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2.  IHFA Management and Occupancy Review (MOR) Process:  Initial MOR Notification Letter  Desk Review by IHFA pre- MOR  Day of the MOR  MOR Report  Follow-up by IHFA or the Owner/Agent (O/A)  Records Retention Requirements 2

3.  On a conference call with HUD on April 8, 2009 IHFA was informed that HUD will be publishing a revised version of chapter 6 of the 4350.1. (chapter on MOR processes) When this is published it may effect some of these processes. 3

4.  This letter (form #1) will request (if you currently have EIV access) that you make available for review, the following security related forms:  EIV Coordinator Access Authorization Forms (link #1)  EIV User Access Authorization Forms (link #2)  EIV Owner Approval Letter (form #2)  Security Awareness Training Questionnaires (link #3) 4

5.  This letter will also request that you make available for review on-site:  Development Policy and Procedure Manual(s) ▪ The EIV Policy and Procedure Manual will be reviewed at the time of the MOR. 5

6.  The security file documentation will be reviewed at MOR. IHFA suggests that the coordinator keep the following files:  A file that contains all the original/initial and current required security forms.  A file that contains historic documents and/or terminated user information.  Please ensure that the files are available for review on the day of the MOR. The files should contain forms for anyone that has/had access to EIV for this site. 6

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8.  The desk review process is completed by the IHFA Compliance Auditor prior to conducting the MOR:  The auditor will run the following reports regardless of site access to EIV: ▪ Failed Verification Report ▪ Deceased Tenant Report ▪ Multiple Subsidy Report ▪ If there are any discrepancies on any of these reports, the auditor will take these reports to the MOR and give to the on-site manager for follow-up/resolution. 8

9.  IHFA will run a report from iREMS, (HUD secure system for PBCA’s) or ask HUD to run this report for them (for those sites that we are not granted access) that will show everyone with EIV access roles.  This report will be taken to the MOR and used to ensure all coordinators/users with access have the appropriate security documentation on file. 9

10.  If the O/A has EIV access, the auditor will also run the following reports:  Income Discrepancy Report  No Income Report  New Hire Report ▪ These reports will be used to assist in choosing units for audit as well as alert IHFA to any red flags regarding income reporting discrepencies at the property. 10

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12.  Policies and Procedures will be reviewed.  The 3 non-income related reports will be given to the O/A for resolution. (if applicable)  The EIV security file will be audited and compared to the report from iREMS/HUD. (form #6)  The O/A will be interviewed regarding security of the data. (form #7 and #8) 12

13.  A sample of tenant files will be audited to ensure the correct 9887 and 9887A are completed and in file.  The tenant files will be reviewed for applicable EIV reports and supporting documentation to verify resolution of discrepancies. (if applicable)  Note: IHFA may request additional files for this purpose. 13

14.  EIV data/reports will be reviewed to ensure compliance with established Polices and Procedures.  Any Discrepancies/Observations/Findings will be discussed in the exit interview. 14

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16.  Per the HUD webinar conducted December 17 and 18, 2008, link: http://www.hud.gov/webcasts/index.cfm, the following Observations/Findings will be taken/issued: http://www.hud.gov/webcasts/index.cfm  Note: We understand that this will change when EIV becomes mandatory effective September 30, 2009. The following is applicable for the 2009 audit year only. 16

17.  If the O/A has no EIV access:  Nothing will be communicated on the MOR report.  If the 9887 and/or 9887 A are not completed and in file:  A Finding will be issued, regardless of EIV access, in accordance with the HUD Handbook 4350.3 Rev-1 Chg. 2 guidance. 17

18.  If the O/A has access to EIV and any of the 4 required security file documents are not completed and/or missing for any current coordinator/user:  An Observation will be issued and:  IHFA will e-mail HUD ”immediately” and access to EIV could be terminated. If the O/A submits the required documents to IHFA, a second e-mail will be sent to HUD and access will be reinstated. 18

19.  The following is an example of the observation that will be issued:  O/A did not provide CAAF, UAAF, EIV Owner Certification, or Security Awareness Training Questionnaires for EIV access, yet O/A is using the system to verify income of tenants. As directed by HUD, an email has been sent to the Director of the Housing Assistance Policy Division at HUD Headquarters to report the missing documentation. HUD may terminate user and/or coordinator access. 19

20.  If the O/A has access to EIV and is using the system, but does not have established Polices and Procedures:  An Observation will be issued. ▪ Example: Owner/Agent must establish policies and procedures that provide instruction and information on the acceptable use, disposition and storage of data obtained through the Enterprise Income Verification (EIV) system. 20

21.  If the O/A has access to EIV and is not resolving the income discrepancies listed on the Income Discrepancy Report obtained in EIV: (form #9)  A Finding will be issued. ▪ Please note that resolution does not necessarily mean an increase in the resident’s rent. 21

22.  If the O/A has access to EIV and is not using EIV data as the preferred method of verification, before other acceptable verification methods are attempted:  A Finding will be issued. ▪ Example: An O/A is currently using EIV to verify SSA data but does not use NDNH or other income data. 22

23.  If the O/A has access to EIV and is not resolving discrepancies between EIV data and second party verification:  A Finding will be issued. ▪ Example: EIV shows that the resident makes $300.00 per month but the second party documentation provided supports $550.00 per month. Third party verification was not obtained to clarify this discrepancy. 23

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25.  There are very specific time frames attached to the retention of the data that is obtained from EIV. They are as follows:  Social Security Benefit Data ▪ Term of tenancy plus 3 years  National Directory of New Hires (NDNH) data ▪ 2 years  If you have a report that contains both, the NDNH data must be cut off and removed from the file after the 2 year period. 25

26.  NDNH data must be destroyed at annual recertification of the second year.  When it is destroyed, the file must be noted as such as well as the date of destruction.(form #10)  The first date to destroy data for residents will be January 2010. 26

27.  Tax Credit auditors  USDA/RD auditors  Internal auditors such as your CPA firm that prepares your Annual Financial Statements. 27

28.  In order to ensure that you are destroying this data according to HUD requirements, and to ensure no access is given to unauthorized individuals, IHFA is suggesting that a second file, separate from the tenant file, be kept that contains only the EIV data. 28

29.  EIV Quick Start (form #11)  Complete step-by-step instructions on getting set up  Quarterly Recertification Instructions (form #12)  Sample EIV Notice to Residents (form #13) 29

30.  HUD EIV Website: http://www.hud.gov/offices/hsg/mfh/rhiip/eiv /eivhome.cfm http://www.hud.gov/offices/hsg/mfh/rhiip/eiv /eivhome.cfm  IHFA Website: http://www.ihfa.org/multifamily_section8.as p http://www.ihfa.org/multifamily_section8.as p  Ross Business Development: http://www.rbdnow.com/eiv.htm http://www.rbdnow.com/eiv.htm  Sample forms packet provided today 30

31.  HUD RHIIP Website: http://www.hud.gov/offices/hsg/mfh/rhiip/mfhrhiip. cfm http://www.hud.gov/offices/hsg/mfh/rhiip/mfhrhiip. cfm  EIV Notice: http://www.hud.gov/offices/adm/hudclips/notices/h sg/08hsgnotices.cfm http://www.hud.gov/offices/adm/hudclips/notices/h sg/08hsgnotices.cfm  RHIIP Q and A’s: http://www.hud.gov/offices/hsg/mfh/rhiip/qnaon435 0pt3.pdf http://www.hud.gov/offices/hsg/mfh/rhiip/qnaon435 0pt3.pdf  Course materials from this class on the Idaho AHMA website: http://www.idahoahma.org/events/course- materials.htmlhttp://www.idahoahma.org/events/course- materials.html 31

32.  Misty Schafte: Misty.schafte@hud.gov 971- 222-2656Misty.schafte@hud.gov  Sheryl Putnam: sherylp@ihfa.org 331-4821sherylp@ihfa.org  Heather Wiedenfeld: heatherw@ihfa.org 331- 4868heatherw@ihfa.org  Noel Gill: ngill@nwrecc.orgngill@nwrecc.org 32

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