HUD’s Q&A for Multifamily Housing Updated

On April 14 and April 16, HUD updated its Q&A for Multifamily Housing document making this the 3rd and 4th update respectively. The following clarifications – in no particular order – were made…

  • The $1200 household stimulus payments and the temporary $600/week enhancement to unemployment are NOT to be included in calculations of income BUT regular state-issued
    unemployment payments are includable.
  • There is NO prohibition on having residents who have been hospitalized with COVID-19 from returning to their unit until a negative test is received and in fact, encourages us to be cooperative.
  • Properties DO have the authority to restrict visitors but state and local laws should be reviewed first and if visitor restriction is implemented, property policies/rules must be amended.
  • The majority of the funding Congress appropriated for multifamily housing programs through the CARES, Act is designated for increased rental subsidy to cover tenants’ loss of income but also for increased cleaning costs.
  • Indicates that if a property received an inspection Notice of Default prior to the stoppage of inspections, all Exigent Health and Safety (EH&S) deficiencies must be corrected immediately and clarifies the process.
  • Service coordinators should take the necessary protection precautions including working remotely BUT if the person’s salary is funded by a grant or the project budget, they must continue to function.

The Q&A document also addressed the eviction ban, utility analysis, move-ins/move-outs, forbearance, property contract renewals, non-receipt of certificates of occupancy, 223(f) underwriting guidance, Phase I ASTM Environment Site Assessments and the General Counsel’s office response during the pandemic.

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