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Using HUD’s Newly Updated Tenant Income Certification (TIC) Form (January 1, 2013)

Thursday, January 10th, 2013

Using HUD’s Newly Updated Tenant Income Certification (TIC) Form (January 1, 2013)

Written by Paul Perpich, Spectrum Enterprises

Click here to download the TIC, these instructions or any of our other updated forms.

January 1, 2013 marks the date you must start using the updated Tenant Income Certification (TIC) form used to collect additional tenant data that HUD is requiring. This new requirement was mandated by congress in the Housing and Economic Recovery Act (HERA) of 2008. The new elements of the TIC form will be incorporated into the Spectrum End of Year (EOY) software that will be available for downloaded from the Spectrum web site on March 1, 2013.

The following additions and changes are include on the updated TIC form:

Part I – Development Data

Square Footage: The unit’s square footage has been added

BIN Address:  There is now separate spaces for City and Zip

BIN#: HUD is requiring that the correct BIN number, as defined by the IRS and located on form 8609, be entered on the TIC. The BIN# must follow the specific format as described below.

Enter the Building Identification Number (BIN) assigned to the building (from IRS Form 8609). This is expected to be in the following format:
            ME-87-00001, ME-87-00002, ME-87-00003, etc.

Where: 
            – ME is the state allocating agency’s two character state designation. In this case Maine.
            – 87 is the last two digits of the BIN’s year of allocation (1987)
            – 00001, 00002, 00003 is a 5 digit serial number usually sequential.

Part II – Household Composition

SSN: 0000 is now the default entry when a social security or alien registration number is not available.

Race: New codes: 6 – Other, or 8 – Tenant did not respond have been added.

Ethnicity: A new code: 3 – Tenant did not respond has been added.

Disabled?:    The disability status must now be indicated as follows:

Enter 1 – (Yes) if the household member is disabled according to Fair Housing Act definition for handicap (disability)

Enter 2 – (No) if the household member is not disabled.

Enter 3 – Tenant Did Not Respond

Part IV – Determination of Income Eligibility

The wording “Current Income Limit per Family Size:” has been modified to “Current LIHTC Income Limit per Family Size for the federal 50% or 60% set aside:”. This is to indicate the income limit entered there must always be the Federal Set Aside Income limit not any reduced income limit that may be in place for the household.

Part VI – Rent

A new section has been added that collects data on any rental assistance that is being provided including the source of any Federal assistance.

Part VII – Student Status

An additional Student Use Explanation code (6. Extended Use Period) has been added.

 

The Art of Clarification

Thursday, April 14th, 2011

Written by Melissa Zera, Compliance Analyst

The key to a well documented file is clarity and organization.  Clarifications are just as essential to the compliance as the other verification forms and documents.  They answer the who’s, how’s , what’s and why’s that left unanswered could lead to potential noncompliance.

Third party verifications often are returned with missing fields, crossed-out or illegible information or data that is just not understandable.  Like the rental application, all data fields must be answered .  Auditors will not make the assumption that the unanswered questions means that they do not apply.  For example, if the overtime field is left blank, then it leads to a possibility, an unknown, a mystery.  They could be receiving.  An indication of  “n/a” or “none” is the proper answer leaving no speculation.  Follow-up should be made directly with whoever completed the form(s) to confirm any missing information not provided.

The use of a separate clarification form is essential.  These forms should immediately precede or follow the verification they are supporting in the file, remember organization is key.  When contacting the employer/bank/etc., be sure to document “who” you spoke with, the company they work for, time/date of contact, “what” information was requested to be clarified and the notate all details resolving the issues.

As document experts, some Property Management companies have become creative in development of specific forms to clarify recurring inconsistencies.  For example, when paystubs are used in lieu of employment verifications, we have seen an Unable to Obtain Third Party Verification form utilized.  If an application is partially completed by the applicant and partially by the manager (a huge red flag during an audit), clarification is noted on an affidavit as to “why” assistance was given by the manager. The use of a calculation worksheet takes the “how” out of determining what numbers were used to annualize income and so forth.

Always take all guess work out of your files.  At the end of the day what story will they tell?  Hopefully not mysteries but happily-ever-afters with zero non-compliance.


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