The CARES Act identifies different types of unemployment compensation.
In HUD’s latest Q & A available on our RBD/Resources/COVID-19 Resources page, HUD clarifies which payments are to be included as part of tenant income calculations for HUD assisted Multifamily Housing.
The CARES Act contains the following three types of unemployment compensation:
Section 2102: Pandemic Unemployment Assistance (PUA). This is an unemployment benefit for individuals who are self-employed, seeking part-time employment, or whom otherwise would not qualify for regular unemployment insurance (UI). HUD has determined that PUA benefits must be included as annual income.
Section 2104: Federal Pandemic Unemployment Compensation (FPUC) program. This program provides eligible individuals who are collecting certain UI benefits, including regular unemployment compensation to receive an additional $600 in federal benefits per week for weeks of unemployment ending on or before July 31, 2020. HUD has determined that FPUC benefits meet the definition of temporary income and must NOT be included in annual income.
Section 2107: Pandemic Emergency Unemployment Compensation (PEUC) program. This program provides an extension to regular unemployment insurance benefits for eligible individuals, allowing them to receive up to 13 weeks of additional benefits (this extends UI from 26 weeks to 39 weeks in total). HUD has determined that PEUC benefits must be included in annual income.
HUD also notes that regular payments of unemployment insurance (issued by the state) are also included as part of annual income according to existing HUD policy.
See HH 4350.3 Paragraphs 5-5 and 5-6 for additional information about how to treat unemployment payments.