According to 24 CFR 214.315(b) File retention requirements: financial records, supporting documents, statistical records and all other pertinent records, both electronic and on paper, shall be retained for a period of 3 years from the date the case file was terminated for housing counseling. If the housing counseling agency is a recipient of a HUD housing counseling grant, then the client files for the housing counseling grant year must be retained for 3 years from the date the final grant invoice was paid by HUD.
Hence, if the participating agency closing is an affiliate or subgrantee, the intermediary, multi-state organization (MSO), or state housing finance agency (SHFA), the participating agency should request and retain any closed files that are subject to the file retention requirements outlines in the Handbook. If there are any active files, the intermediary, MSO, or SHFA should facilitate a transfer of those files/clients to another nearby agency if possible.
If the agency closing is a local housing counseling agency (LHCA), intermediary, MSO, or SHFA, the agency should assure that all files are closed, and any files that are subject to the file retention requirements are the responsibility of the agency until the file retention period is complete.
The Federal Register 24 CFR 214.315 can be access at: https://www.ecfr.gov/current/title-24/part-214/subpart-d
Hence, if the participating agency closing is an affiliate or subgrantee, the intermediary, multi-state organization (MSO), or state housing finance agency (SHFA), the participating agency should request and retain any closed files that are subject to the file retention requirements outlines in the Handbook. If there are any active files, the intermediary, MSO, or SHFA should facilitate a transfer of those files/clients to another nearby agency if possible.
If the agency closing is a local housing counseling agency (LHCA), intermediary, MSO, or SHFA, the agency should assure that all files are closed, and any files that are subject to the file retention requirements are the responsibility of the agency until the file retention period is complete.
The Federal Register 24 CFR 214.315 can be access at: https://www.ecfr.gov/current/title-24/part-214/subpart-d