, and background authorizations are required. A medical examination may also be required. You may be offered an employee unit as a part of your overall compensation package. See Employee Accommodations Agreement, Form 3.304(4). This must be included with the complete employee package submitted. The employee will be required to give up the unit upon termination of employment status. Any employee considered for occupancy in any of the units must go through the same application process as any tenant. 305 - New Hires Newly hired employees must review and complete:

New Hire Packet Form 3.305(1) General Job Descriptions Form 3.305(2)

Employment Eligibility Verification Form I-9 requires that you present documentation establishing identity and employment eligibility prior to your start date. Prior to the day of hire, the New Hire Packet, I-9 verification documents, and Social Security Card should be immediately delivered to Payroll. As part of the New Hire Packet, review the following information to ensure completeness and accuracy:

Wage/withholding information. Insurance enrollment or waiver.

Designated sections must be initialed. Signed Acknowledgment is complete.

Before the first payroll check is issued to the new employee, a Corporate Officer must sign the New Employee Certification Sheet. During training, your Supervisor will review the Procedures Manual, discuss our corporate structure, and describe your employment responsibilities. You will be given a tour of the worksite and introduced to your next immediate Superior and coworkers. Orientation meetings should be held the second and third weeks of employment to discuss progress, address problems, and offer encouragement. 306 - Orientation Period During your first 90 days, your Supervisor will review procedures with you. This initial period gives us the opportunity to get to know you, your skill set, and whether you are well suited for the position. During the Orientation Period, you are not entitled to any of the benefits, privileges,



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or protections set forth herein unless required by applicable law. Completion of Orientation does not guarantee continued employment, your “at-will” employment status continues during and after this period. 307 - Performance Reviews Performance evaluations for all employees are conducted annually. See Employee Evaluation, Form 3.307(1). After the evaluation is approved, Site Managers will conduct an evaluation interview with an employee to discuss the employee’s strengths and weaknesses while utilizing the Performance Evaluation Form. The evaluation will be reviewed and signed by a Corporate Officer prior to the evaluation interview. Following the interview, the evaluation is to be signed by the Site Manager and by the employee, with copies to the employee, the employee’s personnel file, and the Property Manager. Evaluations are to be taken very seriously, and will provide an opportunity for both the manager and the employee to recognize the value of the employee as an individual. It is also very important to stress the impact each employee has on reaching the financial goals of the property. Careful consideration should be given to each evaluation category, and the manager should objectively reflect upon the employees' attitude and performance during his/her tenure. It is important to remember that each employee has unique personality characteristics, which if accentuated, will normally result in positive contributions toward the ultimate success of your team leadership. The primary function of the evaluation interview is to ensure that the employee understands that his/her value as a member of this organization is recognized and appreciated. This is especially important because budget constraints will not always permit monetary compensation in direct proportion to the employee's perception of his/her commercial value. Therefore, we must draw upon our resources to provide our employees with intangible compensation in the forms of recognition, appreciation, loyalty, and job security, to the extent practical. An equally important function of the evaluation interview is to convey to the employee a clear understanding of areas of needed performance improvement. Both written and verbal comments should be honest, objective, and constructive in nature. The manager must ensure that all points are made without monopolizing the interview conversation and encourage the employee to engage in open communication regarding any work-related topic. Finally, the evaluation interview should serve as a foundation for establishing long and short-term goals for both parties. Prior evaluations may be used as a gauge to monitor progress. 308 - Personal, Wage & Work Changes Immediately inform your Supervisor and Payroll in writing of any changes in personal information. Employee information changes must be reflected in the On-Site Employment Information Sheet. See Form 3.308(1). Management will complete wage adjustments via the Employee Wage Adjustment Request. See Form 3.308(2). Updates will be completed as soon as possible. Changes in work location or job transfers must be processed with the Employment Change Authorization, Form 3.308(3).



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309 - Employment Information Requests/Reference Checks Third-party information requests regarding current or former employees must be directed to Corporate for response. We only release information when required by court order, a government agency, or pursuant to an employee’s written request for the release of information. SECTION D: WORK & PAY POLICIES

401 - Business Hours, Rest & Meal Periods Normal business hours are from 8:00 a.m. to 5:00 p.m. Monday through Friday. Employees must show up to work not under the influence of alcohol, illegal drugs, or legal drugs that impairs your ability to perform your job duties. Employees scheduled to work a regular full-time schedule of 8 hours per day and 40 hours per week are provided a 1 hour unpaid meal period, normally from 12:00 noon to 1:00 p.m. We do not permit paid meal breaks or rest times unless required by applicable law. During a meal period, you may leave the job site or remain at your work station, but you are not permitted to work. You may not alter your work schedule by working through the unpaid meal period, unless the Overtime Policy is complied with to ensure wage and hour compliance. Review your timecard daily and report any mistakes immediately to your Supervisor. Sleeping or personal leisure hobbies are not permitted during working hours. It is Management’s exclusive right to establish work schedules, approve Leave, or change meal/break times. To the extent possible, we will give reasonable notice when work schedules are modified because of operational needs or weather conditions. Direct all questions regarding work schedules to your immediate Supervisor. California Worksites Only: Full time employees will receive a 15-minute paid rest break in the morning and afternoon. You are required to punch when you start and end the break period. All other business hours, rest, and meal period policies remain unchanged. 402 - Workweek & Paydays The workweek begins each Friday at 5:01 pm and continues through the following Friday at 5:00 pm. Paydays are every other Friday. In the event that a regular scheduled payday falls on a holiday, you will be paid no later than the next business day after the holiday. 403 - Payment Methods We offer pay by direct deposit or pay card. In limited circumstances, and if required by applicable law, you may receive a paper check. Where applicable law provides, acceptance of a particular method of payment is not contingent on employment. See New Hire Packet, Form 3.305(1) or specifically the Electronic Payment Request, Form 3.403(1).



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To receive your pay by direct deposit, you must designate a participating financial institution. Your pay will be deposited into your designated account each payday and a written explanation of deductions will be accessible to you. See Employee Login Instructions, Form 3.403(2). If you fail to elect a payment method, your pay is deposited into a pay card account. Funds are accessed through a card similar to a debit/credit card and through participating ATMs. Limited charges may apply. You will receive one free transaction which you may use to withdraw or transfer money. You should receive a copy of the terms and conditions of a pay card account. If you do not receive these immediately upon hire, please contact Payroll. 404 - Timekeeping Accurately recording time worked is the responsibility of every employee. “Time worked” is time spent physically at a worksite performing assigned duties during business hours and for certain employment-related travel. Overtime must always be approved and working from home is strictly prohibited. See Overtime Policy, Section 405. To track time worked, we utilize a computerized web-based timekeeping system. Employees may only access the system using authorized devices. Use of any other device is prohibited. Accessing the timekeeping website via an unauthorized device will be grounds for termination. For Management’s convenience, the IP Address (or tracking number) for each device is recorded and may be reviewed upon written request to Corporate. Employees are expected to arrive at the worksite at or near the scheduled starting time and leave as soon as possible after the end of a shift. Employees should accurately record the time they start (“punch in”) and end (“punch out”) work. You may not start working until 8:00 a.m. and must stop working at 5:00 pm. Arriving earlier or leaving later than scheduled will not be considered “time worked” and shall be kept to a minimum. You may not alter the work schedule by working through the unpaid meal and rest periods, unless the Overtime Policy is observed. Attempting to earn overtime through repeatedly punching in at times that cause unauthorized and unnecessary overtime may result in corrective action including termination. You should also record the beginning and ending time of any split shift or departure from work for personal reasons. If you leave work for any non-employment related reason, including unpaid meal periods, you must “punch out” when leaving and punch in when returning to the worksite. When not “punched in,” nonexempt employees may not work. If an employee works outside normal business hours at his/her own initiative or at a Supervisor’s request, or fails to punch in or out, the employee will be subject to corrective action including termination. Site and Property Managers may only edit punches for missed punches, technical errors, or time clock malfunctions. Edits must reflect time worked and may never be used to reduce time worked to avoid overtime. All timecard edits must electronically note the reason justifying the modification (select the “Note” option within the timekeeping software) and will be reviewed by Superiors weekly.



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Altering, falsifying, tampering with time records, or recording time on another employee’s time record may result in corrective action including termination. Punching in for another employee, falsification of any time record, or sharing your Timekeeping Code with another employee is strictly prohibited and may result in termination. 405 - Overtime Nonexempt employees must be paid for all time worked. Overtime compensation is paid to nonexempt employees in accordance with applicable law at a rate of time and one-half for all hours worked in excess of 40 hours in a given week. If a nonexempt employee works more than the typical 8 hours per day during the week, there will be an overtime decision that must be resolved by either:

1. Reducing the employee’s hours within the same work week or day, or 2. Paying the overtime hours.

Employees may not direct their own overtime. All overtime must receive an immediate Supervisor’s written authorization and prior Corporate approval, except for emergencies or unavoidable situations when prior Corporate approval is impossible. Under no circumstances is any employee allowed to carryover overtime hours from one week to another week. Oral or side overtime agreements permitting the carrying over of overtime hours are illegal and will be grounds for immediate termination. Overtime assignments will be distributed as equitably as practical. Overtime pay is based on actual hours worked. Time off on vacation, bereavement leave, or any other paid or unpaid time off will not be considered hours worked for the purpose of calculating overtime. Working from home is strictly prohibited. Nonexempt employees must not access or answer job related emails or otherwise conduct business outside of working hours unless approved by an immediate Supervisor in writing and with prior Corporate approval. You are personally responsible for ensuring that your daily time worked is accurately recorded on your timecard. Promptly report any discrepancy, such as missing time worked, overtime, working through lunch or after-hours to the attention of your Supervisor so that corrections can be made as quickly as possible. Contact your immediate Supervisor with any questions. California Worksites Only: Overtime compensation is paid to nonexempt employees at a rate of time and one-half for all hours worked in excess of 8 hours up to and including 12 hours in a given 24-hour period and the first 8 hours worked on the 7th consecutive day of work in a workweek. Employees earn double time for all hours worked in excess of 12 hours in any workday and for all hours worked in excess of the 8th hour on the 7th consecutive day of work in a workweek.



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406 - Lactation Breaks When required by applicable law, we will provide a private room and unpaid break time to accommodate the expression of breast milk for infant children up to 1 year of age. The break time should be taken concurrently with other break periods, if possible. 407 - Payroll Deductions Legally authorized payroll deductions include wage garnishments, child support withholdings, Social Security taxes, and applicable federal, state, and local income taxes. Your written authorization may be requested. Eligible employees may authorize deductions from their pay to cover the costs of participation in voluntary programs and benefits. Paycheck stub and payroll information is available on the Employee Web Portal. To the extent permitted by applicable law, we may deduct from your paycheck amounts to recoup wage overpayments, damages to company property, or for your failure to return company property. If you have any questions regarding deductions, consult the Employee Web Portal or contact Payroll. 408 - Administrative Pay Corrections Promptly bring any discrepancy, such as missing time worked, overtime, working through lunch, after-hours time, vacation, or other paid time, incorrect address, or incorrect deductions to the attention of your Supervisor so that corrections can be made in good faith and as quickly as possible. You have a daily responsibility to review, report, and ensure that any mistakes in your timecard record are corrected immediately. A failure to accurately report all hours worked for each week is grounds correction action including termination. SECTION E: EMPLOYEE BENEFITS & TIME OFF

501 - Benefits & Benefit Eligibility Employees who average at least 30 hours per week are provided a wide range of benefits at a prorated rate after 90 days of continuous employment. To receive full benefits, you must work 90 days of continuous full-time employment. Eligible employees may participate in the programs listed below. The following programs are available:

Holiday Pay Vacation, Personal, Unpaid Time 401(k) Participation Health Insurance COBRA Continuation Workers’ Compensation

Family/Medical Leave Military Leave Paid/Unpaid Personal Leave Bereavement Leave Voting & Jury Duty Leave Witness & Victims of Crime Leave



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All paid and unpaid time off is subject to business operational needs. We reserve the right to apply unused benefits and other paid time-off to absences. All leave benefits run concurrently with any state leave benefits where permitted by applicable law unless specifically noted otherwise. For eligibility information, consult our Workplace Notice Poster located in the office, employee break room, or other similar area. 502 - Holidays Eligible employees receive the following paid holidays:

New Year’s Day (January 1) MLK Day (3rd Monday in January) Memorial Day (last Monday in May) Independence Day (July 4)

Labor Day (1st Monday in September) Thanksgiving (4th Thursday in November) Friday after Thanksgiving Christmas Day (December 25)

In rare instances, you may be required to work on a designated holiday. You will receive your current pay rate plus Holiday Pay. Holiday time is paid at the employee’s regular hourly rate. To receive Holiday Pay, you must elect paid time off for or work on the scheduled workday immediately preceding the Holiday and the workday immediately following the Holiday. If a recognized Holiday falls during a paid absence, pay will be provided for the Holiday only. Holiday time is not counted for overtime purposes. If a Holiday falls on Saturday, it is observed the Friday before, and if it falls on Sunday, it is observed on the Monday following unless otherwise notified. 503 - Vacation, Personal, & Unpaid Time Employees earn Vacation, Personal, and Unpaid Time. Such benefits may be elected and are approved through the electronic timekeeping system. Site Management is responsible for approving time off requests and ensuring that appropriate staffing for the property is maintained at all times. We reserve the right to deny time off requests if it interferes with business operations. Subject to the conditions stated below, and with a Corporate Officer’s written permission, paid and unpaid time may be retroactively applied in the event of an emergency or unforeseen situations. We require reasonable pre-notification for all non-emergencies (generally 2 weeks). To help reduce the volume of vacation requests at the end of the year, please have all requests, for the balance of the current year, submitted by October 31st. Granting time off does not excuse an absence for corrective action purposes. Should you fail to designate how your time should be applied, we will apply your benefits in the following manner: accrued time, barrowed time, and unpaid time. Deviation from this policy is strictly prohibited.



