Kingsbury Corporation's Twin Towers
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Kingsbury Tenant Selection Policy

Revised 02/01/2014

Moderate Income Management Co., Inc. has prepared a Tenant Selection Policy which has been approved by the Kingsbury- a non- profit housing corporation’s Board of Trustees and is in accordance with the HUD regulations. This plan establishes a set of policies which are consistently applied to all residents and applicants regarding the marketing, tenant selection and ongoing occupancy.

Kingsbury’s Twin Towers contains a total of 364 units. 308 are funded under the Section RAP program and of these units 238 are one bedroom, 62 are two bedrooms and 8 are three bedrooms. The additional 49 units are funded under the Section 236 program and of these units 19 are two bedrooms and 30 are three bedroom units.

I. Fair Housing Act Amendments of 1988:

The Fair Housing Act prohibits discrimination in housing and housing related transactions based upon race, color, religion, sex, national origin, disability and familial status.

Management will not:

Refuse to rent or negotiate for rental of a dwelling based on race, color, religion, sex, national origin, disability or familial status;

Engage in activities that steer potential residents away from or toward particular units by words or actions;

Make housing units and related services unavailable to any potential resident;

Purposely provide false information to applicants about the availability of units that limit the living options of prospective residents;

Deny or limit services based upon race, color, religion, sex, national origin or familial status.

Management will market the available units in accordance with the AFMP in a non- discriminatory manner.

The Federal Fair Housing Act provided additional protections for persons with disabilities. Management will make reasonable accommodation and/or modification to affordance disabled persons equal opportunity to use and enjoy the dwelling unit.

ii. Section 504 of the Rehabilitiation Act of 1973:

Section 504 of the Rehabilitation Act of 1973 prohibits discrimination based upon disability in all programs or activities operated by recipients of federal financial assistance.

The Owner has designated one person for the property to coordinate efforts to comply with Section 504 requirements.

Deborah Gershen can be reached at (609) 989-8500 or P.O. Box 3709 Princeton, NJ 08543.

The Owner/Agent will seek to identify and eliminate situations or procedures that create a barrier to equal housing opportunity for all. In accordance with Section 504, the Owner/Agent will make reasonable accommodations or modifications for individuals with a disability. See REASONABLE ACCOMODATION SECTION.


It is the policy of Grace Housing, Inc. to guard the privacy of individuals conferred by the Federal Privacy Act of 1974 and to ensure the protection of such individuals’ records maintained by the Owner/Agent.

Eligibility Requirements:

  1. Income Limits for the Property are established and adjusted annually. The household’s annual income may not exceed the applicable income limit for this property for the household size. (Area Income Limits are attached as attachment No. 1). Those units in the community which provide subsidy through the RAP program are required to admit applicants in accordance Low Income Limits - who meet the income limits at 60% of the current median income level. 2.) Those units in the community who entering through the 236 program are required to meet the income limits at 80% of the current median income.

  1. Rent - The applicant must agree to pay the rental amount established at the in-take interview as approved by the Contract Administrator and HUD.

  1. Only Residence - The unit must be the household only resident and receive assistance only in one unit. Assistance may not be provided to households who will maintain another residence in addition to the assisted unit. This rule is meant to ensure that the Government pays assistance for only one unit for a household and provides assistance to as many eligible households as possible with available funds.

  1. Household - Definition of applicable households for this property are made in paragraph I. The household must be appropriate for the size of the unit as described in Unit Standards.

E. Social Security Numbers - The applicant must disclose the Social Security numbers for all applicants and residents from birth on up. If a household member does not have a Social Security number the applicant must sign a certification to that fact.

  1. Restrictions on Assistance to Non-Citizens - Assistance can only be provided for applicants and their household members if they are either United States Citizens, Nationalized Citizens or have eligible immigration status.

1. Applicants and all household members claiming to have eligible immigration

status AND who are 62 years of age or older must sign a declaration attesting to such status AND provide proof of age.

  1. Applicants and all household members claiming to have eligible immigration status AND provide INS documents supporting said status. When the household member is claiming eligible immigration status ALL information provided in support of eligible immigrations status must be independently verified with the INS before eligibility can be determined.

  • Assistance can only be provided for household members whose eligible immigration status has been verified.

  • Should the household contain eligible and ineligible household members, assistance will be provided in accordance with HUD regulations.

  1. Student Status Restriction: restrictions of income for section 8 assistance, an owner

must first determine whether or not the individual is:

    • Under the age of 24 and

    • Enrolled at an institution of higher education

Once it is determined that the individual is a student then the owner needs to determine whether or not the student:

  • Is a veteran

  • Is married, or

  • Has a dependent child

If the student does not meet any of the second set of criteria, then there is a two-part test that must be met in order for the student to be eligible for section 8 assistance:

(1) the student must be eligible for section 8 assistance AND

(2) the student’s parents, individually or jointly, must be eligible for section 8 assistance.

