Three most common mistakes to avoid in Multifamily Housing Enterprise Income Verification (EIV)
Unlike other programs, Multifamily Housing Enterprise Income Verification (EIV) doesn’t allow you to write your own rules; instead, you must follow official guidelines to the letter, every time. A mistake is worth potentially millions of lost dollars: Any violation will result in HUD taking 5% of the total property’s voucher for the month following, then for each month thereafter until the violation is cured.
So let’s help you avoid costly errors. Here are the three most common mistakes in EIV you should be aware of.
Not pulling the summary and income reports
You are required to pull the summary and income reports 90 days after a move-in is submitted to TRACS. A lot of owners fail to pull these reports which end up costing them. It is also important to review income reports, resolve any discrepancies, and to retain a copy of the reports in the resident file.
Not pulling the income and income discrepancy report with every interim
The income and income discrepancy report must be pulled with every interim regardless of what the interim is for. For example, if you’re adding a new baby to the household, even if it doesn’t impact the family’s income, you’re still required to pull an income and income discrepancy report. This is because you still need an income report even if it’s about changing family composition. Make sure this information is in the file with that interim.
Not getting the 9887/9887A consent forms signed
If your residents have a 17-year-old who’s turning 18 in between interims or in between annuals, the family doesn’t have to report when that child turns 18. The owner must keep up with that information either with a birthday tracking chart or software. When the child turns 18 in between recertifications, you must find the child and get the forms signed. You can’t pull your EIV income reports on time that month until everyone in the household has signed those consent forms.
Remember! EIV must be used in its entirety, you must do everything right every time or it will cost you. So be aware of these common mistakes to make sure you’re always in compliance with EIV rules.
Interested in learning more? Be sure to register for our Multifamily Housing Specialist course where we cover eligibility, screening and selection, admission, rent calculation, recertification, termination, and a discussion of HUD’s multifamily systems.
About the author:
Renee McTyeire is an accomplished, motivated, and goal-oriented trainer and consultant with a proven track record of managing, training, and consulting, gained through more than two decades of progressive leadership experience in the multifamily housing industry. She left property management in 2004 to work for a performance-based contract administrator (PBCA) for four states, where she conducted management and occupancy reviews (MORs) and processed special claims. In 2007, she took a senior trainer position with the same PBCA, training multifamily housing owners and agents in compliance with the program’s HUD Handbook 4350.3, REV-1, Change 4, and on proper submission of special claims. Since joining NMA in 2016, she has been the multifamily housing subject matter expert, training owners, agents, and PHAs in multifamily housing compliance, the Rental Assistance Demonstration (RAD) project-based rental assistance (PBRA) program, and customer service skills in affordable housing. She also provides consulting services nationwide, and recently took the lead role in developing NMA’s Model Tenant Selection Plan, Model EIV Policies and Procedures, and the new Multifamily Housing Rent Calculation seminar.