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Vacation Time (12 or 17 days/year) Vacation is earned at the rate of 1 day per full calendar month worked, or 12 days per year. Employees with 5 years of continuous employment are entitled to 17 days per year. Vacation accrues the first full month after the Orientation Period is complete and is not earned for a partial month worked. Vacation must be used in the calendar year in which it accrues, but may be borrowed in advance of time earned with a Corporate Officer’s written permission. Before advancing 6 or more consecutive vacation days on or before June 30th of the current year, the employee must enter into an Authorization for Repayment of Borrowed Vacation. The Authorization may only cover the specific hours advance during the vacation period requested. Should you attempt to schedule Vacation to avoid entering into this Authorization, or should it become likely that you will not be able to earn back all time advanced, your Supervisor may require compliance. See Authorization for Repayment of Borrowed Vacation, Form 501(1). Unless otherwise prohibited by applicable law, all borrowed time that is paid but unearned will be deducted from your last paycheck upon separation at the rate the time was advanced. Borrowed time may never be advanced during a leave period. Vacation may not be borrowed in advance where employment separation is likely to occur before the advanced time is earned. Vacation is calculated at the pay rate when the time is taken and does not count for overtime purposes. If approved time falls on a Holiday, you will receive Holiday Pay. Only accrued Vacation time is paid upon termination at the employee’s current rate of pay.

Personal Time (3 days/year for maximum of 30 days) Additional paid time off is earned at the rate of 2 hours per full calendar month worked, or 3 days per year and may be rolled over from year to year for a maximum of 30 days. Personal Time accrues the first full month after the Orientation Period is complete. Personal Time may never be borrowed in advance of time earned and is not paid upon separation.

Unpaid Time Off (5 days/year)

After one year of continuous service, Unpaid Time may not exceed 5 days per year and does not carry over from year to year. Before Unpaid Time may be elected, you must exhaust all unscheduled Vacation and Personal Time. California Worksites Only: Employees who consistently work 30 hours or more will earn 1 hour of paid time off for every 22 hours actually worked including overtime. You may elect up to 12 days off per year. Time may be rolled over from year to year for a maximum of 30 days and must be elected in an increment not less than 2 hours per day. Time will start to accrue on your first day of employment but may not be used until after completion of the Orientation Period. Accrued but unused time is paid out upon separation. Unpaid Time remains unchanged. Part-time Employees: For California employees who work less than 30 hours per week, we will observe the state paid sick leave regulations only. You will earn 1 hour of paid sick time off for every 30 hours actually worked including overtime. You may elect up to 3 days off per year.



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Time may be rolled over from year to year for a maximum of 6 days and must be elected in an increment not less than 2 hours per day. Unused sick leave is not paid out upon separation. Unpaid Time remains unchanged. 504 - 401(k) Participation 401(k) participation is offered every January 1 and July 1 after one year of continuous employment and at least 1,000 hours of service. The 401(k) plan is described in detail in a separate package that is provided to employees as they near eligibility. Part time employees who average less than 30 hours per week are not eligible for benefits with the exception of the one year/1,000 hour requirement. 504 - Health Insurance Benefits We provide health and dental insurance benefits at no cost to you, the employee. Additional dependents and/or family coverage are available for an extra bi-weekly fee. Vision insurance is also available for a minimal cost to the employee. By enrolling in our insurance program, you consent to the automatic deduction of fees from your paycheck for coverage. Please make sure to review and complete the Employer Provided Benefits Notice in your New Hire materials. See New Hire Packet, Form 3.305(1). A packet of information, including all necessary enrollment and waiver forms, will be mailed to your home address at least 30 days prior to completing the Orientation Period. 506 - COBRA Continuation Most employers (those that sponsor health care plans and that have 20 or more employees) are required to offer covered employees and their qualified beneficiaries the opportunity to elect a temporary continuation of health coverage at group rates, when coverage under the plan would otherwise end due to certain qualifying events pursuant to the Consolidated Omnibus Budget Reconciliation Act (COBRA). This rate may include a 2% administrative fee. Examples of COBRA qualifying events include termination, layoff, or leave of absence without pay; death of employee or retiree; divorce or legal separation; and, dependent child no longer meeting eligibility requirements. Either the Company or its health insurance carrier or administrator will provide notice with further information upon the occurrence of a qualifying event. 507 - Workers’ Compensation Immediately notify your Supervisor of any work-related injury so that an Accident Injury Report may be promptly completed. See Accident Injury Report, Form 3.507(2). Failure to report any injury could jeopardize your workers’ compensation claim. For the initial medical appointment on the day of injury, you will be compensated for time missed during your normal work schedule. Upon discharge from a medical facility, immediately notify and provide to your Supervisor any medical information you were provided regarding your injury, work restrictions, or prognosis. Attendance of any subsequent medical appointments are unpaid and should be scheduled during non-working hours to the extent possible.



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If you are receiving workers’ compensation benefits and are not working, you will be deemed inactive. For serious medical conditions that occur within the scope of your employment and cause an extended absence, you will be automatically enrolled in FMLA which will run concurrently with Workers Compensation Leave. We provide 12 weeks of unpaid leave. All accrued paid time off must be exhausted and will run concurrently with FMLA, except in situations where you receive FMLA and benefit payments from a disability insurance plan or workers’ compensation. You will not accrue attendance or seniority credit during any unpaid leave periods. As a result, you will not accrue vacation or personal time during this unpaid leave period. Paid time off may never be borrowed to substitute for unpaid leave. After 12 weeks of continuous inactive employment, we will attempt to hold your position open as long as business operations allow. You will not accrue attendance or seniority credit during unpaid leave periods. If you are receiving benefit payments under workers’ compensation, accrued paid leave may supplement your benefit wages. To start the process, contact your Supervisor. Any incomplete requests, documents, or medical certifications will be immediately returned and missed time will be treated as an unexcused absence. Fringe benefits terminate after 30 days of continuous inactive employment. We will preserve your insurance benefits and employment position during leave. Inactive employment runs concurrently with any FMLA Leave for eligible worksites. Contact your Supervisor to confirm your return to work 2 weeks before your leave period ends. Complete and submit the Intent to Return to Work, Form 3.507(3). As required in the Form, your healthcare provider must certify your ability to resume work including any work restrictions. For active claims, Supervisors must refrain from discussing the status of the claim with you. Management cannot guarantee payment or denial of any claim. You must provide all claim information requested and cooperate in the investigation and processing of any claim. You should direct all questions to your appointed claims adjuster, including questions regarding payment, wages, medical bills, treatment, etc. Employees who fail to comply with our procedural requirements will be subject to our corrective action policy. You are expected to obey safety rules, to exercise caution in all work activities, and to keep your work area neat and orderly at all times. You must immediately report any unsafe condition to a Supervisor. Employees who violate safety standards, cause hazardous or dangerous situations, or fail to report or remedy such situations, may be subject to corrective action including termination. For a list of recommended workplace safety procedures and practices, please consult IMS Tools, Procedures Manual, Chapter 2 - Maintenance Procedures. California Worksites Only: All supervisors and managers are responsible for implementing and maintaining the California Injury & Illness Prevention Program (“IIP Program”). A copy of this IIP Program is posted on IMS Tools. See Procedures Manual, Chapter 3, Personnel Management.



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508 - Off-Duty Activities As condition of employment, and continued employment, you must review and complete:

Release of Claims: Off-Duty Activities Section J SECTION F: LEAVES OF ABSENCE

Leave benefits run concurrently with any federal or state benefits where permitted by applicable law unless specifically noted otherwise. For eligibility information, consult our Workplace Notice Poster located in the office, employee break room, or other similar area. 601 - Family and Medical Leave Act (12/26 weeks unpaid/year) We observe the Family and Medical Leave Act (FMLA) where applicable. Eligible employees are entitled to 12 weeks unpaid leave for family, medical, and military reasons. Eligibility requires that an employee must:

Worked for at least 12 months; Worked at least 1,250 hours during the 12 months prior to the start of leave; and, At least 50 employees are employed at your work location or within 75 miles thereof.

Eligible employees may take up to 12 workweeks of leave in a 12-month period for the following reasons:

Child birth or placement of child with you for adoption or foster care. To care for a spouse, son, daughter, or parent who has a serious health condition. A serious health condition that makes you unable to perform your essential job functions. For any qualifying exigency arising out of the fact that a spouse, son, daughter, or parent

is a military member on covered active duty or called to covered active duty status.

An eligible employee may also take up to 26 workweeks of leave during a "single 12-month period" to care for a covered service member with a serious injury or illness, when the employee is the spouse, son, daughter, parent, or next of kin of the service member. The "single 12-month period" for military caregiver leave is different from the 12-month period used for other FMLA leave reasons. For serious medical conditions that occur within the scope of your employment and cause an extended absence, you will be automatically enrolled in FMLA which will run concurrently with any other applicable leave. All accrued paid time off must be exhausted and will run concurrently with FMLA, except in situations where you receive FMLA and benefit payments from a disability insurance plan providing for wage replacement benefits or workers’ compensation. You will not accrue attendance or seniority credit during unpaid leave. As a result, you will not accrue vacation or personal time during this unpaid leave period. Paid time off may never be borrowed during an unpaid leave.



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To start the process, contact your Supervisor. Leave must be requested 30 days prior to the start of leave or as reasonably practical. Please complete the Leave Enrollment Form, Form 3.601(2). Any incomplete requests, documents, or medical certifications will be immediately returned and missed time will be treated as a non-FMLA absence. After receiving the Leave Enrollment Form, the FMLA Administrator will request certification from you or your healthcare provider. Certifications must be completed and returned within the deadline specified. Your healthcare provider must support the length of the leave noting dates of time off and restrictions. If all certification information is timely returned and complete, the FMLA Administrator will issue a Designation Notice reflecting the decision. Requests may be delayed or denied for your failure or the healthcare provider’s failure to make a timely and complete submission. You must update your Supervisor of your condition and status monthly. Employees electing intermittent leave must follow our normal reporting for work, leaving the work site, and calling off procedures noted in Procedure Manual, Chapter 1 and Chapter 3. Extensions of leave must also be processed through your Supervisor. Please submit medical documentation to support the leave extension along with your request. Your health care provider must support the length of the extension noting dates, weeks, or additional time off and restrictions. Contact your Supervisor to confirm your return to work 2 weeks before your leave period ends. Complete and submit the Intent to Return to Work, Form 3.507(3). As required in the Form, your healthcare provider must certify your ability to resume work including any work restrictions. Fringe benefits terminate after 30 days of continuous inactive employment. We will preserve your insurance benefits and employment position during leave. After 12 weeks of continuous inactive employment, we will attempt to hold your position open as long as business operations allow. At that time, all company-provided benefits will terminate. Employees who fail to comply with our procedural requirements will be subject to our corrective action policy. Depending on your medical condition, you may be entitled to an ADA Reasonable Accommodation. Please be sure to make a written request if you believe you are entitled to additional leave or accommodations. For eligibility information, consult our Workplace Notice Poster located in the office, employee break room, or other similar area. 602 - Military Leave We observe the Uniformed Services Employment and Re-employment Rights Act which provides for unpaid leave for eligible members of the armed services. We will re-employ returning service members in the same job that they attained had they not been absent for military service and with the same seniority, status and pay, as well as other rights and benefits determined by seniority. During the leave period, vacation and holiday benefits will be suspended and will resume upon the employee's return to active employment.



