HUDBlast October 11, 2007

Enterprise Income Verification (EIV)

For an archive of HUDBlasts visit RBD online at www.rbdnow.com

EIV Coordinator Update

Attention Enterprise Income Verification (EIV) System Coordinators

·        The first annual re-certificaton of an EIV Coordinator’s contract(s) and/or property(ies) within EIV is due by October 31, 2007. 

EIV Coordinators must complete an updated Coordinator Access Authorization Form (CAAF) requesting re-certification of their contract(s) and/or property(ies) and submit it to HUD’s Multifamily Helpdesk according to the following schedule which is based upon when they submitted their initial CAAF for access to EIV.

·        If the initial CAAF was sent between July 21, 2006 and November 30, 2006, the re-certification CAAF request must be sent before October 31, 2007 to avoid a possible interruption in service after this date.

·        If the initial CAAF was sent between December 1, 2006 and December 31, 2006, the re-certification CAAF request must be sent between November 16, 2007 and December 14, 2007 to avoid a possible interruption in service after December 31, 2007.

The updated CAAF is available on Multifamily Housing’s Enterprise Income Verification (EIV) System webpage at http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/eivhome.cfm under Helpful Tools.

The completed CAAF requesting recertification must be submitted to HUD’s Multifamily Helpdesk according to the above schedule via fax at 202/401-7984 or by email at: Mf_Eiv@hud.gov 

As the initial deadline of October 31, 2007 is fast approaching, EIV Coordinators who, based upon the above schedule, must submit their re-certification CAAF request by October 31, 2007 should do so as soon as possible because if it is submitted shortly before or after October 31, 2007, they are likely to experience a temporary interruption in service. HUD’s Multifamily Helpdesk will process these and all requests as quickly as possible.

Thank you for your patience and cooperation in adhering to the established schedule.

·        EIV Coordinators who submitted their initial CAAF requests for EIV access to HUD’s Multifamily Helpdesk on or after January 01, 2007 need not submit their CAAF requests for re-certification of their contract(s) and/or property(ies) to HUD’s Multifamily Helpdesk.  The capability for EIV Coordinators to see when their contract(s) and/or property(ies) is due for annual re-certification within EIV will come with the EIV 8.0 release scheduled for December 07, 2007. The ability to complete and submit on-line CAAF requests for re-certification of a contract(s) and/or property(ies) to HUD’s Multifamily Helpdesk for approval, through EIV, will also come with the EIV 8.0 release in December. The EIV User Manual and the External User Administration Manual will be updated to include instructions on using the enhanced EIV system.   

·        For continued updates, please see HUD’s Enterprise Income Verification (EIV) System Updates for Multifamily Housing Program Users web page at: http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/sysupdates.cfm  Thank you for your interest in HUD’s EIV System and for assisting the Department in further reducing income and rent determination errors in HUD’s rental assistance programs through use of the EIV system.

USERS MUST RE-CERTIFY BY END OF OCTOBER

For those of you who are EIV Coordinators and Users, Keep in mind that, while Coordinators are re-certified by HUD on an annual basis, Users must be re-certified each quarter.  October is User Re-certification month.  Once user certification is complete in October, users will have access to EIV through the end of the year (unless the coordinator terminates access). 

If Users do not request re-certification, or if the coordinator does not re-certify the user BY THE END OF OCTOBER, that User’s access to EIV will be terminated automatically. 

Users must request recertification for each property through the “Authorization Request” option on the bottom of the EIV menu. 

After Users have Requested Re-certification, Coordinators must re-certify users using the “User Certification” option under User Administration. 

Unfortunately, the Coordinator expiration dates do not show under the certification reports.  We will check with HUD and provide additional clarification regarding Coordinator re-certification in a future HUDBlast. 

If you have questions about re-certification, you should refer to the EIV System User Manual dated August 2007.  This manual can be accessed by clicking on the User Manual icon in EIV.  (Located below the menu options).  If you have additional questions, contact the Multi-family Help Desk. 

HUD Handbook 4350.3 REV-1 Summary of Questions:

The Final Multifamily Mailbox:  4350.3 REV-1 Summary of Questions has been reposted to the Multifamily Housing’s RHIIP website at http://www.hud.gov/offices/hsg/mfh//rhiip/mfhrhiip.cfm . 

The Summary of Questions was removed temporarily while the questions and answers were revised to comply with Change 2 to the Handbook.

A listing of Frequently Asked Questions pertaining to the revisions contained in Change 2 to the Handbook is being prepared and will be released at a later date.

RBD will monitor the RHIIP web site and let you know when the new Handbook FAQs are posted via a future HUDBlast.  This will probably be announced via the RHIIP ListServ as well.  If you do not receive the RHIIP ListServ, we recommend you register at http://www.hud.gov/subscribe/signup.cfm?listname=Multifamily%20Housing%20RHIIP%20(Rental%20Housing

%20Intergrity%20Improvement%20Program)%20Tips&list=MFH-RHIIP-TIPS-L

Additional Change 2 Clarifications from HUD

Destroying Criminal Records

There has been a lot of comment about the addition of Paragraph 8-14-C-13 which states the following:

13. All criminal records received are to be maintained confidentially, not misused or improperly disseminated; and destroyed upon completion of the originally intended use. When destroying records of criminal background, a notation should be made in the tenant file that includes the date the records are destroyed and a statement that the records were destroyed for purposes of confidentiality.

