This is an unprecedented time with lots of unknowns, fears and challenges. As you may be aware, we are beginning to get affordable housing-related notices from HUD, the IRS and many state HFAs. Much of this news relates to keeping ourselves and our residents healthy but some of it also deals with handling rent, recertification and monitoring issues.
HUD REAC has stopped all inspections until further notice and has issued a Q&A document addressing many affordable housing-related issues. Owners and managers are being encouraged to conduct interviews via telephone or through the use of teleconferencing options, receive documents including verifications electronically and obtain tenant signatures later and instead sending certifications using Extenuating Circumstance Codes. They also recommend setting up secure collection boxes for rent and other payments.
In the meantime, HUD indicates they are working diligently to ensure all housing assistance payments, operations funding and various other funding streams continue to be paid. They also indicate that a decrease in household income is not a basis for termination or eviction and encourages owners/managers to prevent displacement through such action.
HUD has prepared a Q&A document addressing many concerns and have promised to update it on an ongoing basis as new information becomes available. Some of the questions this document addresses include, but are not limited to…
- What to do if a household needs to quarantine a household member and asked to use a vacant apartment to do so;
- The steps to take if a household is unable to make their rent obligations;
- How and when operating account funds can be accessed to assist with outbreak preparedness and response (including extra supplies, administrative assistance and overtime, etc.); and
- How to work with residents (infected or not) to complete recertifications.
LIHC properties should look to their state HFA for specifics as the IRS, at this writing, has not yet made any announcements, however several State HFAs have including California, Indiana, Flordia, Georgia, Kentucky, Ohio and Texas. I expect this list to expand greatly in the next week or two.
EMC Response to Coronavirus
We are taking the necessary precautions here at Elizabeth Moreland Consulting (EMC) as well. Personally, both my family and Bobbi’s are practicing self-distancing as recommended by the CDC. Fortunately as the majority of our services are made available online, most things will not change as we will be keeping the Housing Credit Training Center fully functional which means all classes are available 24 hours a day… 7 days a week… accessible anywhere you have internet access. However, we have canceled any face-to-face trainings a nd engagements until further notice.
As for certificate requests, NCP Membership related-items, product orders and other such requests/orders, please understand there may be delays in delivery. We will process these as quickly as we can but also will be limiting Bobbi’s exposure to the public which includes trips to the post office and the like.
We will respond to phone calls, voicemails, emails and other correspondence as quickly as we can but understand there will be delays as we are working remotely. Emails are the BEST way to communicate with us during this period but we will also be checking our phone messages regularly throughout our normal business hours and will get back to you as soon as we can. When emailing us, please use [email protected]. Bobbi managers this account and will forward any messages to me that need my attention. Compliance Coach emails are expected to be answered timely but this may change if circumstances change here.
If you have any time-sensitive needs, please email us at the above address and let us know the details surrounding your situation. We will do our best to help meet these needs but will do so in a way that keeps our families and our community at large protected.
Stay healthy everyone! And be kind!!
This is a stressful period for everyone
with many experiencing increased anxiety and fear.