Key reporting requirements for
landlords under HOTMA:
Income
Reporting:
Frequency: Landlords
must report tenant income and rent changes annually through the HUD
Electronic Tenant Selection System (e-TSN).
Information
required:
Gross
income for all adult household members and authorized minors.
Source
of income for each earner.
Deductions
claimed by the tenant on their income taxes.
Any
changes in rent over the past year.
Timing: Reports
must be submitted within 60 days of the annual income recertification
or any changes in rent or income exceeding 10%.
Vacancy
Reporting:
Requirement: Landlords
must report any units becoming vacant within 24 hours to the local
Public Housing Authority (PHA) or HUD field office.
Additional
information: The report should include details like the unit
number, lease information, and reason for vacancy.
Tenant
Fraud Reporting:
Responsibility: Landlords
must report any suspected tenant fraud related to the program to the PHA or HUD
field office.
Examples
of fraud: Providing false income information, unauthorized
occupants, exceeding income limits, or misuse of vouchers.
Other
Reporting:
Unit
inspections: Landlords may be required to report on the condition of units
during scheduled inspections.
Tenant
requests: In some cases, landlords may need to report tenant requests
for repairs or modifications.
Important
notes:
Compliance: Failing
to comply with reporting requirements can lead to penalties, including
suspension from the program or financial sanctions.
Resources: The
Department of Housing and Urban Development (HUD) website provides resources
and guidance on HOTMA requirements for landlords, including the e-TSN
system and specific reporting forms.
EIV Income Report and Safe Harbor for Landlords under HOTMA
The Electronic
Income Verification (EIV) system automatically retrieves income data from
various sources, including Social Security Administration and Internal
Revenue Service.
Landlords
can use the EIV:
As the
sole verification for Social Security income.
In
conjunction with self-certification for prior-year income at annual
reexaminations.
As
supporting documentation for other income types if not fully covered by
Safe Harbor.
Benefits
for landlords:
Reduces
need for manual collection and verification of income documents.
Streamlines
the process and potentially saves time.
Increases
data accuracy and reduces risk of fraudulent reporting.
Limitations:
EIV
doesn't cover all income sources (such as self-employment sources and some
gig income).
May
not be available for all programs or locations.
Safe
Harbor:
Safe
Harbor allows landlords to accept income reported in certain other
programs without further verification.
Programs
accepted under HOTMA:
Social
Security Administration benefits annual
cost-of-living adjustments (COLAs) be included
Supplemental
Security Income (SSI)
Veterans
Affairs benefits
Unemployment
insurance
State
or local public assistance programs
Earned
Income Tax Credit (EITC)
Benefits
for landlords:
Simplifies
income verification process for qualifying income.
Reduces
administrative burden and saves time.
Limitations:
Only
applies to specific income sources listed above.
Income
from assets is always subject to verification.
Remember:
Landlords
can choose between EIV and Safe Harbor based on preference and
eligibility.
Combined
use of EIV and Safe Harbor is prohibited.
Landlords
are responsible for understanding and following HOTMA reporting
requirements in their area.
OTHER NOTE:
Section 104 of HOTMA sets asset limits
for households seeking or keeping federal rental assistance. The limits are $100,000
in net household assets and ownership of real property that is suitable for
occupancy by a household as a residence. However, retirement accounts and educational savings accounts are not
considered a net family asset and are not included in the limit. Assets are reviewed for extrapolating it as an income
source.
