On Thursday, April 16, 2020, HUD posted an updated Questions and Answers for Office of Multifamily Housing Stakeholders.
Included is guidance pertaining to payments under the CARES Act. This includes household stimulus payments and Pandemic Unemployment Compensation.
Q4: Are household payments under the CARES Act reportable as tenant income?
A: Household stimulus payments of up to $1,200 (which is technically an advance tax credit) and the temporary $600 per week federal enhancement to unemployment insurance provided by the CARES Act are not to be included in calculations of income. However, HUD notes that regular payments of unemployment insurance (issued by the state) are treated as income, as is customary under program rules.
In compliance with HH 4350.3 Paragraphs 5-5 and 5-6, when a resident receives regular unemployment, owner/agents project the unemployment for 52 weeks.
Residents should be advised that the Pandemic Unemployment Compensation of $600 per week (for 17 weeks) is not included when determining the housing assistance payment.
Refer to HH 4350.3 Paragraph 5-6, Figure 5-3 for instruction explaining how to determine regular unemployment compensation amounts on the 50059.
If/when unemployment benefits stop, residents should notify the owner/agent, within a reasonable amount of time, and the resident should provide documentation supporting the date of termination of the benefits. Owner/agents will then prepare a recertification removing the unemployment income.
According to HUD Model Lease 90105A, Paragraph 16, residents are required to report when an adult member of the household, who was reported as unemployed on the most recent certification, obtains employment.
HUD does not define the time frame when information must be reported. In HUD’s Handbook Q & A, HUD provides the following guidance.
Answer: HUD does not specify a time frame for reporting changes in income. Owners should establish a reasonable policy and apply the policy consistently.
RBD offers a sample Policy Days to Report Change Template as part of our FASTForms offerings.