HUD Issues Revised Transmittal to Handbook's Change 4

On Dec. 10, a revised transmittal for the 4350.3 REV-1, CHG-4 Handbook appeared online. It was signed by Carol Galante, Assistant Secretary for Housing, and its issue date was Nov. 27, 2013. Here are the changes based on the transmittal:

Clarification of Verification Techniques

The transmittal made the following clarifications to verification techniques. In paragraph 9-10(A), the transmittal adds that owners and agents must not use tenant-provided documentation even when generated by a third-party source in these particular situations:

• Tenant can’t provide acceptable and current employment and/or income documentation to support wages and unemployment in the Enterprise Income Verification system (EIV);
• Tenant disputes EIV income information;
• There is an EIV income discrepancy reported at the annual recertification, interim recertification, or other time as specified in the property’s EIV Policies and Procedures; or
• EIV employment or income data for the tenant is incomplete and the owner or agent needs more information. Some examples include no effective date of income, no information about new employment, and no EIV data for a tenant.

Paragraph 5-13(B)(1)(b)(2) has an added note referring to paragraph 9-10A for situations when verification must come directly from the source before verifying through a third party.

Chapter 3: Eligibility for Assistance and Occupancy

Paragraph 3-13(A)(2) was changed, and paragraph 3-13(A)(2)(h) was added. These notes more accurately reflect the changes made in the handbook regarding the Section 8 rules for student eligibility. The added note clarifies that Section 8 assistance shall not be provided to any individual who is not individually eligible to receive Section 8 assistance or has parents who are not income eligible to receive Section 8 assistance. Unless the student can demonstrate his or her independence from parents, the student must be eligible to receive Section 8 assistance and the parents (individually or jointly) must be eligible to receive Section 8 assistance in order for the student to receive Section 8 assistance.

Appendices

The transmittal removes all appendices associated with Chapter 9 of HUD Handbook 4350.3 REV-1, CHG-3. Other changes to appendices are as follows:

• Appendix 3 now includes: (1) a new column “Provided by Applicant” under Third Party Verification; (2) Note “e” referencing the examples and requirements found in paragraph 5-13.B.1; and (3) updating to align with new verification techniques found in paragraph 5-13, including self-declaration of income related items and reworded verification tips for clarification.
• Removal of the following indexes: Appendix 7-B, Appendix 9, Appendix 10-A, Appendix 10-B, Appendix 10-C, Appendix 10-D, Appendix 11, Appendix 12, and Appendix 13.
• Appendix 14 A-F is now Appendix 7 A-F.

Implementation

According to the transmittal, owners and managing agents had until Dec. 15, 2013, to implement the changes made by Change 4. Also, owners and managing agents have until March 1, 2014, to implement changes that require changes in their compliance software. This refers to entering citizenship eligibility codes and income for foster children and fostered adults. HUD may extend the March 1, 2014, date if software vendors can’t make the changes due to incompatibility with TRACS.