UNLESS the student can demonstrate his or her independence from parents.

  1. All adults in each applicant household must sign the Authorization for Release of Information prior to receiving assistance and annually thereafter.

  1. Information reported by the household is subject to verification prior to receiving assistance and annually thereafter.


  1. Family -two or more persons sharing a residency.

  1. Elderly person-one who has attained the age of 62.

  1. Elderly household-a household whose head, co-head or spouse is 62 years of age, handicapped or disabled and at least 18 years of age. NOTE: a household may not designate a family member as head of household solely to qualify as an elderly household.

  1. Live-In Aide/Attendant - a person who lives with an elderly, handicapped or disabled person and is essential to that individuals care and well being; not obligated for the individual’s support and would not be living in the unit except to provide support services. The Live-In Aide/Attendant may not qualify as a remaining family member should the tenancy end for any reason. An aide must complete a certification with the Management office.

  1. Handicapped Person - a person with a physical or mental impairment that:

  • is expected to be of long-continued and indefinite duration

  • substantially impedes that person’s ability to live independently

and is improved by more suitable housing

  • meets the occupancy regulations of the project.

  1. Disabled person - as defined by the Housing Act of 1989

  1. Verifications – will be obtained in accordance with the HUD Handbook 4350.3 and HUD Notice 2011-21. All verifications will be attempted in the following priority: EIV verifications, 3rd party and finally 1st party.

  1. LGBT Families and Individuals- HUDNo.12-014 provides that all core HUD programs are open to all eligible persons, regardless of sexual orientation or gender identity.


Occupancy standards serve to prevent the over or underutilization of the housing units. Occupancy standards also ensure that residents are treated fairly and consistently.

  1. The decision to allow unit transfers will be at the sole discretion of management, based upon changes in family composition and/or possible medical condition. These will be made based upon written verification provided by the residents.

  1. Minimum/maximum bedroom distribution with respect to this project will be in accordance with Fair Housing standards and municipal codes.

1 BR: 1-2 Persons

2 BR: 2-4 Persons

3 BR: 4-6 Persons

  1. Units with one or more bedrooms will be assigned based upon the principle that two members of the same sex regardless of age may share a bedroom.

  1. Units designed specifically for the handicapped will be reserved solely for families whose head, co-head or spouse qualifies for the unit.

Exceptions to occupancy standards are subject to prior written approval by HUD or the Owner.

V. Accessible Units:

Disabled applicants in need of architecturally adapted units are processed to assure maximum utilization of adapted units by persons who require accessible features. If some form of assistance is needed to enable an applicant to comply fully with the lease terms, screening staff will obtain verifications that such assistance is available to the applicant. The certification of an individual or agency providing assistance form will be used for this verification.

Screening personnel will keep in mind that an applicant with a disability who may, for example, be unable to care for a current apartment alone, may still qualify for the unit. Assistance could be in the form of a live-in-aide, or it could be a friend, family member or a social service agency. It is not it the province of the property to make judgments about the best way for assistance to be provided.

An example of a reasonable accommodation might be approving an applicant for a dwelling unit larger than that determined by the occupancy standards, to permit occupancy by a live-in-aide who would assist the applicant with some aspect of lease compliance, which the applicant would not otherwise achieve.

Accommodations, to be considered reasonable, must not cause undue financial and administrative burdens or an alteration in the fundamental nature of the assisted housing program. If the service is necessary for compliance with the lease, the property cannot be required to provide it to an applicant with a disability if it is not provided to other residents, but the property must consider admitting that applicant if he or she can document that the service will be provided by others at no cost to the property.

A reasonable modification is alteration to the physical characteristics of a dwelling unit or to the common areas of a building, requested by an applicant or resident, to allow accessibility by a member of the household.

Accessible units shall be offered first to internal transfers who need the features:

If an accessible unit must be offered to someone who does not need the features, the lease shall include a clause requiring the resident to move to the first available comparable unit if an internal transfer or and eligible applicant requires the features. If the resident refuses to move within a 30 day period, it may become necessary to commence legal action.


If a member of the household is absent from the unit due to military or education purposes and leave a spouse or a dependent in the household, they will remain a household member. If an adult member of the household is absent due to criminal charges or being incarcerated for a period of 1 year or longer, the member will be removed from the lease and will no longer be part of the household and will be required to re-apply for admission. If the member is away from the unit for more than a 180 day period due to a medical reason, verification of the date of return is required to be provided by a member of the medical community. The absent member may not be considered head, co-head or spouse.


  1. Any person who is 18 or older may apply to be added to the waiting list. Household members may be considered even if they are not related directly to the primary family. Management will offer aid to the applicant in completing the application and explain tenant selection process.

