On July 29 and August 9, 2021 HUD released updates to its COVID FAQs.
You can find the document here >
Changed sections include:
Q: Can participants in Multifamily Housing programs receive assistance under the U.S. Department of Treasury’s (Treasury) Emergency Rental Assistance (ERA) Program for rent or utility arrearages?
A: Yes, Multifamily Housing owners/agents may accept funds from the ERA Program for rental arrearages and some utility arrearages for HUD-assisted families. Due to the COVID-19 pandemic, families may have experienced unexpected financial hardships, and some families may have fallen behind on their rent or utility payments. Consistent with the Treasury FAQs, Question 15, dated March 26, 2021, HUD-assisted families that have accumulated a rent or utility arrearage and are at risk of experiencing homelessness are eligible for assistance from the ERA program provided that ERA Program funds are not applied to costs that have been or will be reimbursed under any other federal assistance.
Much more information on ERA for subsidized residents can be found in the FAQ.
Q: The American Rescue Plan of 2021 (ARP) provides a monthly payment from the enhanced child tax credit that will begin being distributed to families in July 2021. Can HUD clarify whether these payments are to be included in tenant income calculations for HUD assisted Multifamily housing?
A: Section 7527A: Advance Payment of Child Tax Credit in the ARP provides a monthly payment up to $300/month from July 2021 through December 2021. Owners/agents shall exclude the child tax credit on the basis that it is excludable income under 26 USC 6409.
Q: The CARES Act identifies different types of unemployment compensation. Can HUD clarify which payments are to be included in tenant income calculations for HUD assisted Multifamily housing?
A: The CARES Act contains the following three types of unemployment compensation:
- Section 2102: Pandemic Unemployment Assistance (PUA). This is an unemployment benefit for individuals who are self-employed, seeking part-time employment, or whom otherwise would not qualify for regular unemployment insurance (UI). HUD has determined that PUA benefits must be included as annual income. In instances where the tenant was required to repay PUA because s/he was not entitled to the payment, and evidence of the repayment can be provided by the tenant, then the amounts of PUA repaid must not be counted as income.
- Section 2104: Federal Pandemic Unemployment Compensation (FPUC) program. This program provides eligible individuals who are collecting certain UI benefits, including regular unemployment compensation to receive an additional $600 in federal benefits per week for weeks of unemployment ending on or before July 31, 2020. FPUC was reauthorized by the 2021 Appropriations for a reduced amount and then extended by the American Rescue Plan (ARP). FPUC benefits are now available under the 2021 Appropriations at $300/week through the week ending on or before September 26, 2021. HUD has determined that FPUC benefits meet the definition of temporary income and must NOT be included in annual income.
- Section 2107: Pandemic Emergency Unemployment Compensation (PEUC) program. This program provides an extension to regular unemployment insurance benefits for eligible individuals. This program was extended to reflect the actual number of weeks of unemployment ending on or before September 6, 2021. HUD has determined that PEUC benefits must be included in annual income. HUD also notes that regular payments of unemployment insurance (issued by the state) are treated as annual income according to existing HUD regulations.
Further guidance on the CDC eviction moratorium, financial audits, residual receipts, capital needs assessments, and RAD closings is also included.
