HUD sent a memorandum to its staff and owners and managers of HUD-assisted multifamily properties providing interim updated guidance regarding prevention and response to pest infestation, particularly bed bugs.
Housing Notice 2012-5, issued in 2012, is now out of date due to advances in the treatment of pests and an increased understanding of the importance of a property-wide integrated pest management (IPM) strategy. In addition, many properties are adding bed-bug lease addenda to the HUD Model Lease that may contain provisions conflicting with the Model Lease or current guidance. HUD is therefore drafting an updated notice. Until the new notice is published, HUD has provided Model Lease guidance through the memorandum.
HUD Field Office staff must approve any additions, including addenda, or changes, to the Model Lease. The memorandum lists a number of provisions HUD staff should consider before granting approval and should deny any addenda that contradict the listed provisions. Several of those provisions include:
- The Model Lease requires landlords to provide extermination services, as necessary.
- Rental assistance, owner advances, and reserve-for-replacement funds may be used to control infestations.
- A regular, proactive inspection program by management is a crucial component of IPM.
HUD concludes that its Field staff should rescind any leases or addenda that shift the burden for inspection, reporting, and cost of extermination to residents.
The memorandum is at: https://bit.ly/2VDwdD9