Enterprise Income Verification

Written by Katie Rawson, Spectrum Enterprises

Recently, I was asked how management should verify Social Security benefits to be in compliance with tax credits.   The property has HUD financing as well as tax credits and management was concerned because HUD has requested that owners use EIV as the primary source for verifying Social Security.  They were also unsure of how to verify the benefit since SSA no longer honors third party requests for verification.

EIV (Enterprise Income Verification) is a topic that keeps popping up within tax credit compliance.  This is a system where certain third party sources share income information on tenants participating in HUD rental assistance programs.

EIV cannot be used to verify income for tax credit residents.  This page shows which HUD programs can use the EIV system http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/resincdisc.pdf.  Please note if your property has both HUD and tax credits you still cannot use EIV to verify income, nor can it be in the tax credit portion of your file.  To answer the above questions posed by management, I would recommend having either two separate sections of a file – one for tax credits and the other for HUD or having two separate files altogether.  In the HUD file you would use the EIV system and for tax credits you would follow regular procedures for verifying income and assets.  To verify Social Security benefits for tax credits you would simply obtain the annual award letter, making sure to use COLA if needed.  As always, be sure to check with your state agency for specific policies.

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