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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) 2

3.  Records Retention Requirements  Repayment Plans for unreported income  What is coming up from HUD 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) and subsequent recertifications done annually  EIV User Access Authorization Forms (link #2) and subsequent recertifications done quarterly 4

5.  EIV Owner Approval Letter (form #2)  Security Awareness Training Questionnaires (link #3) retaken annually on the anniversary of the initial access date.  Rules of Behavior (form will be published by HUD at a later date) required for all personnel that have access to data but do not have a WASS ID i.e. site managers or internal auditors 5

6.  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. *Note: HUD will be publishing a Rules of Behavior Certification that will be required to be signed by all persons that have access to EIV data but do not have a WASS ID such as other staff members and internal auditors. This will also be requested at the time of audit when published. 6

7.  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. (see sample file set up) 7

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9.  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 ▪ Identity Verification Report- Failed Pre- screening Report ▪ manager for follow-up/resolution. 9

10. ▪ 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 10

11.  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.  Note: This report will soon be able to be viewed in EIV. (Question #72 on EIV Q and A) 11

12.  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. 12

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14.  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) 14

15.  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. 15

16.  EIV data/reports will be reviewed to ensure compliance with established Polices and Procedures.  The Resident Selection Plan will be audited if using the existing tenant search report.  Any Discrepancies/Observations/Findings will be discussed in the exit interview. 16

17. *Note :When Idaho Housing comes to your site to review your files, we have been given authorization to look at the EIV documentation. This is given in the 9887. (EIV Q and A #71) 17

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19.  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. 19

20.  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. 20

21.  If the O/A has access to EIV and any of the 4 (and soon to be 5) 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. 21

22.  The following is the information that IHFA is required to report to HUD (EIV Q and A #70):  Your name, contact information  The observation(s)  User’s name, contact information, M-ID#  Project name 22

23.  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. 23

24.  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. 24

25.  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. 25

26.  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. 26

27.  If the O/A has access to EIV and is not resolving discrepancies:  A Finding will be issued. ▪ Example: EIV shows a resident on the new hire report as being employed and has just had their annual, yet income from this source has not been reported by the resident or counted on the 50059. The file does not show that the O/A has followed up on this information. (EIV Q and A #35 and #48) 27

28. If there is a discrepancy between the resident and EIV, third party verification is required, and the third party verification is what is relied on for calculating rent and subsidy. *Note: There is no longer a requirement to support EIV data with second party documentation. This has changed with the publication of the EIV Q and A and the change to the data destruction requirements. 28

29.  If the O/A has access to EIV but the O/A has not “clean up” the Pre-screening or Failed Verification Report(s) (EIV Q and A #76):  An Observation will be issued. ▪ Example: A resident’s social security number failed to match records held with the Social Security Administration. This discrepancy was not resolved and the resident continues to show on the Failed Verification Report. 29

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31.  All data that is obtained from EIV is required to be kept for the term of tenancy plus 3 years. HUD has signed new Computer Matching Agreements with both HHS and NDNH.  Note: This is a major change from pervious guidance and the two year data destruction requirements are no longer valid. 31

32.  Tax Credit auditors  USDA/RD auditors  See EIV Q and A question #20 for detailed information on further requirements.  This is also a major change from pervious guidence as it now allowed to give access to internal auditors as long as they sign the “Rules of Behavior” 32

33. *Note: If you have a site with multiple subsidies, such as Tax Credits, layered on HUD is very clear about the fact that no data sharing can happen between the two programs. This is true of learned unreported income from EIV. (EIV Q and A #31) 33

34.  In order to ensure that no access is given to unauthorized individuals, and no data sharing between the programs exists, IHFA is suggesting that two files, one for each program, be kept. 34

35.  EIV Q and A #63:  Can we ask a zero income tenant to show us the contents of their wallet? ▪ No. Viewing the contents of a tenants wallet would serve no purpose in establishing annual income. 35

36.  The following is an example of the repayment process from start to finish:  A resident comes in for their annual recertification and it is found, through the use of EIV, that they have been working for 9 months making over $200.00 per month.  A third party verification is sent to the employer and the information is confirmed.  An IR is created effective 08-01-08 (which is the first of the month following the date of hire) 36

37.  It is noted that the resident now owes over paid subsidy in the amount of $1,000.00.  A repayment agreement is signed by the resident agreeing to pay at $100.00 per month for 10 months.  Since the reason for the over paid subsidy is un reported income from the resident, the owner does not have to pay HUD back, until and as the resident pays the owner.  The 08-01-08 IR, making a negative adjustment is reported on the next HAP voucher. 37

38.  A manual adjustment is added to the same voucher in the amount of $1,000.00 to reverse the adjustment made due to the over paid subsidy.  A copy of the executed repayment plan is mailed along with the voucher.  IHFA begins tracking the repayment of the subsidy.  The resident comes into the office and pays $100.00 toward the balance due. 38

39.  A negative manual adjustment in the amount of -$100.00 is made to the next HAP voucher, with a description of the resident name and unit number.  This process is repeated until the over paid subsidy has been paid in full.  If the resident does not pay, or pays less or more than agreed upon, the voucher should reflect accordingly. 39

40.  The EIV Q and A questions #58, #59 #62 through #64 address repayment plans in more detail. Please read and review these questions when you are writing and/or updating your policies.  There is no suggested form for repayment plans. IHFA suggests you consult legal council when creating this form. 40

41.  HUD has schedule a second Webinar for October 2009. Check the EIV Q and A for more information  4350.3 REV-1 Change 4 is on process and will include EIV information and requirements.  HUD is in the process of updating Notice 2008-3, which is the HUD notice regarding EIV.  Q and A on update of Chapter 6 of 4350.1 41

42.  In September 2009 HUD will be releasing an update to EIV that will include:  The O/A certification report  Reformatting of reports  Recertification of users to bi-annually instead of quarterly.  Ability to view M-ID’s in EIV 42

43.  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) 43

44.  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 44

45.  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 45

46.  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 46

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