HUD’s Office of Multifamily Housing Issues Memorandum on Income Recertifications, April 13

HUD’s Office of Multifamily Programs (Multifamily) distributed a Memorandum, “Annual and Interim Recertification Protocol during COVID-19,” from Tobias Halliday, director of the Office of Asset Management and Portfolio Oversight (OAMPO). The Memorandum simply repeats the recertification protocols of Q7 of HUD Multifamily’s April 7 “Questions and Answers for Office of Multifamily Housing Stakeholders: Coronavirus (COVID-19)” (see Memo, 4/6).

The Memorandum was sent to HUD Multifamily regional center directors, satellite office directors, asset management directors, and performance-based contractors. It was also sent to other stakeholders like NLIHC. It is not posted on the HUD Multifamily website yet.

HUD considers the Center for Disease Control and Prevention’s (CDC’s) recommendations for controlling the spread of the coronavirus as well as shelter-in-place and similar orders as qualifying as an “extenuating circumstance” that might impede owners and tenants from complying with interim and annual income recertification requirements. Therefore, owners should follow the extenuating circumstance instructions provided in the April 2 update as well as HUD Handbook 4350.3 REV-1.

HUD recommends an owner begin, and if possible complete, recertification actions within 90 days of being advised of the extenuating circumstance. When an extenuating circumstance is present, there is no change to a tenant’s recertification anniversary date. The Total Tenant Payment/Tenant Rent and the assistance payment are effective retroactively to the recertification anniversary date.

HUD will allow tenants who may have lost income due to coronavirus to self-certify for annual or interim recertifications. Self-certification can be used if the information cannot be verified by another acceptable verification method. Self-certification can be provided to the owner by other means such as mail or email, and the owner may consider collecting the original documents from the household at a later date.

HUD will allow alternate signatures (e.g. copies or images of signatures sent by email, fax, or other electronic means) as long as original (“wet”) signatures are obtained at a later date. Tenants can provide the owner with required documentation for the recertification by email or other electronic delivery at the owner’s discretion.

“Annual and Interim Recertification Protocol during COVID-19,” is at: