A HANDBOOK WE CAN BELIEVE IN...

Housing professionals who have been reading this blog know that I have been on my "soapbox" for a while now about the need for a revised HUD Handbook 4350.3, Rev. 1 as an alternative to all the HUD notices that have been issued.

Here's one more reason, if one was needed.

I've been getting a lot of questions lately from Section 202 PRAC properties who are diligently trying to implement the provisions of the consolidated notice on the use of EIV (HUD Notice H2010-10). This notice contains detailed instructions on "mixed families" and Social Security numbers.

"Mixed families" is a term that is part of the Section 214 (Non-citizen) rule. Nothing wrong with what HUD did here; the noncitizen rule applies to most HUD programs......

.....BUT.....it does NOT apply to Section 202 PRAC (Paragraph 3-12, HUD Handbook 4350.3, Rev. 1).

Does this mean that, on this issue, Section 202 PRAC properties fall back to Paragraph 3-9 of HUD Handbook 4350.3, Rev. 1? If so, that paragraph does not contain ANY penalizing provisions for anyone who NEVER had a Social Security number (Paragraph 3-9A). It states they simply certify they never had an SSN.

The only "penalizing" provisions, in Paragraph 3-9C, apply to individuals who HAVE an SSN, but cannot document it. Don't believe me? Read the first sentence of the paragraph.

I am not one to "slam" HUD. I used to work there. And I know what the agency is capable of....which is excellent rulemaking for good and valid reasons.

But putting owners/agents between the proverbial "rock and hard place" benefits no one -- particularly the extremely low-very low-low income families our industry is proud and privileged to serve with the fundamental human need of safe, decent and sanitary housing.