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HUD Handbook 4350.3 Change 4 – Investment Assets

Written by Erik Whitton, Spectrum Enterprises

HUD recently revised some language in the HUD 4350.3 Handbook.  Some of the changes relate to how manager should treat investment and retirement accounts.  Past versions of the HUD handbook were unclear and many LIHTC compliance consultants felt certain accounts had to be treated as both a source of income as well as an asset on the certification form for the family.  

Based on the new language in Change 4 Spectrum will no longer advise our clients to treat these accounts as both a source of income as well as an asset.  Here are the key issues to verify:

1.  If the tenant is receiving periodic payments the account should be listed as income on the certification form.  You no longer treat this as an asset.

2.  If the tenant is not receiving periodic payments but has access to the balance in the account treat this as an asset.

3.  If the tenant cannot access the balance in the account and no periodic payments are taken this counts as neither income nor an asset. 


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