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603 - Maternity Leave (5 days paid and 30 days unpaid/year) Maternity Leave is for prenatal treatment, birth, and post birth recovery. In a 12-month period, you may elect up to 5 days of paid leave and 30 days of unpaid leave. The eligible leave period begins 9 months before your certified due date and continues until 7 weeks post birth. Maternity may be elected intermittently or as a continuous period. Intermittent leave for prenatal treatment and/or medical appointments requires certification of attendance. You must give your supervisor reasonable notice before any intermittent absence. All other attendance policies apply and will be strictly enforced. Where applicable, we may request a medical certification from your physician. Prior to electing unpaid Maternity, you must exhaust all accrued paid leave. Paid Maternity days maybe elected at any time during the leave period. During Maternity leave, job preservation and insurance benefits will continue. You will not accrue attendance or seniority credit during unpaid leave. As a result, you will not accrue vacation or personal time during this unpaid leave period. Paid time off may never be borrowed during an unpaid leave. To start the process, contact your Supervisor. Leave must be requested 30 days prior to the start of leave or as reasonably practical. Please complete the Leave Enrollment Form, Form 3.601(2). Prior to the start of your leave, you must complete and return a Leave Plan which will describe how you plan to manage your time off. Maternity Leave Plan, Form 3.603(2). Any incomplete requests, documents, or medical certifications will be immediately returned and missed time will be treated as a non-Maternity absence. You must update your supervisor of your condition and status periodically. Extensions of leave must also be processed separately. Contact your Supervisor to confirm your return to work date 2 weeks before your leave period ends. Complete and submit the Intent to Return to Work, Form 3.507(2). As required in the Form, your healthcare provider must certify your ability to resume work including any work restrictions. To add your newborn to your insurance policy, you will need to notify our carrier of the birth within 31 days. If the newborn is not timely added, your claims will be denied. Also, please notify our Payroll Department of the newborn’s Social Security Number as soon as it is available. Should you leave our employ during the leave period, you may be required to pay back advanced paid time and/or funds spent to maintain your health insurance while on leave. This benefit runs concurrently with any other maternity or pregnancy leave under federal, state, or local law. If you are unable to perform your job duties due to a pregnancy-related condition, contact your supervisor to discuss an accommodation or additional leave options. We will attempt to accommodate you as required by applicable law.



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604 - Bereavement In the event of the death of an employee’s family member, eligible employees will be granted a maximum of 3 consecutive days off. You must:

Notify your Supervisor. Complete a Bereavement Leave Request, Form 3.604(1). Provide verification of death (death certificate, obituary, etc.).

The eligibility period begins the day of notification of the death (if elected) and ends on the day after the burial or similar memorial service. Members/relatives covered are defined in Bereavement Leave Request Form. Bereavement is paid at your current pay rate and is not counted for overtime purposes. 605 - Voting & Jury Duty Voting should not interfere with your working schedule. Time off for voting is not permitted, unless other noted or required by applicable law. If called to Jury Duty, your absence will be excused and you will receive pay at the rate when Jury Duty is first elected. You must:

Notify and provide a copy of the Jury Duty Summons to your Supervisor. Obtain from the Court Clerk verification of your attendance, noting the start and ending

time of your duty. After Jury Duty, you must return to work if your work has not ended. Your work wage is in addition to any compensation paid by the Court. Prior to payment, verification must be submitted to your Supervisor. California Worksites Only: Employees may receive up to 2 hours paid time off to vote at a statewide election. Voting can only be taken at the beginning or end of your regular work shift. You are required to notify your supervisor at least 2 business days prior to the election. 606 - Witness & Victims of Crimes We observe Witness and Victims of Crime Leave in accordance with applicable law. You are given unpaid time off to attend or participate in a court proceeding. Vacation Time may be utilized, if available. You must:

Immediately notify your Supervisor. Submit the request in writing. Provide proof of attendance to Human Resources.

Exempt employees may be provided time off with pay when required by applicable law.



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SECTION G: EMPLOYEE CONDUCT

701 - Attendance and Punctuality If you are absent or tardy, you must notify your Supervisor before your scheduled start time. You must provide the reason for your absence and date/time you expect to return. Unless the absence is excused in advance, you must notify your supervisor every day. Do not leave a message, send email/text, or relay this information through others. You must personally contact your Supervisor. In the event of an emergency or if you are physically unable, you must notify your Supervisor as soon as possible. It is your responsibility to verify the accuracy of all information presented to your Supervisor on your behalf. Employees who fail to call and report to work for 3 consecutive days shall be considered to have voluntarily resigned. In the event you fail to provide reasonable notification of your request for paid/unpaid time, we reserve the right to take corrective action even if the request is granted. We also may take corrective action if you exceed the leave, paid or unpaid time off limits. 702 - Corrective Action Policy In keeping with our management duties, corrective action is sometimes necessary and will be uniformly and proportionally applied. For minor violations, you will have ample opportunity to correct performance. This policy does not modify the “at will” employment relationship in anyway. For serious violations, probation, suspension, or termination may be the first and only corrective action taken. When warranted, you may be sent home immediately and suspended without pay. This policy does not modify the “at will” employment relationship in anyway. Written reprimands are recorded with the Corrective Counseling Form, Form 3.702(1). Each reprimand, along with the supporting documents, must be forwarded to your supervisor prior to issuance. The final reprimand must be completed prior to termination to afford the employee an opportunity to submit a response statement. In termination situations, the final reprimand should be given to the employee along with all other separation documents. 703 - Company Property, Supplies & Documents We provide standard office equipment and supplies to use in the performance of work-related duties. The use of employer-paid postage for personal correspondence is not permitted. You should not have any personal items delivered to any work site. All mail addressed to you and received at work is presumed to be work-related, and we reserve the right to open all mail. You have no right or expectation of privacy in any such items. You may be required to provide and use your own tools or equipment. You may be held responsible for loss or damage beyond normal wear and tear for company property in your possession. Do not take company property home or use company property for non-employment purposes unless Management approves. Upon separation of employment, or Management’s request, company property must be returned. You may be asked to sign a form acknowledging



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the receipt of property. The failure to return company property may result in a law suit against you (i.e., laptop, mobile phone, keys, uniforms, etc.). 704 – Technology, Internet & Email Usage Technology, internet, or email may not be used to solicit others for non-business matters unless approved by a Corporate Officer in writing. We reserve the right to monitor computers and internet/email usage. Internet usage is primarily limited to job-related activities, but limited personal use is permitted if reasonable and does not interfere with productivity. You may be monitored if we have reasonable cause to believe company property is being used for unlawful purposes or if work privileges interfere with productivity. All monitoring must be authorized by a Corporate Officer. Abuse of technology, internet, or email access may result in corrective action including termination. Employees may also be held personally liable for any violations of this policy or applicable law. Any behavior or violations that are also legal violations will be turned over to the appropriate authorities for full investigation and prosecution. The following behaviors are examples that are prohibited and can result in corrective action:

Sending or posting discriminatory, harassing, or threatening messages or images. Stealing, using, or disclosing another’s electronic access passwords. Copying, pirating, or downloading software or files without a license or permission. Disclosing non-public proprietary employer, customer, or contractor information. Engaging in unauthorized transactions, services, or transmissions. Modifying hardware, software, or any settings thereof to intercept telephone calls, emails,

or other electronic communications. Sending or posting messages that unlawfully defame or slander other individuals. Unauthorized access to electronic files or communications. Sending solicitations or advertisements without permission.

Respect copyright, trademark and similar laws and use such protected information in compliance with applicable legal standards. The unlawful use, installation, copying, or distribution of copyrighted, trademarked, or patented material is expressly prohibited. Employees should notify their immediate Supervisor upon learning of any violations of this policy. Employees who violate this policy may be subject to corrective action including termination.

Equipment and Software

Users will be held accountable for damage to cellular phones, computers, computer hardware, and laptop computers. Do not relocate desktop computers, monitors, or printers without written permission from an officer of the corporation. The installation and/or alteration of any hardware and software including program settings are prohibited unless with written approval from an officer of the corporation. It is recommended that you not alter Windows desktop themes. It is prohibited to install third party screensavers and desktop themes.



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Data Retention Policy

To ensure that business-related information is retained:

Where a legal matter is pending or reasonably foreseeable, all data should be preserved. Any email accounts related to a legal hold may be temporarily disabled and maintained. All steps will deliberately be taken to preserve any and all information related to any legal matter. You are prohibited from deleting, altering, copying, etc. any information relevant to any legal matter that is pending or reasonably foreseeable. Personal Phone & Use of Technology

Cellular phones are permitted at your workstation. However, we ask that you keep personal telephone calls and text messages to a minimum. Please enable the “vibrate” or “silent” sound function while working. You may not take, distribute, or post pictures, videos, or audio recordings while on working time unless authorized by law. You also may not take pictures or make recordings of work areas unless engaging in a protected concerted activities by law such as taking pictures of health, safety and/or working condition concerns. IMS allows limited personal usage of email and internet if it is reasonable and does not interfere with work. Please limit internet searching to lunch or break hours. It is prohibited to use our equipment for personal shopping or finances. All Internet or electronic data composed, transmitted, or received via our computer communications systems is considered official corporate records. Employees do not own or retain any rights in company Internet data or electronic information. Such information is subject to disclosure to law enforcement or other third parties. 705 - Employee Searches All business equipment is company property. You have no expectation of privacy in terms of any business item brought or left on company property. When presented with reasonable cause, we reserve the right to inspect company property, as well as any articles or containers found in them, either with or without prior notice. A Corporate Officer must preapprove in writing all searches of company property. 706 - Video, Audio & Electronic Surveillance You may be subject to surveillance. Cameras will record video, sound, and other information. As such, you may be recorded while working. Accordingly, employees have no right or expectation of privacy in any information, data, pictures, emails, video, audio, etc. that may be tracked, recorded or otherwise retained. As a condition of continued employment, you must review and complete:

Video, Audio & Electronic Surveillance Release Section J



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707 - Relationships in the Workplace Employees/Supervisor/Coworker Relations Be respectful, courteous and professional toward all coworkers, residents, contractors, or any other third party. Do not make inappropriate, threatening, intimidating, or coercing gestures or comments while working in the course and scope of employment or otherwise interfere with the job performance of coworkers. Use of racial slurs, derogatory comments, insults, or profanity of any kind is prohibited. Personal relationships between employees must be disclosed to your Supervisor or next immediate Superior. Employees involved in a relationship of any kind will refrain from public displays of affection and excessive conversation while at work. If charges of sexual harassment are made, the existence of a consensual relationship shall not be a defense. We will take prompt action if an actual or potential conflict arises. This policy applies to all employees without regard to gender or sexual orientation.

Employee/Resident Relations You are prohibited from showing favoritism toward any resident. To avoid the appearance of preferential treatment or discrimination in resident relations, resident interaction must be respectful and professional. Do not inquire or exchange personal information. Refrain from preforming “personal favors” like making telephone calls or running errands. It is acceptable to assist residents with moving in and recertification paperwork. All other requests should be refused, except in cases where a 504 Reasonable Accommodation has been approved. We will take prompt action if an actual or potential conflict arises. 708 - Contracts, Monies, and Usage of Names The following are authorized to sign contracts: President, Vice President and Chief Financial Officer and under limited conditions, those with written prior approval from a Corporate Officer. You are prohibited from purchasing personal items from suppliers under the company’s name. Use of the company's name, logos, marks or other protected information or property for any business/commercial venture requires written prior approval from a Corporate Officer. Further, you may not use any stationary for personal use. You may not use the company’s name for any political, personal, or charitable activity without written authorization from a Corporate Officer; however, all other lawful uses are permitted. All action taken inconsistent with this policy, or any other policy herein, is ultra vires and outside the scope of the employee-actor’s employment. A failure to observe this policy may result in corrective action including termination. 709 - Emergency Closings Hazardous commuting conditions may make it impossible to report to work. Inform your Supervisor as soon as possible if you are unable to travel. Working from home is strictly prohibited. If conditions improve, you must make a diligent effort to report to work. If the office closes, every effort will be made to notify you.



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710 - Outside Employment You are expected to devote your primary work efforts to our company. Outside employment must not be inconsistent with the company’s interest, present a conflict of interest, or have a detrimental impact on the company’s image. Outside employment is prohibited during any periods of leave unless such employment existed prior to the granting of the leave period. 711 - No Solicitation/No Distribution During business hours, you may not sell, collect, or solicit for any other business, organization, or cause. Also, in the interest of maintaining clean and orderly facilities, distribution of non-work related materials are prohibited. While we do not ban all forms of solicitation and distribution, you must give a Corporate Officer at least 5 business days to review and approve your request. Samples of the items you intend to distribute or sale must be included. Non-employees are not permitted to solicit or distribute advertisements, literature, or other non-work matter on company property at any time unless approved by a Corporate Officer. 712 - Personal Appearance and Dress Code During business hours and functions, employees are expected to present a clean, neat, and tasteful appearance.

