CoC records are kept the greater of five years or the stated period, participant records five years after all grant funds are spent, and housing locations are not made public

coc.recordkeeping.five_year_retention_and_confidentiality_of_location · v1.0.0

All records pertaining to Continuum of Care funds must be retained for the GREATER OF FIVE YEARS or the period specified for the record type. Documentation of each program participant's qualification as homeless or at risk of homelessness, and other program participant records, must be retained for FIVE YEARS AFTER THE EXPENDITURE OF ALL FUNDS from the grant under which that participant was served -- an anchor that can run well past five years from the participant's own file activity. Where funds were used for acquisition, new construction or rehabilitation of a project site, records must be retained until 15 YEARS AFTER the site is first occupied or used by program participants. In addition to HMIS data security requirements, the recipient and its subrecipients must develop and implement WRITTEN PROCEDURES ensuring that all records containing protected identifying information of anyone who applies for or receives CoC assistance are kept secure and confidential; that the address or location of any family violence project assisted with CoC funds is not made public except with the written authorisation of the person responsible for its operation; and that the address or location of any program participant's housing is not made public except under a preexisting privacy policy of the recipient or subrecipient and consistent with State and local privacy law and confidentiality obligations. HUD, the HUD Inspector General and the Comptroller General have a right of access to all records pertinent to the grant, and that right is not limited to the retention period -- it lasts as long as the records are retained.

Confidence

high

Effective from

2016-11-16

Consequence model

agency finding with cure

Last reviewed

2026-08-29