EIV,Third Party Verification and PBCA's

During a recent training, I inadvertently stunned my audience by a comment I made about EIV compliance.  To be completely candid, I did not do the best job of phrasing my comment -- and EIV can be confusing enough without the poor explanation of a rule. 

The issue at hand is traditional third party verifications.  According to this audience, their PBCA's were requiring them to get traditional, third party verifications of income even in instances where the EIV Income Report and tenant-submitted documentation agreed, and were without dispute.

HUD Notice H2010-10 states as follows: When there is NO DISPUTE of the EIV Information: "EIV Income Report, current acceptable tenant-provided documentation, and, if necessary (as determined by the Owner/Agent) third party verification. (HUD Notice H2010-10, Section VII, Part A2b(1), page 19 (emphasis added)).

This seems clear to me.  In instances where there is no dispute of EIV Information from the Income Report, it is the decision of the Owner/Agent, not the PBCA, whether or not traditional, third party verification should also be obtained.  An extensive (not exhaustive) listing of acceptable tenant-provided documentation can be found in Appendix 3 of HUD Handbook 4350.3, Rev. 1.

For the record, PBCA's get a bad rap sometimes that's not deserved.  The majority of them do outstanding jobs, and it isn't an easy one.  And we're all human, which means we make mistakes.  The easiest way to create problems, whether you're an Owner/Agent or a PBCA, is to not consistently refer back to source documentation, or to make up rules that are not there.