You must dress in either business or business casual attire. Avoid exposure. Briefs, halters, short shorts, tank tops, and jeans are not acceptable. Do not wear obscene, nudity, or other designs that may be offensive to others. Business appropriate footwear is required.

Where required, company issued uniforms or attire will be provided. You will be expected to return such items as requested by Management, and will be responsible for items that are not returned. If your Supervisor determines your personal appearance is inappropriate, you may be asked to leave until you are properly dressed or groomed.

Maintenance/Groundskeepers

If you work around machinery or vehicles, you must wear clothes that do not present safety hazards. You should not wear loose clothing, long sleeves or jewelry (e.g., rings, watches, necklaces, bracelets, etc.) that might get caught or tangled in moving equipment. Also, hair should be worn at a safe length or tied up securely. Employees are expected to wear safety glasses, as required, in designated areas. You may some be required to wear designated footwear, and are expected to follow the footwear requirements for the areas that they work in and around.



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713 - Personal Property We are not responsible for personal property or items that you bring to work, including but not limited to vehicles, purses, wallets, personal mobile phones or other electronic devices, ruined clothing, or any other personal belongings. You waive any and all rights to sue any such damage or loss if personal property is stolen, damaged, or destroyed while at work, on company property, or at a business-related function. No bailment exists. 714 - Smoking in the Workplace Smoking of any kind is prohibited on company property including electronic smoking. This includes common work areas, offices, hallways, stairways, and restrooms. Management may designate inconspicuous areas outside for smoking. Debris must be disposed of properly in designated receptacles. 715 - Working from Home Non-exempt employees must get approval from their immediate Supervisor prior to working from home. Hours worked from home without prior approval will result in corrective action including termination. SECTION H – EMPLOYEE SAFETY

801 - Safety in the Workplace See Chapter 2 - Maintenance Procedures 802 - Driving and Vehicle Usage We may ask for proof of your current operator’s license at any time and we will obtain and review vehicle records for all employees who drive or may drive as part of their job duties. If you drive as part of your job duties, you are required to immediately notify your Supervisor if you lose driving or are subject to restricted driving privileges. 803 - Drug, Alcohol & Fitness for Duty Evaluations You, contractors, and visitors may not use, possess, conceal, manufacture, distribute, divert, dispense, or sell controlled substances, narcotics, drugs or alcohol while on company property or on company time. You are prohibited from improper use of prescribed medication and/or being under the influence of drugs or alcohol while on the premises. You may not be under the influence of an alcohol or controlled substance while working. Violation of this policy may result in corrective action including termination. Where we have reasonable suspicion that you are under the influence such that it presents a safety risk or may have caused a safety violation, we reserve the right to require you to submit to



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a fitness for duty evaluation including urine, blood, breath and/or psychological evaluations. Refusal to submit a requested genuine specimen may result in corrective action including termination. A fitness for duty evaluation may be conducted when:

Your behavior, performance or other information creates a reasonable suspicion that the employee is using or is under the influence of any alcohol, drug, improper self-medication, or the employee is engaged in aberrant behavior.

Following an accident or injury, where safety precautions were violated. As a condition of continuing employment or reinstatement following the completion of a

hospital-approved treatment, counseling or rehabilitation program. Any alcohol, illegal drug, or drug paraphernalia is found on company property or is

controlled or used by the employee (personal storage area, parking lots, vehicles, etc.). Absent an exigency, a Corporate Officer must preapprove such evaluations. If the test results are not immediately known, you will be suspended until the results are known. A positive test will indicate that you may be unfit for duty. Such a finding may result in corrective action including termination. “Under the influence” means any amount of alcohol or controlled substance in the employee’s bodily system that affects observable coordination, speech, and/or other behavior. 804 - Violence Prevention Any conduct that threatens, intimidates, or coerces employees or customers, including off-duty periods, will not be tolerated. All employees and customers should be treated with courtesy and respect. Prohibited behaviors include disruptive conduct, physical actions (even if short of actual contact/injury), oral or written threats to people or property as well as implicit threats which cause intimidation or fear. Suspicious individuals or activities should be reported immediately. Employees should not place themselves in peril. If a disturbance occurs, do not intercede, instead notify Management and Security. If threats of or actual physical harm occurs, contact law enforcement or call 911. SECTION I - SEPARATION OF EMPLOYMENT

901 - Resignation, Termination & Discharge

Voluntarily Separation We request 2 weeks’ notice of your separation and written notice to your Supervisor. We do not accept conditional resignations. Conditional resignations are resignations contingent on employment through a date certain and shall not be construed as altering the “at will” employment relationship. Acceptance evidences only the fact of resignation and does not constitute an agreement of any kind including continued employment. You acknowledge that failure to give any notice, coupled with returning company property in your possession, constitutes a voluntary resignation. Should you verbally resign, a written



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confirmation will be mailed to your last known address. You acknowledge that your failure to refute such confirmation will be determined to mean consent that you resigned.

Employee Discharge Letter and Discharge Form With every employment separation, the Discharge Form must be forwarded to Corporate. See Form 3.901(1). In the event of involuntary termination, the Employee Discharge Letter must be used (Form 3.901(2)) and all Corrective Action Forms and supporting documentation must accompany the Discharge Form. Typically, this will include 3 written reprimands but may be less in the event of immediate termination or other situations.

Separation Process

In the event of separation of employment, the following must be completed immediately:

Complete a Corrective Action, Form 3.901(1), if applicable. Complete Letter of Termination, Form 3.901(2). Give the Employee a copy of the Corrective Action Form and Letter of Termination. Complete the Discharge Notification Form, Form 3.901(1). Forward the Discharge Notification, all Corrective Actions/supporting documents, and

Letter of Termination to the Property Manager. Inform vendors the Employee is not authorized to incur any obligations, if applicable.

If the Employee occupies a staff unit, initiate legal action to recover possession of the unit through local counsel. 902 - Return of Property Employees are responsible for all company property in their possession or control and must return all property immediately upon request or termination. Company property includes:

Site, maintenance, and unit keys. Electronics or technology (e.g., cellular phones, pagers, laptops, etc.). Company credit cards.

Property must be returned in the same working condition as was provided to them less reasonable wear. Where permitted by applicable laws, written authorization may be requested to withhold the cost from your final paycheck of any property that is lost, damaged, or destroyed while in your possession. In the event company property is not returned before separation, consult your Supervisor to determine if the filing of a police report is required.



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SECTION J - SIGNATURE DOCUMENTS

1001 Video, Audio & Electronic Surveillance Release 1002 Off-Duty Activities Release 1003 Release of Corrective Action Documents 1004 Acknowledgement /Receipt of Understanding 1001 - Video, Audio & Electronic Surveillance Release The CARSWELL GROUP, INC. d/b/a INDEPENDENT MANAGEMENT SERVICES and its past, present or future affiliates, managed properties, insurance carriers, or workers’ compensation carriers are not liable for any and all harms, losses, or damages resulting from the recording of any information while on or using company property including but not limited to audio, video, electronic or any other surveillance, monitoring or tracking means. You voluntarily agree to hold the above parties harmless against any and all harms, losses, or damages to the extent allowed by applicable law.

1002 - Off-Duty Activities Release The CARSWELL GROUP, INC. d/b/a INDEPENDENT MANAGEMENT SERVICES and its past, present or future affiliates, managed properties, insurance carriers, or workers’ compensation carriers are not liable for the payment of workers' compensation benefits or any other damages for injuries that occur during your voluntary participation in an off-duty recreational, social, or athletic activity sponsored by us. By participating in any such employer-sponsored event or activity, you assume the risk of liability and agree to hold the above parties harmless against any and all harms, losses, or damages to the extent allowed by applicable law.

1003 - Release of Employment or Corrective Action Documents

To the extent permitted by applicable law, you acknowledge and hereby waive any and all entitlement to copies or written notification of our reproduction or transmission of any employment or corrective action information to any party in the event such information is disclosed in anyway by THE CARSWELL GROUP, INC. d/b/a INDEPENDENT MANAGEMENT SERVICES and its past, present or future affiliates, managed properties, insurance carriers, or workers’ compensation carriers.

1043 - Handbook Acknowledgement and Receipt of Understanding I fully and completely understand that all employment policies, benefit programs, employment conditions, etc. may be changed by IMS at any time, with or without notice to me individually. I also understand that the most current polices will be maintained for team members via the IMS Online Tools, and may be obtained at any time upon verbal or written request to my Supervisor. Current benefit program information has been provided to me and can be obtained by submitting a written request to the Payroll Department. I acknowledge that I have received the Procedures Manual, Chapter 3, Personnel Management, that remains in effective on the date noted below and I have read and understand the policies contained therein. I understand that unless expressly stated by statute or contract, my employment is “at will”. I understand that I have the right to terminate my employment at any time. I also understand that IMS has the right to terminate my employment at any time, with or without cause or notice. I understand that the information I come into contact with during my employment is proprietary to IMS, and accordingly, I agree to keep it confidential, which means I will not use it other than in the performance of my duties or disclose it to any unauthorized person or entity outside. I understand that I must comply with all of the provisions herein. I also understand that if I do not comply with all provisions herein, my access to IMS resources may be revoked, and I may be subject to disciplinary action up to and including discharge. I understand that this Chapter represents only current personnel policies and that it does not create a contract of employment. IMS retains the right to change these policies at any time and without any prior notice. Nothing herein, intended to prevent other employees or me from engaging in concerted activity protected by law. A current copy of and any changes or updates to this Chapter may be accessed through IMS Online Tools.

I HAVE READ THIS DOCUMENT AND FULLY UNDERSTAND IT.

Property # _________________ Property Name: ______________________________ ____________________________ ____________________________ _______________ Employee Signature Date



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Notes:

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Chapter 4

MARKETING, LEASING AND MOVE-OUTS Properties are as different as individuals. What works in one market may or may not work in another. Each location has its own “personality”. Sometimes that personality may need to be altered in order to achieve owner/investor objectives. Through the development of a rental income in the shortest possible time for the least possible cost, the goal is to maximize the revenue producing capabilities of the property and develop permanent solutions.

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Chapter 4, Marketing, Leasing and Move-Outs

MARKETING AND ADVERTISING Each property is required to inform the public of their non-discriminatory policies and their desire to serve all persons in a considerate and professional manner. The Site Manager will have fully performed such obligation by: 1. Displaying the Fair Housing Poster in a conspicuous location in all offices where there is

rental activity or regular contact with the public; 2. Include on each item of literature used for public distribution concerning rental activities

including, but not limited to, stationary, business cards, rental applications, and lease forms, a notice that the property provides "Equal Housing Opportunity" ; and

3. Including an "Equal Housing Opportunity" slogan or logo in all newspaper or other printed

advertising according to HUD standards. The main purpose of all marketing efforts for a property is to attract qualified prospective residents. The factors affecting this goal, which are within the Site Manager's control, include:

General Appearance

The general appearance of the property, including the cleanliness of the common areas; the cleanliness of the curb lines; the appearance of the grassy areas; the absence of weed growth; the cleanliness and repair of the asphalt surfaces; and;

The appearance and quality of the units in which prospective residents move into, as that

quality forms the basis of the reputation developed for the site staff and management company; and;

The reputation of the property, as well as the reputation of the staff of the property; and the

reputation of the management company; and; The appearance, attitude, and competence of the property's staff.

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MARKETING AND ADVERTISING (CONTINUED)

Advertising

Advertising includes all paid placements in newspapers, magazines, Internet and other appropriate publications to attract the targeted market as is defined in the HUD approved Affirmative Marketing Plan established for each site by the Property Manager. The goal of the advertising is to create awareness of the property and to increase traffic to the property and rental office. In addition, ensuring that the signage for the site is attractive and easily visible provides an inexpensive form of advertising to passerby individuals seeking rental housing. All advertising must be carefully planned and designed prior to submission for approval. All ads for marketing apartments or help-wanted or any other reason must have prior corporate approval. That is, the exact language that you intend to publish must be written into the Purchase Order. Please do NOT publish any ads without an advance Purchase Order.

Signage The property signs must at all times appear freshly painted and in excellent condition. While advertising and signage may attract prospects to a property, the property itself is the primary factor in their decision to rent. Therefore the appearance of the property and its grounds is extremely important. PROSPECTIVE RESIDENT APPLICATION PROCESSING

1) Complete application is received at the site that includes the back documents and has a separate application completed for all adult household members 1a) The site marks the date and time on the application and puts the application in OneSite on the wait list. **Applications are processed as they are received by date and time and processed in time with the sites turnovers. Effective processing should be to accommodate upcoming vacant units but not so far in advance that the site is processing and reprocessing applications, hence wasting time and resources. 2) A review of the application is conducted for eligibility. 3) Current Income verifications are obtained and reviewed for eligibility. 4) Landlord(s) Verifications are received are obtained and reviewed for eligibility. 5) Credit and Criminal backgrounds are processed and reviewed for eligibility.

