The Department of Housing & Urban Development recently issued a clarification regarding whether or not to count the “cents” that show up as part of the gross amount of Social Security income on Social Security Award Letters. The clarification was made in the Multifamily Housing Rental Housing Integrity Improvement Project Listserv #256.
The issue arose because Section 8 properties using the Enterprise Income Verification (EIV) system were finding that while the Award letter was showing the cents, the EIV verifications were not.
Per the HUD guidance, HUD Notice 2010-10 states the Income Report identifying the Social Security benefit information in EIV must be used as third party verification of the tenant’s income and will be used to calculate the tenant’s income. Additionally, the owner/agent (O/A) must confirm with the tenant that the current benefit amount in EIV is correct. If the tenant agrees that the EIV information is correct, the O/A must use the gross benefit reported in EIV for calculating the tenant’s income by annualizing the gross benefit amount projected forward for the next 12 months. This permits the use of the amount shown in EIV (even if no cents are included) to calculate income.
When a SSA award letter is used to calculate income (e.g., tenant disputes the EIV report or LIHTC properties), the amount shown on the award letter should be used to calculate income, including any cents that are shown. HUD also confirms that the award letter must not be older than 120-days.