  1. When the marketing of units generates an application pool such that the waiting list period is more than one year the Owner will suspend the intake of names of preliminary applications by means of public notice to that effect, posted in the office where applicants are interviewed. The determination as to one years’ pool of applicants shall be the average of the past five years move outs plus an additional one hundred names.

  1. When the application pool diminishes to a point where the waiting list period is less than one year, the Owner will re-market pursuant to paragraph IB above.

  1. A permanent record, maintained in an applicant log book in a format approved by HUD will record all applicants who have applied to the project.

  1. Applications will be removed from the list if the applicant has not responded to the update of the waiting list as required.

  1. The Owner shall be responsible for determining eligibility of applicants in accordance with 24 CFR 812 as well as HUD 4350.3 and NJHMFA guidelines.

G. All applications received will be numbered, dated and time stamped and must be updated by the applicant at least once yearly as requested in writing by the project. All applicants are processed to one of three ends: applicants are admitted to a unit; applicants are rejected because they do not meet all of the eligibility criteria; applicants remain on the waiting list until an appropriate size unit becomes available.

NOTE: Being placed onto the waiting list does not guarantee a lease offering. The applicant can be subsequently rejected for failing one or more of the tenants screening criteria, and/or the eligibility criteria

H. Occupancy for this project will be made in accordance with paragraph III Eligibility


I. A written application must be completed by all applicants in full. An application which is incomplete will be returned to the address on the application or the envelope prior to any additional consideration of the application for housing. An application may be picked up at the rental office or the applicant may request that an application be mailed to them. Applicants must provide a government issued photo identification.

  1. If the waiting list is closed, interested persons may place their names and addresses onto an inquiry list. This list will notify persons of the status of the waiting list only. Should the waiting list be opened through public notice, those persons with their names on the inquiry list will receive a post card indicating the procedures to be followed in order to obtain a place on the property’s waiting list.

  1. All communications will be completed in writing.


Kingsbury’s Twin Towers may request that a tenant or applicant to certify that the individual is a victim of domestic violence. Dating violence or stalking and that the incidence(s) of threatened or actual abuse are bona fide in determine whether the protections afforded to such individuals under VAWA are applicable.


Screening is used to help ensure that households admitted to Kingsbury’s Twin Towers will abide by the terms of the lease, pay their rent, and take care of the property and the unit allowing all residents to peaceful and quiet enjoyment of the community. The tenant screening and rejection criteria always apply to all individuals listed as head of household, spouse or co-head of household who are expected or proposed to reside in the unit. This includes but is not limited to live in aides, security/police officers or any additional household members. Therefore: An applicant household and/or an additional household member who is proposed to reside in the unit will be refused occupancy for one or more of the following reasons:

A. An applicant household and/or additional household members who are proposed to reside in the unit will be refused occupancy for one or more of the following reasons:

  • If an applicant fails to meet one of more of the eligibility criteria;

  • If the applicant submits false information about themselves or any household member;

  • Poor Credit history which is indicated by:

  1. Any credit rating reflecting a payment history of two instances of over ninety (90) days or more past due or one instance of over one hundred twenty (120) days past due within the past 24 months


  1. Any credit history that is an indication of irresponsible behavior that indicates future problems for the development


  1. Upon review of six (6) months rent receipts, those applicants whose receipts evidence a late payment record (more than ten (10) ten days past due on two or more occasions) may be rejected on the basis of poor rental habits. The exception to this is applicants who have been residing with friends or relatives and who have no prior leasing experience for the last year or more.

  1. If Legal action has been started 4 or more times in the immediate 5 years in order to have the applicant pay monies which are owed.

B. All landlord references will be accomplished by telephone with a record kept of statements made indicating date, time and person spoken to from the landlord’s office. After oral representation is indicated, a written landlord reference form will be mailed for written verification. In every case the previous landlord and present landlord will be contacted for the previous five years. More weight will be given to the previous landlord statements.

  • Poor Landlord reference within the past five year which would be indicated when a previous landlord shows the applicant to be:

  1. Continually late in payment of rent

  2. A source of conflict with management and/or other residents

  3. Destruction to his apartment or other public areas

  4. In violation of previous lease agreements

  5. If the landlord commenced legal action to evict a resident for non- payment or material non- compliance four or more times in the immediate 5 years

  1. Criminal and credit background checks will be completed on all applicants. Adverse Police Record which would be indicated by the following:

  1. Any drug related arrests within the last ten (10) years

  2. Any arrests for assault and/or battery within the last ten (10) years

  3. Any felony conviction within the last ten (10) years

  4. Any life time registration for sex offensives

D. Any indication that the applicant can not adequately sustain decent levels of habitability or control of dependents so as to adversely affect the property or other residents.

