1. 4350.3 CHANGE 4 REVISION UPDATES HUD Requirements
Presented by Rose Dubin
CONTACT US
2321 Weldon Parkway St. Louis, MO 63146
Phone:
Zeffert & Associates

2. Enterprise Income Verification System (EIV) Required since 1/31/10
Intro
Third party source of employment and income information for Wages, SS and SSI
Identifies issues or discrepancies impacting assistance
Reduces administrative and subsidy payment errors
Insures that the right benefits are given to the right person
Purpose is to ensure that the right subsidy is going to the tenant and to eliminate fraud

3. EIV Data is collected from: Social Security Administration ( SSA)
Intro
EIV
Data is collected from:
Social Security Administration ( SSA)
Dept. of Health and Human Services (HHS)
State Workforce Agency (SWA)
National Directory of New Hires (NDNH)
New Hires: Quarterly Wages, Quarterly
unemployment

4. Intro
EIV
Data Updates Social Security Administration ( SSA) COLA is not reflected in EIV until the end of the calendar year. AR effective after 4-1 must reflect the benefit amount with the COLA included

5. EIV Applies to HUD Housing Programs
Intro
EIV
Applies to HUD Housing Programs
Does not apply to LIHTC or RHS Section 515
In blended programs, EIV can only be used for HUD Program
View HUD Notice H

6. EIV UPDATE CHG 4 Intro Data Updates
National Directory of New Hires (NDNH) – Health and Human Services.
Various agency database share information based on key information “ Personal Identifiers”
Last Name
DOB
SSN
UPDATE CHG 4
Use of EIV to project anticipated income:
EIV provides 3rd party verification of the existence of employment , not the basis of income calculations.
EIV 3rd party verifies the existence of SS payments AND is used for income calculations

7. Policies & Procedures Intro
Owner/Agents are required to develop a Policies and Procedures Manual to govern the use of the EIV system. These are separate from your Tenant Selection Plan. These procedures should address: a. Authorized use of the EIV system; b. How to handle security breaches; and c. Destruction of EIV data. d. Frequency of printing EIV Reports based on HUD’s recommendations.

8. Confidentiality Intro
Only necessary information should be gathered in file.
Severe HUD and civil penalties apply if information is misused or disclosed to unauthorized persons.
Examples of unauthorized persons:
Employees who do not “need to know”
Other residents

9. Confidentiality Intro
Who Can See EIV Data EIV data for an adult household member cannot be shared without consent of the adult Including other household members. However, the total income and how the rent was calculated MAY be discussed with the head of the household.

10. Confidentiality Intro Who Can See EIV Data
A tenant may have someone assist them with the recert process. (Service Coordinators, translators, and assistants for the elderly/disabled, guardians, power of attorneys or other family members).
They may sign a consent for that person to see their personal EIV data only. Exhibit 9-4 is a sample release form.
Limited allowable official disclosure includes CAs and IPAs hires by the owner to perform financial audits and OIG investigators.

11. Intro
Security
Physical Safeguards Steps must be taken to ensure that EIV data is safe whether stored electronically (computer) or in hard copy. (printed.

12. Security Intro Hardcopy EIV Data
Do not leave printed EIV data unattended.
Printing: Retrieve EIV document when they are printed.
Faxing: Only under extreme circumstance can EIV be sent over the fax. In these extreme circumstances confirm there is someone waiting and ready to retrieve the fax as soon as it is received (printed).
Mailing: EIV data must not be mailed to Independent Public Auditor offices.

13. Security Intro Computer Security
The EIV system will time out after 30 minutes of inactivity, this automatic safeguard should not be the only security measure taken.
Use a password protected screensaver and lock their computer when leaving their workspace.
Do not leave a computer unattended with EIV data displayed on the screen
Exit the EIV system be exited using the “X” at the top right of the screen which will remove the user from the entire WASS system.

14. Security Intro Security Training
All EIV users and staff who view the data must adhere to the “Rules of Behavior” (ROB). This is available at the HUD website. This may include auditors.
Required online Cyber-Awareness Challenge training annually for EIV staff. Certificates of Completion must be retained.
Passwords can never be shared
Burn, shred, pulverize

15. Required Forms UPDATE CHG 4 Intro
Must include statement in Figure 5-5 / 5-59
Intro
Required Forms
All adult household members must sign the A at initial and annual certifications, or assistance must be denied. Must be signed at move-in and each recertification. HUD-9887 Fact Sheet Resident Rights and Responsibilities Brochure EIV & You Brochure Owner Created Verification Forms Must make clear: 1) who will be asked and 2) to whom the form will be returned 3) must contain Title 18 language on verification form
UPDATE CHG 4
The 9887 forms must be on file for employment and income reports. They are not required for Verification Reports (including Existing Tenant Search).
When a tenant turns 18 between certifications, owners cannot use income that shows up in EIV until a 9887 is signed by the 18 year old. The policies & procedures must address notification and timeframe requirements if requiring 9887 forms to be signed other than at recertification.

