We have received quite a few inquiries related to findings issued when an owner/agent does not complete the EIV Income Discrepancy Analysis if the Period of Income for Discrepancy Analysis is before the Move-in Date.
As a result, we thought we would send a clarification.
If the Period of Income for Discrepancy Analysis is prior to move-in, it is likely that you do not have a problem. However, owner/agents do have to take at least one additional step.
Review the EIV Income Report to determine if all the income reflected on the EIV Income Report – earned/paid after the MI effective date - has been reported.
If it has been reported, then no additional action is required, and owner/agents should document the file accordingly. If there is income that has not been reported, then you will have to work with the resident to determine if he/she received the income shown in EIV. If so, the resident must return any improper payment to HUD.
If this comparison is not completed, then Income Discrepancy Analysis has not been completed as required by HUD.
Please note that, in compliance with HUD HSG Notice 2013-06 Enterprise Income Verification (EIV) System – Attachment 5, when addressing discrepancies, owner/agents may use EIV to verify income if the resident agrees that the information in EIV is correct.
We provide a sample self-certification on our RBD FASTForms page Self Certification EIV Income Accuracy.
We also provide EIV Checklists including the EIV Post 90 Day Review Checklist and the EIV AR/IR Checklist.
You can also check out our RBD OnDemand Training explaining how to use EIV and properly document the tenant file.
These classes provide essential training for experienced and new property managers.