  1. A personal interview that indicates an unstable or potentially hazardous relationship between the household and other residents.

  1. A personal interview and/or information that indicates the applicant or any household member would be a threat to the safety and well being of the property and/or other residents.

  1. A personal interview and/or information that indicates the applicant will be unable to comply with the terms of the lease agreement.

  1. Refusal to occupy property unit in accordance with HUD or Kingsbury’s Twin Towers regulations.

  1. Anyone who has committed any fraud in connection with any federal or state housing assistance program, and who owes rent or other amounts in connection with housing assistance.

  1. Conviction of an applicant, or member of applicant family for possession of an unregistered firearm or procession of an illegal weapon.

  1. HUD has prohibited admission of:

  • Any household which contains members who have been evicted from federally assisted housing in the last three years for drug related activity.

Exceptions: 1) the evicted household member has successfully completed an approved, supervised drug rehabilitation program; or 2) The circumstances leading to the eviction no longer exist (e.g., the household member no longer resides with the applicant household).

  • The applicant or household family members in the past 3 years engaged in abuse or pattern of abuse of alcohol.

  • The applicant or household member is a current illegal user of one or more controlled substance as defined by state law.

  • Any household member or applicant who is subject to any state sex offender registration requirement or has been subject to lifetime inclusion on any state sex offender registration.

  • A person’s illegal use or possession of a controlled substance within the preceding twelve months shall create a presumption that such a person is a current illegal user of a controlled substance


Violent criminal activity includes the felonious criminal activity that has as one of its elements the use, attempted use, or threatened use of physical force against the person or property of other.

L. Each rejected applicant will be promptly notified in writing of the reasons(s) for rejection. This notice will advise the applicant that he/she may, within fourteen (14) calendar days of receipt of the notice, request in writing a meeting to discuss the reasons for rejection. Should the applicant request a meeting to discuss the rejection, it will be conducted by a member of the management staff that was not involved in the original decision to reject the applicant. The applicant will be advised in writing of the results of this meeting within five (5) days.

M. Requesting a meeting to discuss the reasons for rejection will in no way prevent the applicant from exercising any legal rights s/he may have. The applicant will be advised of this at the time of rejection.


  1. The amount of the security deposit shall be made at the time of move in and is not changed when the Tenant’s rent is changed.

  1. For Section 236-the security deposit shall not exceed the monthly tenant rent.

  1. For RAP, new construction the security deposit shall not exceed the total monthly payment or $50.00, whichever is greater.

  1. For a unit transfer the security deposit will be transferred to the new unit.


This community does not permit pets.


  1. Following the appropriate HUD guidelines, the Owner will examine and verify the income and family composition of all assisted tenants both initially and thereafter annually. The Owner will initiate the certification process in accordance with the 4350.3 procedures.

  1. The attached lease will be used in leasing the units of this property. The lease term is in conformation with HUD regulations and has been approved by the HMFA.

  1. Each family will be given a welcome package which will include:

  • a copy of the lease

  • house rules

  • the 50059 as approved

  • rights and responsibilities brochure

  • key signature forms

  • recycling information

  • welcome letter

  • crime insurance notice

  • personal insurance notice

  • truth in renting statement

  • emergency forms

  • security deposit damage list

  • fire/emergency plan

  • building registration statement

  1. Evictions will be handled in accordance with the HUD regulations in 24CFR880.607 as well as the laws of the State of New Jersey. Every opportunity will be given to preserve the resident’s tenancy.

  1. When a vacancy occurs, every effort will be made to ensure that it is promptly filled. First preference will be given to those families who have had a change in family composition. Next, those families who meet the local resident preference. Then to those families as they appear on the waiting list in chronological order.

  1. Management MUST approve any new household members BEFORE s/he moves into the unit. The proposed new household member will be considered an applicant and must participate in the eligibility determination and screening process described in this document. In addition, the rent payment will be re- calculated to reflect any income or allowances for the new household member.

  1. Owner/Agent established screening criteria will also be applied to live in aide- EXCEPT for the criteria regarding credit performance or the ability to pay rent because the live in aide is not a party to the lease and not responsible for the payment of rent.

  1. Kingsbury’s Twin Towers will verify all information listed on the application for housing or on the recertification check list in accordance with the 4350.3.

Applicants currently receiving HUD assistance;

  • Income not previously reported;

  • New employment;

  • Historical patterns of earnings and received income;

  • Multi-subsidy verifications for household members included in both PIC and TRACS databases;

  • Deceased household member(s).

Applicants to the Community;

  • Existing Tenant Search;

  • Deceased Household members;

  • Multiple subsidy programs.


The Owner will comply with all Federal, State and Local Fair Housing and Civil Rights Laws and with the Equal Opportunity requirements in HUD-administrative procedures.