News | HUD Publishes NEW COVID-19 Guidance for Multifamily Properties

HUD has publised a revision of their Multifamily COVID-19 Q & A document. It can be found HERE. Although primarily addressed to owner/agents of HUD Multifamily-funded properties, the Q & A includes elements vital to tax credit properties. Revisions can be found on pages 12, 13, 18, 21, 23, 28, 37, 38, 57-61.  

Although we encourage reading the document for details, here we provide some helpful summary information. Of particular interest to our readers may be the following issues:

Which CARES Act unemployment benefit types are included and excluded?

Summary |  Pandemic Unemployment Assistance (PUA) and Pandemic Emergency Unemployment Compensation (PEUC) are counted as household income, while the $300 Federal Pandemic Unemployment Compensation (FPUC) is excluded (page 12).

• Tax credit note: This applies to LIHTC and other programs that use the HUD Section 8 definition of income.

Are ARP Act child tax credits (up to $300 from July-December 2021) counted as income? 

Summary | No, these are excluded (page 12 & 13). 

• Tax credit note: This applies to LIHTC and other programs that use the HUD Section 8 definition of income.

What are the current MOR guidelines?

Summary | There were several revisions. For a detailed listing, see pages 20 & 21.

Can HUD-assisted tenants receive ERA funding for their tenant rent and utilities?

Summary | Yes. When it comes to utilities, however, the assistance must only be for utilities in excess of the utility allowance (pages 57 and 59).

Is ERA assistance counted as income to the household?

Summary | No (pages 58 & 59).

• Tax credit note: This applies to LIHTC and other programs that use the HUD Section 8 definition of income.

As a term of accepting ERA, some owner/agents are asked to forgive a portion of the amount owed. Can owner/agents do this for HUD-assisted tenants? 

Summary | No, tenants must pay their portion of the rent and an owner/agent cannot forgive a portion of that (page 61). 

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