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PROSPECTIVE RESIDENT APPLICATION PROCESSING (CONTINUTED) 6) A interview with the site manager is executed to establish eligibility. 7) A review of the file is conducted for any discrepancies and to determine if the application will be approved or denied. 8) An approval or denial is sent to the applicant and a move in date is set. Resident Applications:

After receiving a completed application from the applicant, keep all the information in a legal size Manila folder, with the applicants name and date, and time they applied; labeled on the tab. Pending applications are to be kept in one of five separate hanging folders labeled as follows:

The applications are placed in the appropriate hanging folder until approved for waiting list or denied.

Denied Applications:

Once denied because of, but not limited to: a. Credit history b. Falsification of information on the application c. Rental history d. Character reference

All information is removed from Manila folder. A copy of the denial letter is placed on top of the applicant information, stapled, and the applicant’s name, month and year denied, written in red on the top. Original denial letter is sent to applicant. Denied applications are then filed alphabetically in a banker’s box with period covered stated on front of box.

Pending Interview

Pending Criminal Check

Pending Credit Report

Pending Landlord Check

Pending Income Verification

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4-5


APPLICATIONS for residency are to be maintained in adequate supply at the site office. Applications are to be processed in accordance with an approved RESIDENT SELECTION CRITERIA, and in accordance with Fair Housing Laws and IMS Fair Housing Policy. They are to be numbered by the date and time, which they were received and logged onto the waiting list. All visitors to the site office are to be treated equally and fairly, and should be provided with a brief description of the property and a sincere attempt to determine whether the applicant's needs can be met in terms of family size and specific requirements. All applications should be reviewed upon receipt for accuracy and completeness, including copies of Drivers License or other Government issued photo I.D. and Social Security Cards for all prospective household members. In processing the application, a professional credit agency is used with the appropriate rating system applied, as well as an appropriate police agency to determine whether a pattern of prior criminal conduct exists, which may adversely affect the welfare of current residents. IMPORTANT: Be sure to check all references. In addition, the Site Manager or appropriate office personnel must follow up on all current and previous landlord references to determine whether the applicant is viewed by other landlords as a responsible renter, particularly with regard to rental payment history, property destruction, general disturbances, etc. Any comments obtained from current or previous landlords are to be noted and included in the application-processing package. Prior to being approved for any waiting list, the applicant must be interviewed in an attempt to determine the applicant’s eligibility for approval. The applicant must provide the name of an employer or government agency as the household income source. Processing of the application must include written verification of income from the source not the applicant. An Application Form is included in Form 4.1, as well as a sample Resident Selection Criteria located in Form 4.2. Form 4.3 is an Application Checklist to be used as a tickler file of an applicant’s stage of processing and is to be attached to the top of the application. Upon completion of the above steps, many applicants will not qualify for reasons including, unacceptable credit history, poor references from current and/or prior landlord’s criminal histories etc. These applicants must be sent a denial letter in the form shown in Form 4.4 and processed in accordance with the steps described in Chapter 1 of this handbook. The applications that are not denied during this phase of the screening process, because obvious reasons for denial do not exist, are to be approved for the second phase of the screening process, the applicant interview.

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4-6


APPLICANT INTERVIEWS This phase of the applicant screening process is critical in ensuring a good qualified resident profile and developing a positive reputation of the property, its staff, and its management company. While it is true that evicting problem residents has a positive affect on the resident profile, it is also very expensive. Chapter 5 of this manual discusses the process of removing problem residents. It is much easier and less expensive to screen those applicants prior to them becoming residents. The applicant interview is a process whereby the Site Manager can develop a sense of the applicant's character, inquire in greater detail about many of the items on the application, and discover inconsistencies and/or fraudulent statements made on the application. It is important that the Site Manager develop a standard set of questions to be asked at all interviews, and that these questions be open ended to promote open discussion on the part of the applicant. This set of questions must be reviewed by the Property Manager to ensure that improper or illegal questions are not being asked. An example of a typical open-ended question might be: "How did you learn about our apartment community?" As opposed to: "Did someone living at our apartment community tell you to apply here?" In general, any question that can be answered with a “Yes” or “No” is not a good question to ask. In the above example, the answer from the applicant to the open-ended question might be: “I have a friend that lives here who told me to apply.” If the resident referenced by the applicant is a problem resident, the Site Manager must consider the applicant’s personal reputation and associations to determine whether this applicant would be a problem resident. Form 4.7 is a list of some standard questions that may be incorporated into the applicant interview, however, it is important that the interview questions be developed to specifically meet the needs of each property. It is imperative that the applicant interview be conducted in an equal and consistent method for all applicants in accordance with the IMS Fair Housing Policy. At the conclusion of the interview process, applicants who are disqualified must be sent a denial letter, and applicants who are approved must then be sent an Approval Letter, see Form 4.5, and then be placed on the appropriate waiting list. The Standard Waiting List Form is located in Form 4.8.

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4-7


MOVE-IN PROCEDURES Once we are aware that a unit will become available and placed on the vacancy board as described in Chapter 2 of this manual, the applicant is to be contacted to schedule the move-in, and that move-in date is written on the vacancy board. If the applicant cannot move in when the unit is scheduled to become “Ready For Occupancy”, the next available applicant is to be contacted and scheduled and so on. It is therefore extremely important that a lengthy waiting list be developed so as not to have long periods of vacancy due to applicant processing. In addition, all verifications necessary to complete a move-in certification should be in advance to ensure that delays are not caused by lack of verification, and to ensure that all information is recent. Verifications do not apply to conventional properties; however, all necessary paperwork should be fully ready for the move-in process. Once the unit is “Ready For Occupancy” (as described in Chapter 2 of this manual) and the scheduled move-in date arrives, the applicant must undergo a move-in interview or orientation. The move-in interview is to be conducted by the Site Manager, and is an opportunity to educate the resident as to his/her rights and obligations.

Move-in Interview The move-in interview begins with a comprehensive review of the lease and its requirements. The Site Manager must discuss each paragraph of the lease with the new resident and have the resident sign the lease upon conclusion of this discussion. The Site Manager must then discuss each rule as contained in the House Rules and again have the resident sign the rules upon conclusion of this discussion. The move-in certification and move-in checklist must be discussed and signed in the same manner as described above. The acceptance of the move-in rent and security deposit, in the form of a money order or certified check only, takes place during the discussion of the lease requirements and prior to the signing of the lease.

Move-in Inspection The conclusion of the move-in process requires that the Site Manager accompany the new resident to the apartment and perform the move-in inspection with the resident. This also provides the Site Manager with the opportunity to discuss special features of the unit and to close the deal leaving the new resident with a positive attitude toward the property, the site staff, and the Management Company. Move-In inspections are to be completed jointly by the resident and manager. Important: Making partial Move-In payment arrangements is prohibited. Note: Do not move a person into the software prior to their actual possession of the unit.

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4-8


MOVE-OUT PROCEDURES

Notice Of Intent to Vacate Residents who are planning to vacate apartments are required to give at least 30 days written notice to the Site Manager. See Form 4.10 for the standard Notice of Intent To Vacate. Upon receiving a resident’s notice to vacate, the Site Manager should attempt to schedule a move-out inspection as described in Chapter 2 of this manual. During this move-out inspection, the Site Manager compares the condition of the unit to that which was documented on the move-in inspection form. The resident is then informed of any charges for damages etc. that will be applied to their account and the resident has the opportunity to dispute any charges at this time. Now is the time to secure a new resident for the unit. In many cases, the resident does not give notice and simply breaks the lease and "skips". To the extent practicable, the move-out procedures are to be followed.

Vacancy Board Once the unit becomes vacant or is anticipated vacant, it is written on the vacancy board, and the turnover process as described in Chapter 2 begins. In the instances when a Notice of Intent To Vacate is received by the Site Manager, reasons for vacating should be noted. If good residents are moving due to reasons within the Site Manager's control, i.e., lack of maintenance, poor staff attitude, drug and criminal activity etc., the Site Manager must immediately address the problem(s). In addition, the Property Manager must be informed of these situations, to ensure that the requirements of this manual and the desires of IMS are being met.

UNIT TRANSFERS

In the event that a resident requests to transfer to another unit, management must complete the Resident Transfer Request Form 4.14.

* * * Unit transfers are approved at the IMS Corporate Office in Fenton ONLY. * * * On the Resident Transfer Request Form 4.14, the manager is to accurately complete the reason for requesting transfer, complete the resident file review and recommendation, and submit this form by Email to the IMS Corporate Office in Fenton. This office will then review the transfer request and the site will be notified if the resident is approved or denied. If your property has Section 8, then the resident’s security deposit will not change. If your property has tax credits, then the Unit Transfer function will be used in the Software

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4-9


MOVE-OUT PROCEDURES (CONTINUED)

Processing the Move-out Once the appropriate charges for damages have been established as described above, the following actions must occur immediately after the receiving possession of the unit: 1. Some local Contract Administrators require a copy Notice of Vacancy. Contact the

Corporate Occupancy Specialist to see if this applied to your property. 2. Move the resident out of the unit on the computer using the "Move-out Resident" option.

When question appears on the computer, always process special claims, if this applies to your property.

3. Apply all charges for damages to the resident's account using the Software "Receipt Charge

Processing" option. 4. Using the Software program, apply the security deposit to all outstanding charges on the

resident's account.

a. If the resident has a balance remaining in the security deposit after all the charges have been cleared, use the "Security Deposit Refund" option to reduce the security deposit balance to zero.

b. If the resident still has out-standing charges on their account after all of the security

deposit has been applied, do not clear the remaining charges owing. c. If there are zero charges or prepaid (negative) amounts on the resident's account to

apply the security deposit for refund, perform the "Security Deposit Refund" option, and input the "Credit" to clear any negative balances on the resident's account.

5. Complete the "Security Deposit Disposition Form" located in Form 6.11 and follow the

Security Deposit Disposition process as described in Chapter 6 of this manual, and process the former resident's file in accordance with Chapter 1 of this manual.

NOTE: Do not move a resident out of the computer until you have absolute possession

of the unit. IMPORTANT: BE SURE TO REFUND THE RESIDENT’S SECURITY DEPOSIT

ACCORDING TO IMS PROCEDURES, WHICH STRICTLY ADHERES TO THE SECURITY DEPOSIT ACT.

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4-10


SECTION 504 COMPLIANCE

Procedures for Special Accommodations If a resident or prospective resident, requests reasonable accommodations for themselves or for a family member such as changes to our property or policies and procedures, they are to be provided IMS Form 4.23 – Section 504 – Request Packet:

1. Have them complete, sign, date and IMS Form 4.23 – Section 504 – Request Packet in your presence for accuracy. (Note that when a person is an SSI recipient that fact serves as verification of a disability but not necessarily that the request is reasonable and necessary for the particular accommodation). The Service/Companion Animal Policy MUST NOT be completed until after the Section 504 Request has been approved by an IMS Corporate Officer.

2. A copy of the Third Party Verification Request, Verification of Disability Letter, and Federal Definition of a Disability must be sent to the treatment provider.

3. Record the request on IMS Form 4.24 Section 504 Accommodation Request Tracking Log.

4. The Site Manager is to review document recommendation of the request and submit it to the Property Manager or Supervisor.

5. The Property Manager or Supervisor is to review the request and document recommendation.

6. Make ONE COPY for the Tenant/Applicant file and submit the ENTIRELY COMPLETED ORIGNIAL request to the Section 504 Coordinator at IMS.

7. If more information or verification is required you will receive Accommodation Review Sheet, note status on the log and get the required information to the 504 Coordinator as soon as possible in order to make a determination.

8. Approved requests should be noted on the log and their completion tracked and noted. A copy of the approval should be placed in the 504 file and also the resident’s file.

9. Denied requests should be filed with the initial request in the 504 file and a copy put in the resident’s file as well. The resident has the right to obtain further verification and to appeal the decision.

NOTE: Service/Companion Animals are not considered pets. They are individually trained to

do work or perform tasks for the benefit of a person with a disability. They are considered auxiliary aids similar to the use of a cane, crutches, hearing aid or wheel chair. Residents must sign and abide by the Service/Companion Animal Policy that becomes a part of their lease.

Feel free to contact Mike Rigdon, 504 Service Coordinator, at (810) 750-7000 if you should have any questions or concerns regarding IMS 504 compliance.

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4-11


Notes:

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5-1

Chapter 5

RESIDENT RELATIONS Good resident relations are essential to successful property management. Residents are the source of nearly all of a property's revenue and that fact that should never be forgotten.

