Employee Records Management Checklist

Match the name on the executed offer letter to the List A or List B+C documents the employee will present for I-9. Capture aliases — maiden names and prior surnames — because state real estate license lookups and FCRA background reports cross-reference them.

Field staff drive alone between properties — capture both the residence address and a mobile number that reaches the employee outside business hours. Note the preferred channel for after-hours dispatch.

The contact lives in the personnel file AND in the on-call dispatch tool (Latchel, AppFolio, your answering service). Refresh annually — turnover in personal relationships outdates this faster than people expect.

File both documents — the executed offer letter and the role-specific job description (leasing agent, maintenance tech, assistant property manager, portfolio manager). The job description is what any later disciplinary memo or PIP will be measured against.

Federal deadline is three business days from the start date. Pull the current Form I-9 from uscis.gov — the form revises periodically and using a stale version is its own violation. If the firm participates in E-Verify, run the case within three business days as well.

Federal W-4 plus the state equivalent — DE 4 in California, IT-2104 in New York, M-4 in Massachusetts, A-4 in Arizona. The direct-deposit authorization and a voided check belong in the same packet.

Confirm the new hire received the SBC for medical and the Section 125 election form. Most plans require enrollment within 30 days of hire or coverage waits until the next open enrollment — missing the window is the most common onboarding complaint.

Leasing agents and maintenance techs are almost always non-exempt; portfolio managers may qualify for the administrative or executive exemption. Misclassification is the FLSA case that gets the firm sued — overtime owed plus liquidated damages plus attorney fees.

States vary. California, Colorado, and Florida generally require a real estate salesperson or broker license for leasing and property management activity, with narrow onsite-employee exemptions. Confirm against the state real estate commission rule before the start date — operating without a required license can void the leases the employee touches.

Pull the license from the state portal — DRE in California, DBPR in Florida, DORA in Colorado, TREC in Texas. Set a calendar reminder 60 days before expiration; CE-hour requirements vary by state and lapsed licenses pull leasing activity offline.

Anyone driving on company business — leasing tours, maintenance dispatch, drive-by inspections, owner meetings — needs an MVR check and a non-owned auto endorsement. Office-only staff don't.

Run the motor vehicle record through the screening vendor and capture a personal auto certificate showing minimum state limits plus the firm listed as additional insured for non-owned auto coverage. Refresh annually — most carriers email the renewal certificate automatically if asked.

Use an FCRA-compliant vendor (Checkr, GoodHire, TransUnion ShareAble). If a report item disqualifies, send the FCRA pre-adverse action notice with a copy of the report and the summary of rights, wait the required window, then send the adverse action letter. Property management roles handle tenant deposits and master keys — this step is non-optional.

NAA's Fair Housing course or the state apartment association equivalent. Anyone touching applications or showings needs this within 30 days of hire and annually thereafter — the certificate is the firm's first defense if a tester complaint lands.

California SB 1343 requires sexual harassment training every two years for all staff at firms of five or more; New York and Illinois have annual requirements. OSHA bloodborne-pathogen and chemical-hazard training applies to maintenance staff with cleaner and solvent exposure.

The first-90 review surfaces fit issues before they become PIPs. For leasing roles, pull conversion metrics from AppFolio or Buildium; for maintenance, pull work-order close rate and tenant satisfaction. Document the outcome — continue, extend probation, or part ways — with both signatures.

Counseling memos, written warnings, and PIPs go in the personnel file under signed acknowledgment — refusal to sign gets noted by a witness. Recognition (NAA CALP designation earned, leasing-of-the-month, owner commendation letters) lives in the same file.

OSHA 300 log entries for any recordable injury, plus ADA accommodation requests and the interactive-process documentation. Maintenance techs are the typical population — falls from ladders, lacerations during make-ready, chemical exposure from drain cleaners.

Walk the file against the new-hire checklist: I-9, W-4 and state withholding, real estate license (if applicable), MVR and auto certificate (if applicable), Fair Housing certificate, anti-harassment certificate, current emergency contact. The annual audit catches expired licenses and stale contacts before they become a liability.

I-9 retains three years from hire OR one year from termination, whichever is later. Payroll records retain three years under FLSA, four under FUTA. FCRA background reports retain five years post adverse action. Keep medical and ADA accommodation files in a separate, access-restricted folder under HIPAA-aligned controls — don't shred early and don't comingle.