Updates to a Multifamily Q&A Document Provide Clarification during COVID-19 OutbreakMarch 26 update: HUD provided an updated COVID-19 Q&A on March 24, 2020, which provided additional information regarding the following topics:
“The deferral of non-essential or non-health and safety repairs should be made on a unit-by-unit basis. If the repair is necessary for the health and safety of residents and the staff person is not comfortable entering the unit as a result of potential COVID-19 exposure, owner/management should consult local health guidance regarding the appropriate precautions to take.”
“All entities required to submit financial information on or before April 30, 2020, are now required to submit their financial information no later than 120 days after the end of the fiscal year of the reporting period, and as otherwise provided by law. This waiver does not apply to the submission requirements for financial information that was delinquent as of March 23, 2020.” HUD also addressed several questions related to Loan closings. Updates to HUD Guidance on Recertifications Related to Collection of Signatures for TRACS SubmissionsOn March 24, 2020, HUD published guidance on the impact of COVID-19 on the Annual Recertifications and Interim Recertification related to the collection of signatures and TRACS submissions.
HUD provides that if a tenant is unable or unwilling to come into the office to sign an annual re-certification the owner/agent may submit the AR to the TRACS using one of the following three (3) extenuating circumstances codes:
1 = Medical (medical staff have quarantined the tenant)
2 = Late annual certification due to accommodation or extenuating circumstances
10 = Other
The owner/agent must obtain a signature from the tenant and submit a corrected certification to TRACS once the pandemic has passed.
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