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5-2

Chapter 5, Resident Relations

BUILDING MANAGEMENT\RESIDENT RELATIONSHIPS Property management is a service business in which residents are the clients or customers. Public image is very important when selling a service, and the appearance of the property, offices, and employees is a key part of that image. The neat personal appearance of the property staff, also clean offices, lobbies, and common areas, set the tone for the property. All personnel must adopt a professional approach to resident service. Good resident relations begin long before a resident moves into an apartment. They begin with the prospective resident's first contact with the property, which may be through an advertisement, word of mouth, or a visit to the property. Good resident relations require a clear understanding of both management and resident responsibilities. Management responsibilities include providing a safe and clean apartment and building. Residents most often cite poor maintenance as a cause for dissatisfaction with a property. Employees should welcome requests for service and recognize that most of them are valid. Employees also should recognize that responding to service requests is one of their primary responsibilities, and without resident requests, some employees might not have a job. If a work order cannot be completed when promised or within 24 hours, whichever is sooner, the resident should be informed of any delays and be advised when to expect the work to be completed. Resident responsibilities, on the other hand, include paying rent on time, keeping the apartment in good condition, and not disturbing neighbors. To preserve the property and ensure the safety and convenience of the residents, rules and policies must be specifically developed for each property. RULES AND VIOLATIONS It is important to communicate the policies and rules of the property to all residents. Rules must be applied consistently to all residents. Exceptions should be approved by the Corporate Officer and made in writing with a memo placed in the unit file. A violation of any policy or rule is, by definition, a problem for the manager. A resident becomes a problem resident any time a violation occurs (e.g., delinquent rent, damage to property, disturbing neighbors or other Lease violations.) Whenever a resident, resident's family member, or resident's guest violate a rule or policy, the Site Manager is responsible for sending an Infraction Notice to the offending resident. An Infraction Notice Form is found in Form 5.1. If the violation continues or is repeated, the Site Manager may need to process an eviction of the resident to protect the rights of the other residents.

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5-3


RULES AND VIOLATIONS (CONTINUED) If the violation is damage done to the property, the resident must be charged for the cost of the damage and collection efforts made according to the lease provisions. All meetings and discussions with the residents regarding violations should be written up as soon after the event as possible and placed in the resident's file. RESIDENT COMPLAINTS Resident complaints should be attended to in a professional and timely manner. Resident complaints are generally about another resident. If the complaint is about an emergency, one that threatens life, health, or property, the Site Manager should first ask if help has been called (i.e., ambulance, fire, police etc.), if not, this should be done immediately. Residents complaining about other residents should be encouraged to come to the office and make their complaints in writing using the Complaint Form found in Form 5.2. After settling or addressing the complaint, the Site Manager should advise the complaining resident of the problem's resolution. Timely attention to a resident's complaint builds confidence in the property's staff and strengthens resident relations. Improper attention to a complaint may cause a good resident to vacate. The simple process of listening to resident's complaints often is the beginning of solving the problem and confirming that management cares. TERMINATION OF TENANCY When good resident relations and communication are established, the problem residents quickly identify themselves because of the rule violations, and resident complaints received against them. In order to achieve and maintain a good resident profile, it is important that these problem residents are evicted from the property. Although drugs and drug related activity have become prevalent in society, it is generally true that it exists at apartment communities because the Site Manager did not screen incoming applicants carefully, did not develop good resident relations, and failed to react to the complaints of good residents. Once a problem resident is identified, the Site Manager should begin the process of terminating that resident's tenancy. It is important to note that the Site Manager may evict a problem resident for reasons unrelated to a specific incident (i.e., a resident involved with drugs may be evicted for repeated late payment of rent, a resident disturbing other residents may be evicted for damages to the property etc., depending upon the situation).

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5-4


TERMINATION OF TENANCY (CONTINUED) If the Site Manager has many problem residents, he/she should discuss the problem with the Property Manager to ascertain the scope of, cause of, and solution to poor resident profile. If the problem residents are not removed quickly, the good residents will vacate, creating an even larger problem for the Site Manager to deal with. It is important to note that the eviction process is an expensive undertaking and should be considered appropriately. When serious or minor repeated violations of the lease agreement occur, an organized and properly documented resident file is invaluable when processing a termination of tenancy in a Court of Law. It should also be noted that termination of a lease does not automatically entitle a property to possession of the unit. Accurate accounting of payment history, damages and lease violations, including resident complaints and Police reports are an essential part of providing proof to a Judge and/or Jury that the resident is in default of their lease agreement and therefore the property is entitled to possession of the unit. RESIDENT GROUPS AND COMMITTEES IMS encourages the participation of residents as an organized group to become a positive force in establishing a sense of community. Properties that are well maintained and where management responds effectively to resident complaints, resident groups can be helpful in solving property problems, reducing theft and property destruction, and increasing the sense of security in the community. It is important that management, in responding to grievances of an individual, responds to that specific individual's concerns not as a representative of the resident group. Distressed properties with a resident profile problem can establish a neighborhood watch group to further assist the Site Manager in identifying problem residents and improving the security of the property. It is important not to permit the group to become fractionalized causing problems for good residents that are not a part of the resident's group. Further, residents of the group cannot be afforded special treatment under the rules and policies of the property, as this will destroy the confidence in the property's staff and weaken the resident relations overall.

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5-5


Notes:

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6-1

Chapter 6

FINANCIAL MANAGEMENT

The other than physical property management, financial management plays a very important role as well. Rental income, vacancy loss and delinquency are critical in terms of successful property management. Managing these factors strongly illustrates a property’s performance.

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6-2

Chapter 6, Financial Management

RENT COLLECTION AND PROCESSING Rental receipts and all other collections are to be deposited to the project operating account DAILY. It is to be expressly understood that no employee is permitted to accept cash under any circumstances. Procedures for processing accounts receivable are in further detail. For each deposit, the following must occur:

1. Copies must be made of all daily receipts (i.e. checks, money orders) and filed at each site. Receipts are then added manually and a calculator tape indicating the deposit items and deposit total is attached to the batch of receipts.

2. Enter each check individually into the OneSite program. The conclusion of this process

will produce a printout totaling all receipts. Review the printout for accuracy, and ensure that the totals from step #1 and the computer generated printout match. If there are no errors or discrepancies, proceed to close the bank deposit batch in the computer program.

3. Endorse the checks using the "Endorsement Stamp" provided. Then scan all checks by

batch. See IMS Form 6.4 – Deposit Scanner Procedures.

4. Email a copy of the computer generated deposit listing from Onesite along with the Deposit Summary from Comerica Bank to [email protected].

5. Draw a diagonal line on front of each check and money order once it’s been scanned

successfully.

6. Mail all scanned checks and money orders by batch with the matching computer generated report and bank report to IMS Corporate weekly.

7. At month end, print the computer generated bank deposit summary and attach to the

monthly receipt detail. NOTE: In the event a computerized system is not present or computer failure, a cash receipts

log is to be completed, itemizing all payments posted to the resident's ledger card. This would be done in place of step #2 above. The cash receipts log form is found in Form 6.1. All receipts must be deposited or mailed to the bank daily even in the event of a computer failure!

A deposit is not considered complete until ALL OF THE ABOVE have been accomplished. CAUTION! We do not accept CASH. Anyone found to be accepting cash may be subject to immediate termination of employment.

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6-3


DELINQUENCY, NON-SUFFICIENT FUNDS (NSF) AND COLLECTIONS Any checks that have been returned from the bank for non-sufficient funds, (NSF) are to be entered and posted as soon as you are notified. During this process, charges are to be applied to the resident's account for late payments & NSF fees according to the project's lease agreements. The returned check is to be held on-site and may be replaced by the resident with a money order or cashiers check only. The returned check is not to be re-deposited under any circumstances. 1. On the sixth (6th) day of the month all delinquent residents are to be charged a late charge,

according to the property’s lease agreement, and posted to the residents account. Payment arrangements with residents require approval from the Property Manager, and are generally not accepted.

2. The residents delinquent in their rental payments are to be sent a "Notice-to-Quit" on a form

appropriate for the project's jurisdiction on the sixth (6th) day of the month with a copy retained in the resident's file, and a copy to be forwarded to the project's attorney after the required time stated in the notice has expired. Payments received from residents for amounts less than the balance owed will not be accepted and should be returned to the resident pending payment in full. HELPFUL TOOL: Those sites that have high delinquencies, the “Notice-to-Quit” may be sent to residents by the second (2nd) day of the month. Written approval from an IMS Corporate Officer must be obtained prior to issuing a 30-Day Notice to Quit to Terminate Tenancy. Note that this is NOT the same as Termination of Subsidy, which is a separate function of our recertification requirements as discussed in Chapter 7. A 30-Day Notice to Quit to Terminate Tenancy is to recover possession of a unit because of lease violations, not to be confused with a Non-Payment action, which should occur automatically if rent is not paid on time.

3. Evictions are tracked using OneSite’s Legal Tracking System. Separate instructions for using

this feature are available. 4. The information entered into OneSite’s Legal Tracking System will be used to generate a

"Legal Case Summary Report" (“LCS Report”) to track legal actions, termination, and eviction. LCS Report is to be submitted monthly to the central office, and must include the delinquency report produced in step #2 above.

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6-4


MONTH END REPORTING On the last business day of each month or as directed by the monthly management calendar, the current month's transactions must be completed to begin the next month's transactions anew. The following process discusses this closing procedure:

1. Confirm that you have received pre-closing approval from IMS Corporate. See pre-closing instructions (Form 6.18).

2. Ensure that all receipts have been deposited and posted as discussed on Page 6-2. 3. Ensure that all recertifications, move-in’s, move out’s, unit transfers are completed for

the month. HUD PROCESSING Housing Assistance Payment (HAP) vouchers are to be prepared 30 days in advance and excess income reported for the prior month immediately following the "closing" process discussed in this chapter.

HAP Voucher

To produce the HAP voucher, use the OneSite program. After ensuring that the billing is accurate, update the schedule. On first business day of the month, process your HAP Voucher, and Special Claims:

1. Scan and email ONLY the cover of the printed FINAL HAP VOUCHER to the IMS Accounting Department.

2. Retain a complete copy of the HAP voucher in your TRIPLECHAM Files.

Tenant Rental Assistance Certification System (TRACS) Upon producing the HAP voucher, use the OneSite program to send certification information and assistance schedules.

Special Claims

Special Claims are an important tool for subsidized properties to keep financial losses to a minimum. The Government set up these different Claims because of the demographics of our Residents, and because of the special screening and lease renewal criteria set up by the U.S. Department of H.U.D. Each of the four types of claims is set up specifically for losses indicative to subsidized housing. Claims must be completed to the standards of your local reporting hub in order to collect on them; failure to do so will cause claims to be denied. Site Managers are required to keep close attention to this process for each moved out resident in order to maximize the return on these claims.

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6-5


Special Claims (continued) Site Managers are also responsible for the reporting process as described below. Site Managers are to process all Special Claims by the tenth (10th) business day of each month, and forward one complete copy to the Special Claims Coordinator for review. After review, the Special Claims Coordinator will submit them to the appropriate H.U.D. office for approval. A FULL copy of each completed Special Claims Packet submitted is to be retained on site for three years. Refer to the OneSite User Guide for Special Claims Processing and the Special Claim Processing Section found at IMS Online Tools.

Recertifications Resident recertifications are to be done timely and according to HUD manual 4350.3. In addition, on the second Monday of each month, the "Next Annual Recertification Report" is to be produced. This Next Annual Recertification Report, can be created using the OneSite program. VENDOR PROCESSING

Vendor Intake Database

Prior to the date of service, the Site must electronically upload the vendor into the Vendor Intake Database called “Vender Insurance Certs” located under “Purchasing” at IMS Online Tools. This Database enables us to monitor the following vendor intake documents: IMS Form 6.35 - New Vendor Setup W-9 Form Certificate of Liability Insurance with the Project and IMS listed as Additional Insureds and

Certificate Holders. Certificate of Worker Compensation with IMS listed as the Certificate Holder. Where permitted by state law, vendors may submit a state-approved Affidavit establishing an exemption from coverage. Use IMS Form 6.36 – Sole Proprietor Statement

Service Agreement, if applicable to the vendor. Independent Contractor Verification All certifications and intake documents must be uploaded into the Database prior to the start of services. Lapses in coverage expose the Project to significant legal and financial liability in case of injury. Lapses in Vendor coverage, or the failure to upload vendors and intake documents to the Database, are unacceptable.

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Vendor Invoice Review

For normal trade payables, payments are generated as noted on the internal calendar every month. All vendor invoices are to be sent directly to the site. To ensure timely payments and accurate accounting, the following items must be accomplished weekly: Vendor Invoice Forms must be completed for all payments. If there are no invoices to be

processed, then submit a Vendor Invoice Transmittal, Form 6.7 indicating “No Invoices”.

