Resident screening a potent weapon in the fight against terrorism; the alert recently issued by the FBI about the possibility of terrorist activity taking place in multifamily housing units underlines the importance of resident screening. Barnett offers property managers some recommended guidelines that could help them make their communities more safe.

In the aftermath of September 11, terrorism and security have become central concerns for millions of Americans. These issues were brought directly to the multifamily housing industry in May 2002 when the FBI's Joint Terrorism Taskforce (JTTF) issued an ominous warning that terrorists may be targeting apartment buildings for future attacks. Specifically, the JTTF indicated that terrorists may be planning to rent apartments for the purpose of storing explosives.

In an increasingly dangerous world, property managers should make it a priority to put together comprehensive policies to reasonably safeguard their residents and their facilities. Policies should include contingency plans for disaster response, appropriate emergency training for onsite staff, and any precautions recommended by the FBI and local law enforcement. There are no shortcuts or easy answers for dealing with the threat of terrorism. The only thing that is certain is that there are a variety of actions property managers can take to protect their apartment buildings.

A New Way of Doing Things

Perhaps no action a property manager could take is more important than resident screening. Without a doubt, September 11 has changed the way property managers in the United States view resident screening. In the past, managers screened rental applicants primarily to evaluate the likelihood that an applicant would pay the rent each month. Today, more and more property managers are focusing on screening as a preventative measure against violent crime, including terrorism.

Incorporating a handful of proactive steps into the resident-screening process will help prevent dangerous individuals from exposing a rental community to a host of unpleasant and potentially life-threatening scenarios. Here are a number of options that should be considered for resident screening.

Verify Identity of All Applicants

Require a completed rental application and original identification documents from all prospective residents and occupants over the age of 18. Incomplete applications and copies or faxes of identification should not be accepted.

Property managers should inform applicants that their applications cannot be processed until all the paperwork is in order. Identification documentation should include a Social Security card; driver's license or other government-issued photo identification; W-2 and pay stub as evidence of employment and/or student identification and current class schedule as evidence of school enrollment; bank check from an existing account; and, for applicants who are not U.S. citizens, a visa, green card or other evidence of an applicant's right to reside in the United States.

Photo identification is particularly useful in the event that law enforcement officials seek to confirm the identity of a resident. All applications, and copies of submitted identification, should be secured to prevent the inadvertent or improper disclosure of confidential information.

Obtain Consumer Reports

Request a consumer credit report and a separate report which includes rental history and landlord/tenant disputes for each applicant.

The vast majority of all adults living in the U.S. have a consumer credit file. A recently opened credit file or the absence of any meaningful credit history requires explanation. In the event of a "No Record Found" search result, or if no credit history exists, order a search based on an applicant's Social Security number.

Social Search (1) and TRACEplus (2) are two such services. These reports help identify application fraud, verify the authenticity of Social Security numbers, provide additional names that applicants might have used in the past, and identify addresses and employers that have been associated with the applicant.

Review Materials for Consistency

Confirm that the addresses and identifying information contained in a rental application are the same as information on identification documents and all consumer reports.

Birth dates, Social Security numbers, names and addresses should appear consistently on all documents. Terrorists and other criminals are unlikely to use the same name over a long period of time for fear of being traced. Inquire about any discrepancies or any gaps in residence history and employment history. Differences that are not explained satisfactorily may be evidence of identity theft or application fraud.

Verify Information

Obtain employment references and/or confirm school enrollment. A phone call can be invaluable in verifying that applicants are either gainfully employed or are full-time students.

Do not simply take an applicant's word as verification. Documents submitted by an applicant may be altered or forged. Make it policy to speak with employers and school registrars or obtain independent verification. Whenever possible, use phone numbers obtained from directory listings or other resources to ensure that references are legitimate.

Obtain Criminal Record Reports

Criminal record reports are now generally available at modest cost for states and counties throughout the U.S. Terrorists often rely upon criminal activity to obtain the means by which they carry out their acts of terrorism.

Obtain OFAC Reports

The Office of Foreign Assets Control (OFAC) within the Department of the Treasury administers and enforces trade sanctions against targeted individuals, organizations and countries involved with terrorism or narcotics. Your applicants can be compared to the official OFAC listing of individuals associated with suspected terrorist and narcotics activities. Sources are able to provide owners with these reports.

Obtain Proof of Authorization

As mentioned, require a visa, green card or other evidence of an applicant's authorization to reside in the United States if the applicant is not a u.s. citizen. Make sure the authorization has not expired and is not scheduled to expire during the term of the lease.

If the applicant is unable to produce such documentation, property managers may consider contacting the Immigration and Naturalization Service (INS). The INS is charged with enforcing the immigration laws of the United States and is responsible for identifying and removing illegal immigrants from the United States. Reports may be filed with local INS field offices. Locations and phone numbers for field offices are available online at www.INS.gov.

Screen Residents on a Recurring Basis

In our dynamic society, it is possible that someone who may have been an acceptable resident in the past is now involved in criminal or terrorist activities. Property managers may want to consider ordering criminal-record reports and the other background checks discussed in this article on a periodic basis. This may uncover new data that has become available since a resident signed a lease.

Conducting annual or semi-annual screenings can ensure that property managers remain vigilant and watchful of threats to their communities. Of course, managers should be certain that lease agreements specifically authorize them to obtain additional criminal and consumer reports during and after the lease term, and allow owners to terminate a lease in the event certain criminal offenses are disclosed.

Summary

September 11 has clearly touched all Americans very deeply. The multifamily housing industry is no exception. As housing providers for millions of families across the country, property managers should understand the important role they can play in helping to keep their communities reasonably free from unauthorized individuals as residents.

By incorporating the steps addressed in this article into a cohesive screening policy that is applied consistently and fairly to all applicants, property managers might be able to lower their exposure to risk, improve the chance for security for their residents and do their part in the nation's ongoing fight against terrorism.

To assure compliance with federal, state and local laws, including Fair Housing laws and The Fair Credit Reporting Act, property managers should draft written screening policies, have them reviewed and approved by legal counsel, and train leasing personnel to apply them uniformly to all applicants.

For information about the FBI's recent warning to property managers, and to report any suspicious activity that may be related to terrorism, contact a local FBI office. Contact information is available at www.FBI.gov and at www.naahq.org.

NSC Members Who Provide Resident Screening

ChoiceDATA
www.choicedata.com

First American Registry
800/999-0350

Resident Data, LLC
www.residentdata.com

SafeRent Inc.
www.saferent.com

The U.D. Registry
www.udregistry.com

(1) Social Search is offered by Experian.

(2) TRACEplus is offered by TransUnion.

Even Barnett is President of First American Registry. He can be reached at 301/881-3400 or e-mail [e-mail]