16. EIV & MOR
Intro
A list of required EIV documentation will be provided by the reviewer prior to the Management & Occupancy Review (MOR).
This list generally will include:
An initial and current Approved EIV Coordinator Access Authorization form, with supporting recertification documents (CAAF)
An initial and current Approved EIV User Access Authorization form, with supporting recertification documents (UAAF)

17. Intro
EIV & MOR
A list of required EIV documentation will be provided by the reviewer prior to the Management & Occupancy Review (MOR).
This list generally will include:
Owner’s approval letter authorizing coordinator access to EIV
EIV Policies and Procedures Manual
Signed copies of the EIV rules Of Behavior for individuals without access to the EIV system.
Copy of TRACS Rules of Behavior, signed and dated.

18. Methods of Verification
Verifications
Upfront-income verification (UIV). UIV is verification of income through an independent source that ” systematically and uniformly maintains income information in a computerized form”
[A]: The first method of verification is call Upfront-income Verification or UIV. This is verification of income through an independent source that maintains the income information in a computerized form.

19. A. UIV Verification There are two types of UIV: Verifications
Using HUD’s EIV system for tenants (not available for
applicants). (REQUIRED)
Must be used as the 3rd party source employment and income information of tenants for all
Recertifications
Interims
[B]: There are two types of UIV. The first type is using HUD’s EIV system. We must remember that this is required for all tenants but is not available for applicants. EIV reports must be run at both Annual and Interim Certifcations, and the information must be used as the third party source for employment and other income types shown on the report.

20. A. UIV Verification There are two types of UIV: Verifications
2) UIV using non-EIV system to verify income: (Optional)
Of applicants;
When no employment or income is available in EIV; or
For other types of income received by the family
Examples of Non- EIV UIV
The Work Number
Other state government databases, if available, to verify income
[C]: The second type of UIV is when no information is available in EIV. This type is what we use for applicants, tenants that have no information in EIV, and for other types of income not reported in EIV. Examples of Non-EIVUIV are the Work Number and other government databases.

21. B. Written 3rd Party Written Third Party Verification Verifications
Examples
Pay stubs
Payroll summary report
Employer notice/letter of hire/termination
SSA benefit letter (if tenant does not agree)
Bank statements
Child support payment stubs
Welfare benefit letters and/or printouts
[B]: The second method of verification is the written third party verification. This is the method we are all used to pre-EIV. Examples of this type of verification includes…
Paystubs
Payroll summary reports
Employer notice/letter of hire/termination
SSA benefit letter
Bank Statements
Child support pay stubs
Welfare benefit letters and/or printouts

22. B. Written 3rd Party
Verifications
The following must be considered when using tenant provided documentation:  
Is the document current?
Is the documentation complete? Paystubs most be the recent four to six, consecutive pay.
Actual paychecks or copies of paychecks should never be used.
Is the document an unaltered original? Photocopied documents generally cannot be assumed to
be reliable.
[C]: If the documentation tenant provided, we need to consider the following when determining if it can be used. First, is the document current? Second, it the documentation complete? For example paystubs must be from the most recent 4 to 6 consecutive periods and should be the actual paystub. Copies of paychecks should never be used.

23. B. Written 3rd Party
Verifications
2. “Written documentation sent directly by the third-party source by mail or electronically by fax, or internet.”
Requested directly from the third party
Fax, , view internet site, or mail all requests. Repeat if necessary.
Due diligence necessary with verifications. Ask yourself:
Is it identifiable as coming from the source?
Examples: fax number supplied on faxes, web address on bottom of internet verification,
company name in address.
[B]: The most common form of this type of verification is written third party that is requested by the owner or management agent directly from the third party and the response is sent back directly by the third party source by mail or electronically by fax, , or internet. What do we need to watch for when using this method of verification?