The vendor invoice form must be completed in total, and initialed by the person completing the form. It must also be reviewed and initialed by the Site Manager and/or Property Manager.

Each form must be accompanied by original invoices that note the P.O. number and a copy of

a purchase order for each purchase. Submit completed forms to the central office. ALL vendor invoices for new subcontractors (i.e. painters, unit cleaners) must include all items listed above under Vendor Intake Database.

Any incorrectly processed invoices will be returned to the site for corrections.

Vendor Invoice Form

When completing a vendor invoice form, it is important that the descriptions accurately reflect the invoice being submitted. A Vendor Invoice Form is found in Form 6.5. Form 6.6 contains the standard "chart of accounts" to use when "coding up" an invoice. Select from this chart, the account number that most accurately reflects the expense category of the invoice and place this account number in the second column of the vendor Invoice Form 6.5.

Reserve for Replacement (R&R) 1. When coding the invoices for payment, if the item is a reserve for replacement item, use only

Account # 651540 on the Vendor Invoice Form. This allows for easier tracking for future withdrawal requests. It is important to note that reserve for replacement items must be listed individually, and the item and location (unit no.) must be included in the description.

2. In addition, copies of all invoices that are eligible as reserve for replacement expenses, in a

separate file labeled "Reserve for Replacement." Listed below are some examples of items that qualify as reserve for replacement items:

Appliances Carpet Boilers Roofs Furnaces Floors Tub walls Generators Hot water Tanks Toilets Cabinets Vanities

* In general, any major replacement items may qualify.


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3. Vendor Invoice Transmittal Summary Form is to accompany each "batch" of Vendor Invoice

Forms. The transmittal will summarize the bills by Vendor Invoice Form, and will serve as the on-site tracking record to use in responding to vendor inquiries regarding payment status. The Transmittal Form is found in Form 6.7.

It is extremely important that all vendor invoices are prepared for payment weekly to ensure timely payments to vendors, and to produce accurate financial reports. Every effort must be made at the site level to communicate with vendors re: payment etc. PETTY CASH CONTROL Petty cash reimbursement requests are processed like vendor invoices. They are to be submitted to the central office for payment as part of a batch of Vendor Invoices. In addition, a "Petty Cash Voucher" form (Form 6.8) must be completed by the project's petty-cashier. This form and all the corresponding receipts are used as the backup for a Vendor Invoice Form when being submitted. It is recommended that the petty cash fund not be completely depleted before requesting reimbursement. This could leave the project without any available petty cash for an extended period. Any requests for increases to the petty cash fund must be directed to the Corporate Office for approval. In the event that the petty cash is surrendered, it must be reconciled on that same day. It’s then closed out and a new petty cash fund is requested on a Petty Cash Voucher for approval by the Corporate Office. The check request will be made payable to the new person responsible. It’s also important for the property manager to notify the financial department immediately to change the vendor on any outstanding petty cash checks to former employees. BUDGETING Property Managers are expected to participate in the development of annual capital improvement budgets, which must be completed 90 days ahead of the fiscal year-end. Property Managers are provided with monthly operating statements to review. These monthly reports are to be used by Property Managers only for monitoring collections, expenses, and occupancy performance. During budget preparation, consideration should be given to any needed staffing changes, annual and seasonal contract bids, deferred maintenance items, capital improvements, special projects, and normal inflationary cost increases. Once a budget has been established and approved, the Site Manager plays the most important role in achieving budget goals, from both an income and expense standpoint. Accordingly, Site Managers are expected to become "intimately acquainted" with monthly financial reports, particularly in budget to performance comparisons. Since the Site Manager must approve all operating expenses, the burden of prudent fiscal management rests primarily with the Site Manager. The Site Manager is to shop around for most favorable pricing when purchasing normal operating supplies, and overstocking of inventory is not permitted. The central office prior to incurring the expense must approve all purchases.

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In addition, Property Managers are also expected to develop long term improvement plans establishing a 5-year plan for improving the appearance, structural components and overall viability of the project. ASSESSING RESIDENT DAMAGES Site Managers are responsible for ensuring that the damages caused by residents or the guests of residents are charged to the resident and posted on the resident's account in the OneSite program. These damages must be those in excess of "normal wear and tear." To ensure that charges for damages are consistent and not excessive, a list of common repair and replacement costs are listed on IMS Form 2.13. If the damages are being assessed as part of a move-out inspection, the items must be noted on the Move-In/Move-Out Checklist Form 2.1 and a Security Deposit Disposition Form 6.11. ADJUSTMENTS TO A RESIDENT'S ACCOUNT Prior to adjusting resident's account on the computer including "Charge Adjustments", "Credit Adjustments", and "Tenant Concessions", authorization must be obtained from the central office with a Rent Adjustment/Bad Debt Write off Authorization Form found in Form 6.10. Note that adjusting a rental account without prior corporate approval is grounds for immediate dismissal. It is imperative, however, that efforts are made to collect any balances owed by former residents. Each property must use an approved collection agency to help this process. Once a resident's account has been cleared during the move-out processing discussed in Chapter 4; any receipts from the former resident must be submitted to IMS Corporate with a copy of the former tenant’s ledger. All bad debt transactions are recorded to the former account, not the current residents account.

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SECURITY DEPOSIT PROCESSING Upon completion of the move-out process as specified in Chapter 4, the following items must occur: 1. The "Security Deposit Disposition Form" (Form 6.11), and a formal letter (Form 6.11A),

must be mailed within five (5) days of move-out to the resident’s forwarding address or last known address if no forwarding address is available. A copy of these forms are placed in the prior resident's file and a copy is sent to the central office along with the resident's account history, "Move-in/Move-out Inspection Form", Notice of Intent to Vacate (form 4.10), and Final Account Statement generated by the OneSite program.

2. If a Security Deposit refund is required, the amount is to be "coded up" on a "Vendor Invoice

Form" as detailed in Page 6-5 of this chapter. The forms noted in step 1 of this process are then included as "backup documentation" for the "Vendor Invoice Form". The Site Manager is responsible for ensuring timely submission (five (5) business days) of security deposit refund information to IMS as damage awards for improperly processed security deposits will be noted in the site manager’s employee file.

3. When a resident's lease requires interest be paid on the security deposit balance, a copy of the

lease page referencing such interest must be included with the above documentation. In addition, the "Interest Calculation" program is to be used to ensure proper calculation of the amount.

FINANCIAL REPORTING AND CONTROLS Financial reports are to be produced monthly and distributed by the 15th of each month following the reporting month. The reports include: 1. Schedule "A" 2. Schedule of Disbursements 3. Schedule of Accounts Payable 4. Profit and Loss Budget Performance 5. Schedule of Reserve balances. Bank accounts and reserve escrows are reconciled monthly and any adjusting journal entries are recorded and available for review by the Controller and C.F.O. Disbursements are made primarily with computer generated checks. The review process requires the comparison of all backup documentation. The checks are printed and reviewed weekly with supporting documents again, which are then signed when approved.

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Notes:

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Chapter 7

COMPLIANCE/OCCUPANCY REFERENCE GUIDE Use this chapter for reference in certifications, recertifications, and many other occupancy/compliance guidelines.

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Chapter 7, Occupancy Reference Guide

OCCUPANCY COMPLIANCE

In this industry we must determine eligibility of applicants and participants for placement and continuation in Opportunity Housing Programs such as, Section 8, 236, 515, Rural Development, Rental Supplement, and Low Income Tax Credit Housing. Daily tasks include interviewing, processing applications, certifying, re-certifying applicants, waiting list administration, and file maintenance for various housing programs. Certifying and re-certifying participants greatly affect the participant’s rent and rental assistance. Other duties entail the development and implementation of marketing activities, executing leases, and completes data entry computer transactions. This reference guide will help you in understanding program regulations and resident orientation.

DETERMINING ELIGIBILIY There are four key components to determining eligibility.

1. Thorough working knowledge of Rental Assistance income qualifying guidelines. 2. Exhaustive data collection process 3. Systematic verification process 4. Accurate certification analysis.

Thorough Working Knowledge of Rental Assistance Income Qualifying Guidelines

All households applying for Rental Assistance and Tax Credit Housing units must be income qualified in accordance with Section 8 guidelines.

For detailed occupancy requirements, refer to the HUD Handbook 4350.3 The income of individuals and area median gross income shall be determined in a manner consistent with determinations of lower income families and area median gross income under Section 8 of the United Sates Housing Act of 1937. The Income and Asset Checklist is used to identify what sources of income and assets a household has in determining eligibility more thorough and systematic.

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Compliance with Non Section 8 or Section 236 Income/Rent Restricted Units

Projects with units that do not have Section 8, but are Income/Rent Restricted under IRS Section 42 - Low Income Housing Tax Credits; ARE NOT market units. They are Income/Rent Regulated Units and applicants must qualify under the appropriate income/rent limits. Projects with units that are Section 236 and are Income/Rent Restricted under IRS Section 42 - Low Income Housing Tax Credits; ARE NOT market units. They are Income/Rent Regulated Units and applicants must qualify under the appropriate income/rent limits.

All applicants for Non Section 8 Income/Rent Restricted (Tax Credit) Units MUST be approved by IMS Corporate (with signature and date), prior to move-in.

All applicants for Section 236 Income/Rent Restricted (Tax Credit) Units MUST be approved by IMS Corporate (with signature and date), prior to move-in.

Certification Timeline

Resident certifications and recertifications are to be done timely and according to HUD Manual 4350.3. In addition, on the second Monday of each month, the "Annual Recertification (AR) Report" is to be produced and submitted to the central office. This report, AR Report, can be created using the OneSite program, please refer to the OneSite Software Guide. Reminder Notices are to be printed and submitted to the resident on the 1st each month. If the 1st falls on a weekend the Reminder Notices must be submitted on the last business day of the prior month. Notices

1. Print the First Reminder Notice for residents due for Annual Recertifications 120 days prior to the resident’s anniversary recertification date. The Notice should ask that the resident meet with you at the office within 5 business days.

2. If the resident does not respond to the Second Reminder Notice, then print the Second Reminder Notice 90 days prior to the resident’s anniversary recertification date. The Notice should ask that the resident meet with you at the office within 5 business days.

3. If the resident does not respond to the Second Notice, then print the Third Reminder Notice 60 days prior to the resident’s anniversary effective date. This Notice must inform the resident that if they do not respond within 10 calendar days after receipt of the Third Reminder Notice, then their Rental Assistance will be Terminated. The residents’ rent will increase to the contract rent or market rent effective on the anniversary recertification date.

The procedure mentioned above is built into our Monthly IMS Planner to remind you when notices must be printed and submitted to the residents. A copy of the notice must also be placed in the resident’s file. OneSite is equipped with an intuitive tracking system to alert you of upcoming recertifications; when to print reminder notices; log resident responses to

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notices; and provides verifications that you need to send to third party for information. When a resident responds to a notice, the recertification must be started immediately.

Exhaustive Data Collection All identified sources of income must be third party verified. For example, if a member of a household is employed, you must verify that household’s income using the Enterprise Income Verification (EIV) system (see IMS EIV Procedures) and an income verification form for the employer to complete and return to your office. This written verification, directly from the source (not the applicant or resident) will include their hire date and wages. This verification must be signed and dated by the employer (third party.) This verification information will be used to complete the participant’s certification or move-in. Collection of income information is valid for 120-day period prior to the move-in date or effective date of the annual recertification. If any information has changed for an applicant, a new verification must be obtained. To expedite processing verifications, include an enclosed self-addressed, stamped envelope when mailing out verification requests to aid prompt return. Have the applicants sign two copies of each verification form and retain one incase one gets lost, or fax transmission is acceptable.

Systematic Certification and Verification process OneSite is adequately equipped with verification forms and an annual recertification report which informs you of upcoming recerts. This program also reminds you when recertification reminder notices should be sent as well as the IMS Monthly Calendar. Printing the Annual Recertification Report on a weekly basis and monitoring the activity of recertification will help you collect and complete recertification on time.

Accurate certification analysis

Be sure that the income and asset checklist and verifications are accurate and complete. While reviewing the checklist and verifications, ask yourself the following.

Are all of the questions answered on income and asset checklist? Is there an income and asset checklist for each household member age 18 years or

older? Is the checklist signed and dated? Are all verifications forms completed thoroughly by the third party? Has the third party signed and dated the verification? Is the information on the verification vague or unclear? Is the verification out of the 120-day certification window?

While completing certifications according to the IMS Procedures Manual and HUD 4350.3, you should need not to answer ‘No’ to any of the questions above.

