HUD has never addressed the many app-based arrangements that seem to appear by the hundreds each day. A little research may be necessary when dealing with new potential internet-based income. It may appear safer to simply count the deposit as income, but we believe that accuracy is more important and fairest to our applicants and even the owners of the property. So, when we got this question, we did a bit of digging.
The ibotta website explains how their system works. As the applicant told you, people shop for items as they usually do at thousands of possible physical or online stores. Discounts for specific items have been arranged with stores and item manufacturers by Ibotta. Sometimes, the discount is automatic, reducing the price of single items that are bought. Sometimes, it is a discount on an entire purchase. Similarly, sometimes the discounts are applied automatically, and sometimes the person has to submit receipts after purchase to get a rebate. However the arrangement works, we believe that you can think of the app as providing sale prices. Sometimes, the discounts come separately in the form of deposits to a person's account, which is what was observed on the bank statements. Still, it is simply the way the household is taking advantage of arranged sale discounts. We are not aware of anyone who has ever suggested that, when a household takes advantage of sale prices, coupons, or rebates, it should be treated as income. More importantly, nowhere has any HUD guidance suggested this.
Why does this matter?
Some may say that it is just safer to count the deposits as income. We can see building that case if there was no harm to anyone. However, if it does do harm then it would appear not to be so much safe as incorrect. Counting ibotta or other arranged discount deposits as income would be inconsistent with how sale prices and rebates have been addressed for as long as HUD has calculated income, to our knowledge. It would also incorrectly increase rent for households that receive income-based rental assistance (such as HUD or RD). Finally, it would potentially result in declaring a household income ineligible who actually qualifies for an affordable housing unit, which is bad for the applicants and may increase an owner's vacancy loss. Even if they qualify, they may have to take a unit at a higher income set-aside, with higher rent, than actually applies. This is an example of how research and accuracy in the face of an unknown produce better results than a shortcut solution that might be imagined to be safer!
Check out our Jump Start! New Manager Bundle HERE. Gigger and app-based arrangements are covered. Looking for quality online on-demand Affordable Housing training for new managers? Or a great refresher for more experienced ones? The bundle includes Qualifying Households for the programs that you need and Fair Housing Fundamentals. More information on this amazing bundle is at the above link.
