The National Center for Housing Management Posts

By Mark S. Alper, RHM, VP Compliance

On Aug. 17, HUD issued yet another notice on the topic of Enterprise Income Verification (EIV). HUD Notice H2011-21 replaces all prior EIV notices, the most recent of which was HUD Notice H2010-10. The latest notice included the following:

• Independent Public Auditors (IPAs) may use printed documents when auditing an owner’s compliance. However, EIV data that is mailed cannot be sent to an IPA’s office; it must be sent to the office of the owner agent.
• Owner/Agents must make sure income appearing in an EIV Income Report does not meet a regulatory/statutory exclusion.
• EIV users are now required to complete the online Federal ISS Awareness training program. The most recent HUD EIV webcast will no longer satisfy the security training requirement.
• Recommends that the Repayment Agreement (due to unreported income) be signed by both the head of household and the family member who had the unreported income.

In other news, HUD announced that it will be engaging in a “do-over” in connection with its recent award of PBCA contracts in more than 40 states and territories as a result of complaints filed with the Government Accounting Office. In an effort to avoid litigation, HUD will be issuing a Notice of Funding Availability (NOFA) while evaluating its processes with respect to PBCA selection. This will not impact PBCAs in areas where there was only one bidder for the contract. Existing PBCAs are being afforded the opportunity for an interim six-month contract at a lower rate with reduced responsibilities.

By Jo Ikelheimer, MPA, RHM

Regular readers of Housing Management Update may remember a Low-Income Housing Tax Credit (LIHTC) article from earlier this year where I was excited to report on the formation of a Rental Policy Working Group consisting of representatives from the White House Domestic Policy Council, the National Economic Council, the Office of Management and Budget, HUD, USDA and the Department of Treasury. To follow up on their activity, I am happy to report that Alignment Reports have now been issued in preliminary format and that two pilot programs have been proposed for alignment of physical inspections between federal rental programs and for subsidy layering reviews. For LIHTC compliance purposes, I would like to summarize the highlights of the Physical Inspection Alignment Report for you in this month’s article.

The stated goal of these efforts is to “better align federal rental policy across the administration.” For purposes of physical inspections, this means a reduction of multiple reviews among varying agencies for the estimated 10,485 “blended” or “combo” properties in this country that have more than one source of federal funding. These properties had a combined 22,546 separate inspections for 2007, the year in which the data was gathered. Through the alignment efforts, it is estimated that one-year savings to owners, operators, developers and investors and/or lenders will be $24 million. Savings for federal agencies are estimated at $4.8 million for a single year and $22.2 million over a three-year period. In addition to the obvious cost savings, it is hoped that this will also “create efficiencies for government, owners and residents” of affordable properties whose units have been subject to multiple inspections.

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