This will probably be my final blog post for 2009, and I felt a short review was in order, and might even be marginally entertaining for those of us in the compliance side of the housing management business.

Secretary Donovan and his team at HUD are also soon to mark the end of their first year, and what a year it has been.  The main focus of the agency has been on matters of economic stimulus, as well as a Green Retrofit Program.  Public Housing Authorities moved toward asset management at a variety of paces ranging from total stealth to aggressive resolve.

The HUD Handbook 4350.3, Rev. 1 had Change 3.  And, of course, we have the mandatory use of Enterprise Income Verification (EIV) now slated for January 31, 2010.  EIV didn't originate with the present administration, but the numerous HUD-RHIIP generated emails over the past few weeks make clear that Secretary Donovan is committed to its implementation.

(I am personally glad, because these numerous changes in the implementation dates: March 2009; September 2009; January 31, 2010 reminded me of the kind of indecisiveness that occurs when certain members of my family are at a restaurant that features a menu with too many choices).

On the tax credit side, the dismal economy has created some difficulties as there are fewer entities signing on as part of syndication deals; it is easier to find interest when the economy is performing in a robust fashion and there is an associated desire to benefit from the tax credits.  Moreover, residents in a tax credit property, with the exception of those receiving Housing Choice Vouchers, pay an "affordable" rent that is fixed.  If the household loses their income, and a Housing Choice Voucher is not available for them, the result is a vacancy through the household moving out of their own volition, or by way of an eviction.

While I cannot celebrate 2009 from a compliance perspective, I can and will celebrate the people who are part of our industry.  I don't think I am being sentimental by telling you that the constant travel and the degree of energy training demands is sometimes more difficult for me to manage as I get older.  What makes it worthwhile for me, always, are the men and women I meet.  I don't think there are many industries which can hold a candle to ours for compassion, diligence, and professionalism.  The skill sets that are demanded are constantly changing, and my colleagues at NCHM and I are constantly developing new training offerings to compliment and strengthen those skills.

I wish all of you another year of health, happiness, and success.  See you again in 2010.

HUD announced today that it has issued Notice H09-15 on the Violence Against Women Act (VOWA).  The new notice replaces HUD Notice H08-07.  There is no difference in content between the two notices, but HUD has clarified that despite its name, VAWA is not gender specific (something NCHM has been pointing out in its UIV-Plus training programs).

HUD is also sharing the official word from the Social Security Administration that there will be no cost of living adjustments (COLA) for 2010. 

HUD has announced the release of Notice H 2009-11 (September 9, 2009) on the subject of State Lifetime Sex Offender Registration.

The notice "reiterates current regulatory requirements whereby owners and management agents must perform necessary criminal history background checks to determine if an applicant, or a member of an applicant’s household, is subject to a lifetime registration requirement under a State sex offender registration program."

The notice also encourages Owner/Agents to adopt a "zero tolerance" policy, including the following:

1. Ask households at each recertification whether any member is subject to a lifetime registration requirement under a State sex offender registration program.

2. Use the Dru Sjodin National Sex Offender website to confirm that applicants and federal housing assistance recipients are not lifetime registered sex offenders.

3. Aggressively termination of assistance or tenancy, as appropriate, for tenants subject to a State Lifetime Sex Offender registration requirement to the extent allowed by law.

The full notice can be accessed here:

http://www.hud.gov/offices/adm/hudclips/notices/hsg/

HUD Secretary Shaun Donovan has announced that the date for mandatory implementation of the Upfront Income Verification (UIV) Final Rule has been extended to January 31, 2010.  The announcement was made in a notice appearing in today's Federal Register.

The stated reason for the additional extension from the implementation date of September 30, 2009 is that HUD wanted additional time to review comments submitted earlier this year so they could address issues of law or policy.  

The notice also states that HUD remains committed to implementing Upfront Income Verification. 

The Associated Press is reporting that there might not be any Cost of Living Adjustments for Social Security recipients for the next two years.

In an article entitled "Social Security Payments may shrink in 2010," Associated Press reporter Stephen Ohlemacher cites projections by trustees who oversee Social Security.  His article notes that COLA's have been automatic since 1975.

The report, if true, could impact those assisted housing properties who include COLA's as a matter of routine for Annual Recertifications effective in January, February and March.  EIV becomes mandatory on September 30th but past EIV notices have stated COLA information will not be available until the end of the year, by which point January-February-March AR's are already in process.

I am posting this for informational purposes only.  As someone who lived and worked in the Washington, DC area for a decade I can attest that a lot can happen on sensitive and highly political issues such as Social Security and the well-being of senior citizens.

The deadline for the mandatory implementation of Enterprise Income Verification (EIV) and the Upfront Income Verifications (UIV) regulations is eight weeks away.  In the hectic and constantly busy world of housing management this time will go by very quickly.

HUD has just issued an EIV brochure for residents, and the brochure can be accessed here:

http://www.hud.gov/offices/hsg/mfh/rhiip/eivbrochure.pdf

Additionally, HUD has posted updated Q&A's from their December 2008 EIV webcast.  This can be accessed here:

http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/eivhome.cfm

Among the many tasks that will need to be accomplished in the coming weeks, even for those Owners/Agents and Public Housing Authorities that have full EIV access, is the development of policies and procedures (HUD calls them "well written policies") associated with EIV and UIV.

I will be available in the coming weeks to offer consulting to Owners/Agents and PHA's, including reviewing policy/procedure drafts.  If you're interested, please contact NCHM's Operations Division in Orange Park, Florida to obtain a quote and contract by emailing: service@nchm.org or calling 1-888-291-5562.