24. B. Written 3rd Party When documenting verbal clarification:
Verifications
When documenting verbal clarification:
Create a Clarification form which includes:
Name, position and contact info of 3rd party
Information requested and the information provided
Name, date and time of conversation
Signature of person collecting information
[A]: The third method of verification is the Oral Third Party Verification. This method is usually used when the Written third party verification is not successful or is incomplete. When using this method we must always document the following information…
Name, position, and contact information of the 3rd party source
The information that they are providing
Your name, and the date and time of the conversation.

25. C. Oral 3rd Party
Verifications
Be Certain you are speaking with the appropriate person
Only complete oral verification by calling the verification source; do not accept verification from the source calling the property management office.
[B]: The last method is the Family Certification. This method is only to be used of the applicant or tenants income cannot be verified by any of the other methods. If the family certification method is used, the file must be documented on why a third party verification was not available. What are some examples of what needs to be in the file?

26. D. Family Certification
Verifications
Only to be used if income cannot be verified by any of the above methods.
Document why third-party verification was not available.
Include in the file:
A note explaining why 3rd party verification was not obtainable
Date-stamped original request
Record of Follow-up efforts
Note after 4 weeks of efforts
without response
[C]:You must include in the file a note explaining why the third party verification was not available, the date-stamped original request, a record of all the follow-up efforts, and if it is because the third party did not respond, a note detailing 4 weeks of efforts without a response.

27. Verifications are Valid…
EXAMPLE
Jolene Recertification is effective 7/1/2014
The manager sends notice to Jolene on 3/3/14
Jolene meets with the manager on 4/1/2014 and provides a 401K Statement dated 1/1/2014.
Can the manager use the statement dated 1/1/2014?
Yes, the statement was not older than 120 at the time of receipt AND
It was received by the manager within 120 days of recert effective date.
Verifications
120 days from the date of receipt by the owner, *not the effective date of the
If verifications are more than 120 days old *from the date of receipt by the owner*, the owner must obtain new verifications.
Note: this is rarely exactly 4 months
Time limits do not apply to information that does not need to be re-verified, such as:
Age;
Disability status;
Family membership; or
Citizenship status.
[A]: So we have the basics of verification down. It is good to know how long verifications are good for. They are valid for a certification for 120 days from date they are received. If you get an employment verification today for a person who wants to move in, the person must move in within 120 days of today, or you will have to get a new form completed by the employer.
in the past, forms were only good for 90 days, but could have their life extended an additional 30 days through verbal clarification. With Change 2 in 2007, this is no longer required, and 120 days is the new limit.

28. Verification Independent 3rd party verification is needed when:
Verifications
Independent 3rd party verification is needed when:
There is incomplete EIV income information for a tenant. Examples include:
The effective date of employment, unemployment or SS benefits.
New employment pay rate, number of hours per week, pay frequency, hire date (which are not required to be reported and may not be in EIV).
When there is no EIV income data for a tenant.
Receipt of SSI payments are adequate to establish disability for “Definition E” programs (Including Section 8).
[A]: So we have the basics of verification down. It is good to know how long verifications are good for. They are valid for a certification for 120 days from date they are received. If you get an employment verification today for a person who wants to move in, the person must move in within 120 days of today, or you will have to get a new form completed by the employer.
in the past, forms were only good for 90 days, but could have their life extended an additional 30 days through verbal clarification. With Change 2 in 2007, this is no longer required, and 120 days is the new limit.
A current HUD 9887 & 9887-A must be signed, dated and on file for each adult household prior to accessing EIV data for a household member.

29. Workshop: Report FrequencyX X X
Income Reports X X X X X X

30. Existing Tenant Search Report (Prior to Move-In)
Purpose: Identify applicants who are receiving subsidy at other properties
What to do: Give applicant an opportunity to explain.
Report is filed in the tenant file
Example: A child subject to Joint custody

31. Failed EIV Pre-Screening Report
Purpose: Identify tenants who have missing or invalid personal identifiers
What to do: Check for typos, including incorrect SS#. Follow up with tenant.
Run Monthly
Place in Master File
Check-
DOB
Last Name

32. Failed Verification Report Tenant to correct SS reporting
Purpose: Identify tenants who have missing or invalid personal identifiers with SSA
What to do: Check for typos. Follow up with tenant. Encourage them to contact SS with errors on SS’s reporting.
Run Monthly
Place in Master File
Tenant to correct SS reporting

