Housing Lottery Documentation Checklist

The agencies that get into trouble over a lottery are almost never the ones that did something wrong. They are the ones that cannot demonstrate they did something right. This checklist is the demonstration, organized around the moment of the drawing, because nearly everything on it costs almost nothing to capture at the time, and may be impossible to reconstruct later.

The reasoning behind each item is in the companion guide, How to Document a Housing Lottery So It Survives a Challenge. This page is the part you tape to the monitor.

Download the printable one-page version (PDF) (free with an AuditDraw account)

Before the drawing

• [ ] Confirm your written policy covers this drawing. Your admission policy or lottery procedure must state the selection system you use (24 CFR § 982.202(d) for HCV; your program's equivalent otherwise). Locate the version in effect today: that exact document is part of the record.
• [ ] Freeze the applicant list. The moment entries close, save an exact copy of the source file and set it aside. Not the working copy you'll keep editing: the unmodified input, preserved as-is.
• [ ] Designate who runs it. Name the operator (a staff member or a neutral third party) in the record. "Who ran it?" is always one of the questions.
• [ ] Plan the public-safe copy now. Decide before the drawing how results will be shared without exposing applicant names or contact details (application or ticket numbers work). Deciding after, under deadline pressure, is how PII gets released by accident.

During the drawing

• [ ] Capture a timestamp on every draw, not just the run. A record showing each entry drawn at its own distinct moment demonstrates a sequential process. A single "completed at 2:14 PM" line does not.
• [ ] Keep a log as it happens. A contemporaneous log is evidence; a log written afterward is a summary. Note the start, each step, any interruption or anomaly, and the finish, while they occur.

Immediately after

• [ ] Preserve the complete draw order. Every entry, every position, not just the winners. Waitlists get worked far deeper than anyone expects, and a record that stops at position 40 is useless when you're calling position 41 in month fourteen.
• [ ] Generate the public-safe version now. Produce the PII-removed results and log at the same time as the full versions, per the plan you made before the drawing.
• [ ] Attach something that proves the files haven't changed. A signature computed from the data itself, such that altering any character produces a different signature. This is the component almost nobody has and the one that does the most work: a file that can be edited silently cannot testify to its own integrity.
• [ ] Archive the set together. Source file, draw order, timestamps, log, public-safe copies, signature, the policy in effect, and the operator's name: one sealed package, stored where it won't be "cleaned up."

Retention

• [ ] Keep everything at least three years (24 CFR § 982.158(f) for HCV programs). HUD and the Comptroller General have the right to full and free access, including examining and copying records.
• [ ] Longer for other programs. LIHTC retention requirements generally exceed three years and are set by your state allocating agency; tribal programs follow NAHASDA; municipal programs follow local ordinance.
• [ ] Under challenge, keep everything indefinitely, until the matter is fully resolved, regardless of the minimum.

The eight-question test

A complete lottery record answers all eight. Run your most recent lottery through this table.

If you run lotteries in a spreadsheet today, working this checklist closes most of these rows without changing tools. The row it cannot close is "has anything changed since": a tool that lets you edit a file cannot also prove the file was not edited. That gap is solvable; see Why a Spreadsheet Isn't Evidence for what closes it.