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Housing Assistance Payment Voucher Review On a monthly basis, HAP Vouchers, TRACS Submission Reports, Annual Recertification Reports, and Weekly Occupancy Reports must be audited to ensure that the correct number of Section 8 tenants are on the Voucher. In conclusion, this audit will ascertain that all tenants and vacant units are accurately reported on the HAP Voucher and determine whether tenants receiving subsidy are paying rent or not. For instance: 1) Part II, 6 a-e, of the HAP Voucher indicates (6a) the total number of units in the HAP contract; (6b) number of units receiving Subsidy under the HAP contract; (6c) number of units abated under the HAP contract; (6d) number of units vacant under the HAP contract; (6e) number occupied by market rate tenants *. The sum of items (6b) through (6e) should equal the total number of units in the HAP Contract. This summary should reconcile with the respective occupancy report, TRACS Submission Report, and Annual Recertification Report. * NOTE: - Market Rate Units on the HAP Voucher are units occupied by a tenants who have initially income qualified, however, later earned enough income to pay contract rent. - Non Section 8 and Section 236 Units are not to be reported on the HAP Voucher. 2) All Certifications reported on the HAP voucher are to be reviewed and reconciled with the TRACS Submission Report to ensure that they were submitted to TRACS. Move-out Certifications should reflect the respective weekly occupancy report. 3) Review of Certifications may result in the correction of obvious errors such as, missing signatures/dates, subsidy amount, eligibility codes, elderly household allowances, over/under housed tenants, anniversary recertification dates, late recertifications, and income/asset duplication, etc. This audit procedure should produce accurate HAP billing & vacancy; Section 8 compliance; and reduce tenant file deficiencies. Please contact the Corporate Occupancy Specialist if you have any questions regarding the recertification process or any other occupancy issue.

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Enterprise Income Verification (EIV) EIV may be used for all household members 18 years of age and older for the following purposes:

Verification of Income Income Discrepancies No Income New Hires Existing Tenants Receiving Subsidy Multiple Subsidies Identity Verification Report

Form 9887/9887/A will be completed for households before running income reports. Residents who turn 18 years of age must sign Form 9887/9887A within 10 days. A Notice will be sent to all residents informing them of this requirement. The Federal Privacy Act prohibits the disclosure of an individual’s information to another person without the written consent of such individual. As such, the EIV data of an adult household member may not be shared (or a copy provided or displayed) with another adult household member, unless the individual has provided written consent to disclose such information. However, management is not prohibited from discussing with the head of household (HOH) and showing the HOH how the household’s income and rent were determined based on the total income reported and verified. Income Reports and Summary Reports EIV will be used to verify employment and income data for all members of the household who are 18 years of age or older at the time of recertification. For Social Security benefits, the Income Report may be used as the primary verification-but only if the head of household has reviewed and approved. For employment income, EIV may only be used as third party verification of the tenant’s employment. Verification from the third party source will be used to calculate the tenant’s income. Income reports will be printed at annual and interim recertifications and 90 days following the TRACS transmission of the household’s move in certification, for new move-ins. The Summary Report will be printed at the time the income is verified through EIV. Income discrepancies will be resolved within 30 days of the Income Report Date.

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Income Discrepancies Income Discrepancy Report: Since the income discrepancies reported in EIV are determined by comparing the wage, unemployment and social security benefits income reported by NDNH or SSA with the wage, unemployment and social security benefits income reported by the family and transmitted to TRACS, it is management’s responsibility to make sure the information in TRACS agrees with the information on the form HUD-50059 in the tenant’s file. This is to be printed at re-certification and the file needs to be documented to show how the discrepancy was resolved. Management will also follow the guidance in HUD Handbook 4350.3 if fraud is suspected. In addition to repayment of overpaid subsidy, eviction may be necessary. Tenant file will be documented with all correspondence related to the income discrepancy. When an income discrepancy is identified, under or over reported income, management will use the following procedures to resolve the discrepancy.

1. Notify and discuss any discrepancy with the tenant. 2. Request current documents from the tenant file (i.e. original, most recent (four to six)

consecutive pay stubs; original SSA benefit award letter dated within the last 120 days, etc.), in accordance with Chapter 5, Paragraphs 5-13 and 5-17.

3. Request written third party verification of any income source that the tenant disputes. 4. Confirm effective dates of unreported, underreported or over reported income. 5. Provide the tenant the right to contest the findings. 6. Determine any retroactive rent due to management in cases where management confirms

that the tenant failed to report income. 7. Execute a repayment agreement with the tenant, when the tenant is unable to pay the

amount due in full, in accordance with Chapter 8, Paragraph 8-20.A and HUD Notice 2013-06. The terms of this agreement will be renegotiated if there is a decrease or increase in the family’s income of $200 or more per month.

8. Adjust the rent, as necessary, in accordance with Chapter 7, to reduce the occurrence of improper subsidy payments.

Management may not suspend, terminate, reduce or make a final denial of any financial assistance or payment under a federal benefit program against an individual, or take other adverse action against such individual, as a result of information produced by the EIV system without properly verifying the information and notifying the tenant in writing of any adverse findings in the same manner as applies to other information and findings related to eligibility factors. If identity theft is suspected, management will refer the tenant or applicant to SSA’s website at www.ssa.gov for information on reporting identity theft or to a local agency who may assist the tenant or applicant in getting the matter resolved.

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No Income Reported on 50059 and No Income Reported by HHS or SSA This report will be used to re-verify tenants who are reporting zero income. If a tenant is reporting zero income and EIV confirms- a zero income questionnaire will be given to the tenant and management will verify zero income quarterly. An Interim Certification will be completed if the tenant’s income changes. New Hires New Hires Report: Management will use this report to identify tenants who have started new jobs within the last six months. Management will notify the tenant and discuss with the resident to determine whether the tenant disputes the employment. Third party verification will be obtained and an Interim recertification will be done. The procedures for income discrepancies (above) will be followed. Existing Tenants Receiving Subsidy Existing Tenant Search: Management will use this report for all household members at the time they are processing an application to determine if the applicant or any applicant household members are currently residing at another Multifamily Housing or Public and Indian Housing (PIH) location. Any applicant found to be receiving subsidy at another property will be required to provide verification of move-out before they are allowed to move in. Telephone clarification may also be used for verification of move-out. Multiple Subsidies Multiple Subsidy Report: This report allows management to search within the TRACS and PIH’s PIC databases to identify individuals who may be receiving multiple rental subsidies. If a current resident is found to be receiving subsidy from another property, the source of the other subsidy will be verified. Contact will be made with the source to resolve the issue. Subsidy may be terminated until such time that the other source of subsidy has been terminated.

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Identity Verification Report Failed EIV Screening Report: This report provides a listing of tenants who fail the EIV pre-screening test because of invalid or missing personal identifiers (SSN, last name or DOB). The tenants on the list will not be sent to SSA from EIV for the SSA identity match. Management must correct. Verification of personal identifiers will be obtained to confirm identity of the applicant or tenant.

1. Confirm with the affected tenant their SSN, DOB and/or last name. 2. Obtain third party verification or documentation to support the tenant’s personal

identifiers and the accuracy of the information on the form HUD-50059 in the tenant’s file and in TRACS.

3. Correct any discrepant information in the TRACS system so that the tenant will be included in the TRACS file provided to EIV for inclusion in the SSA identity match.

Failed Verification Report (Failed the SSA Identity Test): This report identifies household members who failed the SSA identity match due to invalid personal identifiers (SSN, last name, DOB), as well as, identifies deceased household members. Verification of personal identifiers will be obtained to confirm identity of the applicant or tenant.

1. Confirm with the affected tenant their SSN, DOB and/or last name. 2. Obtain third party verification or documentation to support the tenant’s personal

identifiers and the accuracy of the form HUD-50059 and TRACS data. 3. Correct any discrepant information in the TRACS system so that the tenant will be

included in the match against SSA and NDNH data. 4. Encourage the tenant to contact the SSA to correct any inaccurate data in their

databases if the personal identifiers on the form HUD-50059 and in TRACS are accurate. The tenant can request SSA to correct his/her record by completing and submitting form SS-5, Application for Social Security Card, to the local SSA office.

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Deceased Tenant Report Deceased Tenant Report: This report will be used to identify tenants who are participating in on of Multifamily Housing’s rental assistance programs who are reported by SSA as being deceased.

1. Confirm with the head of household, next of kin or emergency contact person whether or not the person is deceased.

2. Update the family composition on the form HUD-50059 if the person is deceased, or in the case of a deceased single member of a household, process a form HUD-50059 to terminate tenancy.

3. Correct any discrepant information in the TRACS system. 4. Encourage the tenant to contact the SSA to correct any inaccurate data in their

databases if the person shown as being deceased in the SSA database is not deceased.

EIV REPORTS All reports are run on a regular basis. Below is a description of the frequency in which these reports will be used. These reports should only be ran in accordance with this schedule. REPORT FREQUENCY Income Report Summary Report Income Discrepancy Report No Income Report on 50059 and No Income Reported by HHS or SSA New Hires Report Existing Tenant Search Multiple Subsidy Report Failed EIV Screening Report Failed Verification Report Deceased Tenant Report

Re-certification and 90 days after the move in certification reports on HAP.

Re-certification and 90 days after the move in certification

reports on HAP. Re-certification and 90 days after the move in certification

reports on HAP.

Quarterly

Quarterly

Prior to Move-in (ALL household members)

Quarterly

Monthly

Monthly

Quarterly

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RETENTION OF EIV REPORTS 1. The Income Report, the Summary Report(s) showing Identity Verification Status as “Verified” and the Income Discrepancy Report(s) and supporting documentation must be retained in the tenant file for the term of tenancy plus three years. 2. Any tenant provided documentation, or other third party verification of income, received to supplement the SSA or NDNH data must be retained in the tenant file for the term of tenancy plus three years. 3. Results of the Existing Tenant Search must be retained with the application:

(a) If applicant is not admitted, the application and search results must be retained for three years. (b) If applicant is admitted, the application and search results must be retained in the tenant file for the term of tenancy plus three years.

4. The master files for the New Hires Report, Identity Verification Reports, Multiple Subsidy Report and Deceased Tenants Report must be retained for three years. 5. Once the retention period has expired, Management must shred the data. EIV Report Retention Index

Report Name

EIV Master

File Tenant

File

New Hires Report X

Multiple Subsidy Report X Failed EIV Pre-Screening Report X

Failed EIV Verification Report X

Deceased Tenant Report X

Existing Tenant Search X

Summary Report X

Income Discrepancy Report X

Income Report X

All personal information is to be retained in the tenant file. General resolution notes are to be retained in the Master EIV file.

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3rd PARTY VERIFICATION

Management will obtain independent third party verification which is used to compliment EIV data when:

1. The tenant disputes the EIV data 2. The tenant is unable to provide management with acceptable and current income

documentation 3. There is incomplete EIV data for a tenant, or 4. There is no EIV data for a tenant

Management always has the discretion to obtain additional third party verification of income or verification of other EIV data based on circumstances encountered during the re-certification process.

EIV & YOU BROCHURE

Management will provide each tenant household with the “EIV & You” brochure at the time of annual re-certification along with a copy of the HUD Fact Sheet “How Your Rent Is Determined”. Management must also provide applicant households who have been selected from the waiting list for screening and final application processing with as copy of the “EIV & You” brochure. To enable full EIV implementation, HUD requires every assisted individual to have a Social Security Number, and to provide required documentation, which is either: A valid Social Security Card issued by the SSA, or an original document issued by a federal or state government agency which shows the person’s name and SSN along with other identifying information, or other evidence that HUD may identify in the future.

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REPAYIMENT AGREEMENTS

The tenant and management must both agree on the terms of the repayment agreement.

The tenant may wish to consult with HUD’s Housing Counseling Agency in their area to assist.

The tenant’s monthly payment must be what the tenant can afford to pay based on the family’s income.

The monthly payment plus the amount of rent the tenant/family pays at the time the repayment agreement is executed should not exceed 40 percent of the family’s monthly adjusted income unless the resident agrees to a higher amount.

The repayment agreement must reference the paragraphs in the lease whereby the tenant is in non-compliance and may be subject to termination of their lease.

The repayment agreement should contain a clause whereby the terms of the agreement can be renegotiated if there is a decrease or increase in the family’s income.

The repayment agreement must be signed and dated by the tenant and management.

If an intentional misstatement or withholding of information cannot be substantiated through documentation, the case must be treated as an unintentional program violation.

If management determines the tenant knowingly provided inaccurate or income information and this can be substantiated through documentation, the incident must be pursued as fraud.

Repeated acts of misstatement or withholding of information by the tenant must be pursued as fraud.

When fraud is present, the authorized course of action is termination of tenancy.

OC

CU

PA

NC

Y

RE

FE

RE

NC

E

GU

IDE


7-14


Notes:

OC

CU

PA

NC

Y

RE

FE

RE

NC

E

GU

IDE