UIV: Breaking News

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NEWS FLASH -- Since writing and posting this item, we received an email from Linda Kornegay of HUD-RHIP (RHIIP Listserve #139) that stated as follows: "Although the effective date may be delayed, owners and management agents are encouraged to begin informing applicants and tenants who have not disclosed their social security number, or the social security number of a child under the age of 6, or who have certified they do not have a social security number, of this upcoming revision to the regulations and their need to begin the process of obtaining a social security number.

In addition to the above, owners and management agents who have access to the Enterprise Income Verification (EIV) system should be verifying and correcting social security numbers for individuals listed on the Failed EIV Pre-screening and the Failed Verification Report as having invalid social security numbers. "

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HUD published today their promised notice pertaining to the Upfront Income Verification (UIV) final rule that appeared in the Federal Register on January 27, 2009.  Here are the details:

* HUD is considering a delay of 60 days in the implementation date for UIV. 

* They are soliciting comments on the delay and the Final Rule, and the deadline for comments is March 13, 2009.

This is being done to comply with the request of White House Chief of Staff Rahm Emanuel that agency heads have an opportunity to review pending regulations in order to identify any issues of "law or policy" that need to be addressed.  This request does not require a 60 day delay, it merely provides that as an option.

What does this mean?

What this means is that the UIV Final Rule, published on January 27, 2009 remains intact.  The implementation dates may or may not change.  While the comment period may elicit issues of "law or policy," we do not yet know this to be a fact.  It is therefore entirely possible that the Final Rule will be left to stand as published without any substantial amendments.

What does NCHM intend to do?

We will be commenting during the period set forth by HUD in the notice today.  We will also continue to offer training on the UIV Final Rule, and have made this decision because there is a chance the effective dates will not change, and this could have our industry scrambling for training at "the last minute." 

But given the possibility of deadline extensions and even the slight potential for change, we're calling our program: UIV PLUS.  We'll cover in detail the UIV Final Rule and recent developments, and we're also adding to the training, by popular demand, detailed treatment of the Violence Against Women Act (VAWA), IMAX/202C issues, and some important fair housing related topics.

Additional information is immediately available by contacting our offices at 1-888-291-5562, and our website (www.nchm.org) is in the process of being updated.  You can also contact me directly with any questions by commenting to this post.