33. Multiple Subsidy Report
Purpose: Identify existing tenants who may be receiving subsidy elsewhere.
What to do: Give applicant an opportunity to explain.
Contact PHA or O/A
Run at least quarterly for both MIH and PIH and Place in Master
Housing Choice Vouchers may show up and
not be a problem if subsidy not double

34. Deceased Tenant Report
Purpose: Identify tenants reported by SS as deceased.
What to do: Check with HH. Report inaccurate data SS.
Place in Master File,
Run at least quarterly
If deceased: update ‘59 HH composition and
income.
If single member HH: 14 days from EARLIER of
decease or vacancy

35. Tenant specific information to
New Hires Report
Purpose: Identify existing tenants who have started jobs in the past 6 months.
What to do: If job not reported send letter to come to office within 10 days.
Run the report at least quarterly for MIH and PIH.
Keep in Master File
Tenant specific information to
be kept in tenant file

36. Run Reports as specified in your Policies and
Additional Reports
Monthly Summary Reports
No Income Reported on 50059
No income Reported by HHS/SSA
Place in Tenant File as needed
Any tenant specific information is to
be kept in tenant file
Run Reports as specified in your Policies and
Procedures Manual

37. What to do: 4 Verification statuses:
Summary Report
Purpose: Provides summary of current certification. Also provides Identity Verification Status. Place in tenant file.
What to do: 4 Verification statuses:
Once tenant is verified, they do not need to be verified again
Verified – personal ID match SS
Failed – personal ID do not match SS
Not verified – not sent to SS yet, or in process
No action necessary, but check monthly for changes
Deceased – SS says deceased

38. Income Discrepancy Report
Purpose: Reports discrepancies between ‘59 and EIV. When difference is $2,400 under or over-reported.
What to do: Check for data entry accuracy.
ID discrepancy
Understand discrepancy
Possible reasons:
Invalid discrepancy (employment changed prior to MI)
Tenant error (failure to disclose income)
O/A Error (data entry)
O/A Previously aware of error. Still in EIV system
Not all can be resolved: errors in SS or HUD system
Negative numbers = potential under-reporting
Positive numbers = potential unreported decreases in income

39. Income Discrepancy Report
TRACS
Income Code
Type of Income B
Business F
Federal Wage M
Military Pay W
Nonfederal Wage U
Unemployment SS
Social Security
SSI
Supplemental Security
Income
Income Discrepancy Report
Purpose: Reports discrepancies between ‘59 and EIV. When difference is $2,400 under or over-reported.
What to do: Check for data entry accuracy.
ID discrepancy
Understand discrepancy
Possible reasons:
Invalid discrepancy (employment changed prior to MI)
Tenant error (failure to disclose income)
O/A Error (data entry)
O/A Previously aware of error. Still in EIV system
Not all can be resolved: errors in SS or HUD system
Negative numbers = potential under-reporting
Positive numbers = potential unreported decreases in income

40. Understanding POI (Period of Income) Income Discrepancy Report
Effective Date of Action = effective date of active 50059
Period of Income Start Date = 15 months prior to effective date of
Period of Income End Date = 12 months form the POI start date
Cert effective
POI Start Date
PIO End Date
Income Discrepancy Report
Purpose: Reports discrepancies between ‘59 and EIV. When difference is $2,400 under or over-reported.
What to do: Check for data entry accuracy.
ID discrepancy
Understand discrepancy
Possible reasons:
Invalid discrepancy (employment changed prior to MI)
Tenant error (failure to disclose income)
O/A Error (data entry)
O/A Previously aware of error. Still in EIV system
Not all can be resolved: errors in SS or HUD system
Negative numbers = potential under-reporting
Positive numbers = potential unreported decreases in income

43. Income Discrepancy Report
Purpose: Reports discrepancies between ‘59 and EIV. When difference is $2,400 under or over-reported
What to do: Check for data entry accuracy.
Understand discrepancy

44. Income Discrepancy Report
Keep in Tenant File.
Attach the resolution to the discrepancy as applicable
Must be printed at be same time as the Income Report.
Print for all Recerts, Annual and Interim
Discrepancy may re-appear
for several months after resolution

45. EIV Income Discrepancies
Steps to Address
EIV Income Discrepancies
Identify Discrepancy Type:
Valid or Invalid
VALID
Tenant Failed to Report Income
Investigate
Obtain 3rd party verification.
Notify tenant to contact O/A within 10 days to discuss
Determine if “tenant error” or “fraud”

46. Obtain 3rd party verification.
Notify tenant to contact O/A within 10 days to discuss
Determine if “tenant error” or “fraud”
Tenant
Error
Correct affected 50059s
(not more than 5 years)
Notify Tenant of obligation to reimburse O/A
Collect Funds/Enter into Payment Agreement (See chapter 8)
Reimburse HUD collected funds
Maintain copies of the Income Discrepancy Report, Verification, affected 50059’s and repayment agreement in the tenant file during tenancy and three years after.

