HUDBlast March 3, 2011

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

Our Address Has Changed!

As of March 1, 2011, our new address is

Ross Business Development, Inc.

3134 Shumard Way

Marietta, GA  30064

Reminder Ė DUNS Number and CCR Certification Due to HUD No Later than 3/4/2011 (Section 8, 202 PRAC, 811 PRAC)!

Last month, we told you that HUD has published HUD Notice 2011-01:  Notice Requiring Owners with Project-Based Section 8 Rental Assistance Contracts or Section 202 or 811 Project Rental Assistance Contracts to Obtain Dun and Bradstreet Numbering System (DUNS) Numbers and to register in the Central Contractor Registration (CCR) http://portal.hud.gov/hudportal/documents/huddoc?id=11-01hsgn.pdf

There is an attachment to this Notice:  DUNS Number and CCR Registration Certification http://portal.hud.gov/hudportal/documents/huddoc?id=11-01hsgnatch.pdf   Owner/agents for Section 8, 202 PRAC and 811 PRAC properties have until Friday, March 4, 2011 to submit these certifications to HUD.  Failure to provide this certification may result in interruption of HAP payments.

Please read the Notice for additional information.  Unfortunately, RBD has no specific information regarding submission to your local HUD office.  To access HUDís local office directory, visit their web site at http://portal.hud.gov/hudportal/HUD?src=/localoffices.

New Options for EIV Security Awareness Training

By now, we all know that there are two types of  property management professionals who use EIV.  One is authorized staff who actually access EIV through HUDís Secure Systems.  These professionals completed a User Access Authorization Form (UAAF) or a Coordinator Access Authorization Form (CAAF) and are periodically re-certified within the EIV System.  EIV users are required to participate in EIV Security Training every year.  This training can be provided through HUDís December 29, 2009 webcast, or via instructor-led or web based training that covers topics outlined in HUD Notice 2010-10. (Please visit our web site to view RBDís EIV training offerings.)

The second group of property management professionals use EIV reports as part of their job function, but do not access the reports themselves.  These people view either electronic or hard copy versions of the reports. 

Owners, agents and their staff who do not have access to the EIV system but who use EIV reports to perform their job function must sign HUDís EIV Rules of Behavior document and are required by Housing Notice 2010-10 to complete security training annually.  The Notice indicates the security training portion of HUDís most recent EIV webcast, currently December 2009, will satisfy this requirement. 

For those property management professionals who use EIV reports but do not have access to the EIV System, the Office of Multifamily Housing is introducing another option to complete required security awareness training.  In addition to the training alternatives described above, acceptable training for that particular group now includes completion of the online Federal ISS Awareness training program.  To complete the Federal ISS Awareness online Security Awareness Training:

         Open your web browser.

         Type http://iase.disa.mil/eta/index.html#onlinetraining.

         Press Enter.

         Click on Federal ISS Awareness icon on the IA Education, Training and Awareness Screen.

         Click on Launch New Information Systems Security Awareness on the Information Systems Security Awareness screen.

         Proceed with the training.

         When the training is complete, print and maintain the Certificate of Completion.

The security training described above is the same training that was introduced in April 2010 to address the security training requirements for TRACS.   If the training has been completed to satisfy TRACS security training requirements, you do not need to complete the training again for one year from the completion date on the training certificate. 

In order to prove participation in this training, the certificate should be filed so that you can present it to HUD or your Contract Administrator upon request.

EIV Ė Missing Property Information

As a result of your calls, HUD recently published a RHIIP ListServ to help owner/agents understand how to proceed when data is missing in the EIV database. 

HUD has been advised that a number of owner/agents are encountering error messages and/or missing data when attempting to view EIV reports for some or all of their properties.  They are aware of the error messages being displayed and are working to correct the issues in the system. 

If you are receiving these errors you are required to perform verifications by reverting back to traditional verification methods used prior to the implementation of EIV.  In addition, you must retain copies of the incorrect EIV reports.  HUD apologizes for this inconvenience and will advise when the issues have been corrected.

So, what does this mean to the property manager who has been relying on EIV for verification?  HUD has not given specific instruction, so we would like to make a couple of suggestions to help you standardize your process. 

First of all, always try to use EIV to review or verify information as required in HUD Notice 10-10.

Checking TRACS

If you are getting a message that says ďNo certification found in TRACS, you should check the TRACS Certification Query to make sure that the last full certification (AR, IR, IC or MI) has been received.  If the certification is recorded in TRACS, we suggest that you note the EIV report by saying ďchecked TRACS, certification recorded on (insert TRACS process date)Ē. 

EIV Master Files

If you are working on the EIV Master File Reports and there is no information or if information is not valid, we suggest you take the following steps:

  • Print the reports as specified in your EIV Use Policy
  • Make a note on the report explaining that the information is missing or invalid
  • Attach a copy of RHIIP ListServ 249
  • File those reports in the propertyís EIV Master File

Resident Files Ė Annual and/or Interim Certification

If you are working with your resident to complete an annual certification, you must print the EIV Income Summary Report, the EIV Income Detail Report and the EIV Discrepancy Report.  If there is no information or if information is not valid, we suggest you take the following steps:

  • Print the reports as specified in your EIV Use Policy
  • Make a note on the report explaining that the information is missing or invalid
  • Attach a copy of RHIIP ListServ 249
  • Use traditional verification as described in HUD Handbook 4350.3 Revision 1, Change 3, Paragraph 5-13 and Appendix 3
  • File those reports in the resident file
  • File the verification documents in the resident file

RHIIP ListServ

HUD will notify owner/agents when this EIV reporting issue is resolved.  This is usually done through HUDís RHIIP ListServ.  If you do not subscribe to the ListServ, we strongly encourage you to follow the instruction at the bottom of this HUDBlast, so that you receive this information in the most timely fashion.

Join RBD For Training In The Following Cities

Itís a full time job just to stay on top of current occupancy issues and their impact on day-to-day property management functions. Join Mary Ross to discuss the latest in HUD occupancy requirements. 

Training includes sample forms, notices and policies that can be used to help you develop your own custom documents.

To register for training, visit our web site at www.rbdnow.com of contact our Training Coordinator (Larue Marin) at 770-426-0577 or email her at larue.marin@rbdnow.com.

 

To sign up for the HUDBlast, visit our web site at www.rbdnow.com.  Just enter your email address in the box in the center of the home page.  You can view previously posted HUDBlasts from our web site at http://www.rbdnow.com/hudblasts.htm

 

We also encourage you to sign-up for the Listserv, so you can receive current RHIIP related information from HUD http://www.hud.gov/subscribe/mailinglist.cfm You can view the RHIIP Tips Archives, under "Listserv-Multifamily RHIIP Tips" at http://www.hud.gov/offices/hsg/mfh/rhiip/mfhrhiip.cfm

 

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.