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REAC Inspector Business Rules and Code of Conduct

On February 5, 2016, HUD Issued updated to HUD REAC Inspector’s Business Rules and Code of Conduct. This notice issued a new code of conduct for inspectors. This new set of REAC Inspector business rules is an update to the existing inspector business rules dated January 20, 2006. This memorandum sets forth basic rules of behavior, a Code of Conduct, and instructions to REAC inspectors on how to handle situations that may arise.

The significant changes to the REAC Inspector Business Rules that will affect owners/managers relate to updates to the Code of Conduct.

REAC Inspector Business Rules States Inspectors Must:

  • Display the REAC-issued photo identification card throughout the entire inspection;
  • Respect resident privacy. For example, inspectors must not attempt to open a closed door in a unit.  They must defer to the property representative.
  • Comply with reasonable requests from residents and project representatives during the inspection;
  • Defer all questions from residents regarding the property to the property representative accompanying the inspector; and
  • Defer all questions from third parties about the inspection or the results to the property owner or representative.

REAC Inspector Business Rules States Inspectors must not:

  • Express opinions or make comments about the nature or condition of the property or residents.
  • Make representations or promises to residents or property representatives or staff that items will be repaired based on inspection results.
  • Active REAC Inspectors may not attend an inspection conducted by another HUD certified UPCS inspector as a consultant.
  • Include in attendance or participation during a UPCS inspection any unauthorized person, including family, friends, or UPCS certified/decertified inspectors.
  • Use any facility on a property, property owner’s office, housing agency office, or HUD field office to conduct personal business.
  • Use profanity or other offensive languages before, during, or after an inspection.
  • Engage in fraudulent activities, such as but not limited to, falsifying an inspection.
  • Be under the influence of alcohol or drugs during the inspection, and
  • Smoke anywhere on a property.
  • Threaten, verbally or in writing, residents, inspection participants, property representatives, or any other individual with whom the inspector comes in contact, and
  • Carry a firearm or weapon of any kind, or any other weapon-like object on a property.
  • Commit theft or intentional damage to property.
  • Cancel an inspection due to a QA review.
  • Threaten or engage in violence against any person while conducting an inspection; and
  • Engage in sexual misconduct or any other type of unwanted conduct.

What is new to this Code of Conduct Update?

There are a few items in the above that are notably new, namely that REAC inspectors cannot accompany other REAC Inspectors on inspections as representatives of management or as consultants. This new rule is essential, as there are a number of consulting firms that utilize active REAC Inspectors to conduct REAC Inspection Shadow Inspections. Secondly, it has clarified rules regarding comments about resident’s homes. Most importantly, it has clarified rules regarding fraudulent or improper behavior.

If you should have any questions about this new notice or any of its contents, please do not hesitate to contact us at any time.

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