47. Obtain 3rd party verification.
Notify tenant to contact O/A within 10 days to discuss
Determine if “tenant error” or “fraud”
Tenant
Fraud
Take Actions to address fraud and terminate tenancy in accord with Chapter 8 in the Change 4.
Report Fraud to HUD – OIG
Maintain copies of the Income Discrepancy Report, verifications, affected 50059’s and termination documentation in the file for 3 years after tenancy.

48. Identify Discrepancy Type:
Steps to Address
EIV Income Discrepancies
Identify Discrepancy Type:
Valid or Invalid
VALID
Document in the file that the reported income discrepancy was a result of management error.
Correct all affected 50059’s
Reimburse HUD over paid subsidy
Maintain copies of the Income Discrepancy Report, Verification, and affected 50059’s in the file for 3 years after tenancy.
O/A Error
Correct

49. EIV Income Discrepancies
Steps to Address
EIV Income Discrepancies
Identify Discrepancy Type:
Valid or Invalid
INVALID
Erroneous Data reported by SSA/NDNH
Investigate 

50. Erroneous Data reported by SSA/NDNH
Investigate 
Notify tenant to contact O/A within 10 days to discuss
Determine source of incorrect data
Gather and maintain documentation demonstrating that the discrepancy is invalid ((i.e. correspondence with employer/SSA)
Document the file that the discrepancy is invalid and what steps were taken to resolve.
Maintain copies of the Income Discrepancy Report in the tenant file along with supporting documentation.

51. Identify Discrepancy Type:
Steps to Address
EIV Income Discrepancies
Identify Discrepancy Type:
Valid or Invalid
INVALID
POI Prior to Move-in
Investigate 

52. POI Prior to Move-in
Investigate 
Obtain verification demonstrating the income reported was prior to move-in. I.e. For wages; verify that the tenant is no longer employed.
Document the tenant file that the income discrepancy is invalid; Income reported was for a period prior to move-in and it has be verified that the tenant is no longer receiving income from the reported source.
Maintain copies of the Income Discrepancy Report in the tenant file along with supporting documentation.

53. Purpose: Verify SS and if there is employment income.
Not On Report
Welfare
Most Pensions
Some employment
Income Report
Purpose: Verify SS and if there is employment income.
Not ALL countable income is on this report!
Annualize current for next 12 months

54. Purpose: Verify SS and employment income.
Income Report
Purpose: Verify SS and employment income.
What to do: SS
Verify, but AND calculate
If tenant agrees to accuracy, have them sign the EIV printout. If they disagree they need to provide documentation
Address COLA per your company policy
Medicare:
Not ALL countable income is on this report!
N = state is not paying

55. Purpose: Verify SS and employment income.
Income Report
Purpose: Verify SS and employment income.
What to do: SS
Verify, but AND calculate
If tenant agrees to accuracy, have them sign the EIV printout. If they disagree they need to provide documentation
Address COLA per company policy
Medicare:
Not ALL countable income is on this report!
Y = if state paying
& start date

56. Y = if state stopped paying
Income Report
Purpose: Verify SS and employment income.
What to do: SS
Verify, but AND calculate
If tenant agrees to accuracy, have them sign the EIV printout. If they disagree they need to provide documentation
Address COLA per company policy
Medicare:
Not ALL countable income is on this report!
Y = if state stopped paying
with start & end dates

57. Purpose: Verify SS and employment income.
Income Report
Purpose: Verify SS and employment income.
What to do: SS
If tenant disputes, or claims SS not on EIV report DO NOT send them to SS office
Website
Toll-free number
Not ALL countable income is on this report!

58. SS doesn’t provide info for garnishments or other deductions (ex
SS doesn’t provide info for garnishments or other deductions (ex. Medicare Part D prescription Drug premiums).
May reveal allowable deductions, differences between gross & net SS in excess of Medicare premium should be discussed with the tenant
NOTE: the disability information provided by EIV is inaccurate and should NOT be used to verify disability status for a HUD program or elderly household deduction.

