This month, HUD published HSG Notice 2020-10 Electronic Signature, Transmission and Storage - Guidance for Multifamily Assisted Housing Industry Partners which revises instruction provided in Housing Notice 2020-04, “Electronic Signature, Transmission, and Storage – Guidance for Multifamily Assisted Housing Industry Partners” published in May. Please note that Housing Notice 2020-04 is now obsolete and is replaced entirely by Housing Notice 2020-10.
HUD has received numerous inquiries from owners and agents asking about signatures, in-person meetings, and income verifications. The Notice provides answers to many of those questions; it provides guidance on acceptable procedures for use of electronic signatures and the electronic transmission and electronic storage of documents and files. Also refer to HUD’s Multifamily Housing COVID-19 Q&A available on HUD’s Multifamily Housing web site.
When comparing this new Notice to HSG Notice 2010-04, owner/agents should note that there are two additions in HSG Notice 2020-10.
1) Section II.A – Adds 811 PRA to the applicable Multifamily Housing Programs who may use the instruction in the Notice.
2) Section VII.B.5 – Revises the language regarding Independent Public Auditors (IPA). While owner/agents have permission to provide electronic versions of the tenant file to CPAs conducting the HUD Financial Audit, that permission DOES NOT include EIV reports. IPAs must comply with the EIV Rules of Behavior which requires IPAs to review EIV information on site or at the management company office.
In light of CDCs recommendations to limit travel and practice social distancing whenever possible, we've asked HUD if owner/agents may consider other methods to communicate compliance with EIV Reporting Requirements.
We'll send another HUDBlast as soon as we receive a response from HUD.
As a result of the revision to this Notice, RBD has added an RBD Online Training Workshop - Electronic Transmission, Electronic Signatures and Electronic Storage scheduled for January 21, 2020 from 1:00-3:00 PM EST.