Since owners usually keep criminal information as part of the resident file, this represented a significant change to process for most owner/agents.  The question, I guess, is what defines “originally intended use”.  HUD provided the following response: 

“ the criminal background checks should be retained for the term of tenancy plus three years after tenancy is terminated.” 

Periodic Payments from Asset Accounts

The change in the asset calculation has been generating questions as well.  Keep in mind, if the asset is not making periodic payments then nothing has changed. 

For those assets distributing monthly or quarterly payments to your residents, you now count only the monthly/quarterly distribution.  The cash value of the asset and interest income from the asset is no longer part of the assistance calculation.  Because the Handbook language seems contradictory, we asked HUD for clarification.  See HUD”s clarification below:

“If the individual is receiving periodic payments from the investment, the investment is no longer considered an asset and the amount of the period payments is included in annual income. (see paragraph 5-6.O)

If the individual elects to receive the investment as a lump sum, the lump sum is included as an asset.  Of course, as with any lump sum how you treat it as an asset depends upon what the tenant does with the money, reinvests in a savings account, CD, etc.  (see paragraph 5-7.G.3)

If the individual has not received the investment as a lump sum or is not receiving period payments, the investment is considered an asset. (see paragraph 5-7.G.2)”

Lease Revision Dates

If you haven’t noticed, the lease revision dates are not consistently applied to the leases.  Some pages have the 5/03 revision date and some pages have the 6/07 revision date.  This has raised a few questions about whether you are required to produce a lease with the revision dates as they appear in the Handbook.  The answer is “no”.  See HUD’s clarification below: 

“It appears that most of the owner’s software doesn’t include the date because of printer variations.  As long as the language in the lease is not changed, unless approved by the HUD Field Office, then this is an acceptable practice. “

We send our sincere thanks to HUD for providing us with the clarifications above and look forward to additional guidance.  As HUD responds to your industry partners, and RBD becomes aware of new clarifications, we will forward information to HUDBlast subscribers. 

New Fact Sheets – How Your Rent Is Determined

As many of you may have noticed, the HUD Fact Sheets “How Your Rent is Determined” changed with the release of the 4350.3 Revision 1, Change 2.  This document is available in the Handbook and on several different web sites.  HUD has updated the RHIIP web site to include the updated versions.  http://www.hud.gov/offices/hsg/mfh/hsgrent.cfm

Please be sure to incorporate the updated Fact Sheets when working with your applicants/residents during move in and annual certification.  The new Fact Sheets are dated June 2007.  Below is a summary of changes. 

Getting Access to SAVE (Systematic Alien Verification for Entitlements)

Earlier this year, HUD provided information for those owner/agents who need access to the SAVE database (SAVE is used to verify eligibility of non-citizens).  HUD sent amended information via the RHIIP ListServ.  See below:

If you have already submitted the required information below to Voneka Bennett as instructed by the previous Listserv message posted on August 2, 2007, and still do not have access to the SAVE system, please resubmit the required information as instructed below to Kevin Garner.  We apologize for any inconvenience this may have caused you.

HUD’s rental assistance is restricted to United States citizens and eligible non-citizens. Owners/management agents (O/As) are responsible for ensuring that the documents provided by non-citizen applicants are valid by verifying the information disclosed in these documents with the Department of Homeland Security (DHS).

The SAVE Program Branch of DHS provides O/As access to an automated verification system consisting of immigration status and employment eligibility verification information. In order to retrieve this information, owners must obtain an access code and user ID from DHS by submitting his or her request via email to Kevin_X._Garner@hud.gov or via telephone at (202) 402-2057.  The O/A’s request must include the following information:

1. Name of the apartment complex

2. Contract number for the property

3. Physical address for the property (no P.O. Box addresses)

4. Phone number for the property

5. Fax number for the property

6. Name of the contact person

7. Email address for the contact person

HUD will forward this information to DHS requesting that the owner be granted access to the verification system. DHS will process the owner’s request within approximately 3 business days and notify the owner directly via email that he or she has been given access to the SAVE system. 

 RBD does not act as a legal advisor nor as a regulatory governing agency.  The recipient should understand that any materials or comments contained herein are not designed for, nor should be relied upon as a source of legal guidance or as a final authority with respect to any particular circumstance. Ross Business Development, Inc. makes no warranty of merchantability or fitness for a particular purpose or any other warranty of any type. Owners and management should seek competent legal advice in developing and carrying out policies and procedures.  While we have been diligent in our efforts to provide comprehensive and accurate regulatory information, Ross Business Development, Inc. shall not be responsible for errors or inaccuracies.