59. Additional Income Reports Accessed from the “Monthly Summary Report”
Caution: Reports retained in a tenant file must only contain information for members of that tenant’s household. If you are printing your EIV reports so they do not have page breaks between households. Owners will need to separate the reports by household by cutting the reports apart until page breaks are inserted

60. Record Retention
Tenant File: 3 years after tenancy Applicant File (did not move-in): 3 years Master File: 3 years after run
Income Reports

61. Requesting Info from SSA
Do not send tenants to SSA office or
Income Reports

62. Identity Theft If tenant suspects identity theft: Check with SSA
File complaint with Federal Trade Commission (FTC)
Monitor Credit Report
Income Reports

63. Owner may retain a portion to recoup costs
Overpaid Assistance
Repayment goes back 5 years covered by 9887
No longer all the way back to move-in
Owner mistakes cannot be collected from tenant
Owner may retain a portion to recoup costs
Lesser of:
Actual costs (some examples):
Staff time investigating, meeting with tenants
Drafting agreement
Generating invoices
Generating manual voucher adjustment
20% of amount collected
Repayment Agreement

64. Repayment Options Lump sum Installments Combo of both
Cannot collect more than 40% of income unless tenant agrees
Tenant and owner must agree
Tenant may consult with HUD Housing Counseling Agency
Repayment Agreement

65. Repayment Options
TTP + payment plan = no more than 40% adjusted income
Example, Page 8-33
Family monthly adjusted income is $1,230
Monthly TTP is $369 (30% of mo. Adj. income).
40% of the family’s mo. adj. income is $492
The monthly payments should not exceed $123.
Repayment Agreement
$ 492 (40% Adj Inc)
- $ 369
$ 123
$ 369 (mo TTP)
+ $ 123
$ 492

66. Repayment Time Period: time to repay
Repayment Options
Repayment Time Period: time to repay
Example, Page 8-33
The tenant agrees to repay $1,000 and agrees to monthly payments of $25.
$1,000/$25 = 40 months (time period).
Repayment Agreement

67. Repayment Options Required in the plan:
1. The total amount owed, amount of any lump sum paid and the monthly payment amount.
2. Reference to the lease provisions whereby the tenant is in noncompliance and may be subject to termination of their lease.
3. A clause whereby the agreement can be renegotiated if there is a decrease or increase in family income of $200 or more per month.
Repayment Agreement

68. Repayment Options Required in the plan:
4. A statement that the monthly retroactive rent repayment amount is in addition to the family’s monthly rent payment, and is payable to the owner.
5. A clause that late and missed payments constitute default and may result in termination of assistance and/or tenancy.
6. It must be signed and dated by the tenant and the owner.
Repayment Agreement

69. Overpayment of Rent UPDATE CHG 4 Tenant must be notified
Notice of the change in rent, retroactive to error
The new monthly rent
Amount of overpayment of rent due to tenant
A form for the tenant to execute and return to the owner stating whether the tenant wishes to:
Receive a full, immediate refund or
Apply the overpayment to future monthly rent
UPDATE CHG 4
Decreases in income of $2,400 or more a year on the EIV Income Discrepancy Report run at a recertification may indicate a tenant has overpaid rent
Repayment Agreement

70. $ 100

71. Fraud
“Deceit or trickery deliberately practiced in order to gain some advantage dishonestly…an intentional deception; it cannot be committed accidentally.”
Must be documented
Owner MUST file a civil action to recover subsidy overpayment
owner may keep 20% of charges collected as an “Administrative Fee”
Criminal charges MAY also be brought.
Tenancy must be terminated.
Repayment Agreement

72. Fraud
“Deceit or trickery deliberately practiced in order to gain some advantage dishonestly…an intentional deception; it cannot be committed accidentally.”
Must be documented
MUST be substantiated through documentation.
If can’t be done, MUST treat as an unintentional program violation.
In cases of potential fraud:
tenant must be informed in writing of the “error”
Must be allowed to schedule a meeting within 10 days.
Repayment Agreement

73. Verification
Reports
30 days
Income Report
Discrepancy Report

74. Common Abbreviations
CAAF Coordinator Access Authorization Form DOB Date of Birth EIV Enterprise Income Verification HUD Department of Housing and Urban Development LIHTC Low Income Housing Tax Credit Program O/A Owner Agent P/P Policies and Procedures RHS Rural Housing Services ROB Rules of Behavior UAAF User Access Authorization Form