HUDBlast December 6, 2006

TRACS & EIV News & Updates

TRACS Transmission Notice 

 

HUD recently posted the following information on the TRACS web page: "The problems with TRACSMail have been resolved. Please be advised there may be a possibility that files from 4 pm 11/30/2006 until 4 pm 12/04/2006 may need to be retransmitted. We will post a message as son as that can be determined. Thank you for your patience."

 

Be sure to check Secure Systems to insure that your TRACS submission was received successfully.
 

EIV Coordinator Authorization Request Forms

 

Effective as of November 20, 2006, any inquiries or questions relating to the EIV system for Multifamily Housing Programs must be directed to the Multifamily Help Desk at 1-800-767-7588 or by email at Mf_Eiv@hud.gov

Also effective November 20, 2006, persons applying for EIV access as an EIV Coordinator must submit their EIV Coordinator Access Authorization Form to the Multifamily Help Desk. The form can either be submitted via email in a PDF format or in a compressed picture format such as GIF or JPG to mf_eiv@hud.gov or by fax to 202-401-7984. For additional instructions on applying for EIV access, see the Instructions for Applying for EIV Access for Multifamily Housing Programs, located on the Multifamily EIV Web site at: http://www.hud.gov/offices/hsg/mfh//rhiip/eiv/eivhome.cfm
 

For those of you who received confirmation that HUD is processing your EIV Coordinator Access Authorization Forms, your should be receiving Coordinator Access confirmation shortly. If you did not receive confirmation that HUD received the Coordinator Access Authorization form, we have been advised that you should re-fax that completed form to the Multi-family Help Desk. This way, the Multi-family Help Desk staff can ensure that your request is processed in a timely manner.

 

No Benefit Information in EIV

A Suggestion on How to Verify SSA/SSI Income

Until 2007 Information is Available in EIV

 

Unfortunately, those of us who relied on TASS to obtain benefit information have been left in a bit of a lurch caused by the fact that EIV has not been updated to include 2007 benefit information.  For those of you who were around, we had a similar delay last year after the COLA increases were announced.

 

Many of our customers have contacted us to find out what to do to provide third party verification of SSA/SSI income for the file.  There are a few options you should consider: 

 

First of all, you should contact the local Social Security office to request a copy of the Social Security benefit letter.  Many of the offices will mail or fax you a copy as long as you send a standard request along with a copy of the appropriate release form.

 

We have heard, however, that a recent SSA memo indicated that the information is available electronically and that local offices should not have to provide these forms.  A carefully worded cover letter could help you get a better response from your local office.  You might want to try something like the following:

 

“We are performing a HUD required annual review of (resident’s name) income to determine the amount of housing assistance HUD will provide to our resident.  In order to verify the SSA/SSI Income, we are requesting a copy of their benefit letter.  The required release form is attached for your records.  HUD is currently working on providing this information in an electronic manner using a system called the Enterprise Income Verification System (EIV).  However, the 2007 information has not been provided yet.  HUD requires that we begin the verification process 120 days before the effective date of the resident’s rent increase/decrease so we are asking the Administration to provide us with the required documentation required to verify this income source/amount.  Your assistance in this matter is greatly appreciated.”

 

If the Social Security Administration still refuses to provide the information, you will have to make a note in the file stating that the benefits were not verified via 3rd party verification because the information was not available in EIV.  If you attempted to get a new letter from Social Security and they refused to send you one, then indicate that as well.

 

Now you should move on to the 2nd form of verification which is “review of documents”.  You cannot use bank deposit information because these do not provide enough detail about what is paid for SSA, what is paid for SSI/SSDI and what is deducted.  Since we have to use the gross amount (including cents) before any deductions, bank statements won’t work. 

 

The easiest thing to do is to:

  1. Sit down with the resident

  2. Access ssa.gov and

  3. Help the resident electronically request a copy of the benefit letter

(I didn’t say it would be easy, I said it was the easiest alternative!)  A new benefit letter will be sent to the resident – usually within 2 weeks.  Once again, this is not considered 3rd party verification because you will not receive the benefit letter, the resident will. 

 

We wanted to provide you with a possible solution that might help you until benefit information is available through EIV.  If this instruction represents a change in management process, please be sure to review with appropriate members of you management team before changing existing processes or implementing new ones.

 

Bank of America and Fees for Bank Verification

 

Last week there was an important announcement based on an effort put forth by the state of Washington AHMA (Affordable Housing Managers Association) and CARH (Council for Affordable and Rural Housing) regarding fee charges for verifications of deposit (VOD) at banking institutions. The issue? Membership had been alerted that the Bank of American had established a policy to charge a $25 fee for each verification of deposit as of December 1st. The local AHMA and CARH Council for Affordable and Rural Housing) wanted to intervene and request a reversal of that policy for affordable housing properties.

 

Through an internet-based request for contact with a BOA official, the agencies were able to find Michael J. Dotson, Vice President at Bank of America, who confirmed that the fee being assessed in a notice distributed to Bank of America branches is ONLY for lenders requesting mortgage payoffs. "Bank of America does not charge a fee for Verifications of Deposit (VODs) to affordable housing providers or tenants who are participating in the HUD Section 8 housing program."

 

RBD Announces New Class

 

Due to numerous requests, RBD has developed a new class for property management professionals managing HUD properties.  This class is entitled Advanced HUD Occupancy Update

 

This advanced class for industry professionals provides information about changes, announcement and updates that affect the day-to-day operations of project-based HUD properties.  During this one day class, we will discuss:

  • Clarifications provided by HUD through the FAQs

  • Changes to the MOR process including ways to avoid common findings

  • HUD/DOJ Guidance regarding reasonable accommodation/modification

  • Changes to the Special Claims process

  • The Student Rule

  • EIV

  • Preparing for Change 2

We will provide you with the information you need to stay abreast of changing regulatory requirements.  In addition, you will also receive sample forms necessary to document these changes appropriately.  

 

Sign Up for RHIIP ListServ

 

We STRONGLY recommend that you sign up for the Rental Housing Integrity Improvement Project’s ListServ.  By signing up for this service provided by HUD, you will get timely announcements about HUD changes that affect the Multi-family industry.  It’s where we get a lot of our information. 

 

To sign up, visit the following web site and provide appropriate contact information.  http://www.hud.gov/subscribe/signup.cfm?listname=Multifamily%20Housing%20RHIIP%20(Rental%20Housing

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

 

 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.