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HUD Change 4 Part 1

Posted on: December 24th, 2013 by Christa Landram 3 Comments

Have you heard of the infamous “Change 4?” If you’ve been in the industry for longer than four months, I’m sure it has been discussed around the water cooler at least once.  This Change is not to be taken in the singular tense. In fact, Change 4 includes more than 225 changes. Don’t fret too much though! Many of these changes are related to typos, duplicates, and other non-substantial changes in the HUD 4350.3 Handbook.  To make things a bit more manageable for you, I will explain some of the more substantive changes. This post will be part of a series because if I tried to put all of the changes in one post, I would lose your interest pretty quickly.  So let’s start with one substantive change this time, and tuned for more updates to come. My hope is that you will be able to get through all of the posts before Change 5 is released!

First, let’s start with the basics. Department of Housing and Urban Development (HUD) issued Change 4 to their 4350.3 Handbook with an effective date of August, 7, 2013. The announcement did not take place until August 22, 2013 but all changes listed are effective as of August 7, 2013.  As you go through this seemingly daunting handbook you will find the changes denoted by an asterisk (*) at the start and end of each change. This assists us in easily locating the changes.

Recently, there has been some confusion as to whether or not a social security number is a necessary component to the eligibility process, so HUD has made this very clear with some distinct revisions to the Handbook. On January 31, 2010 several modifications were made to various sections to include Social Security Number (SSN) requirements. The new Handbook doesn’t actually include any changes to the Final Rule from January 31, 2010, it just adds a little bit of clarity. HUD requires that every assisted individual have a Social Security Number and to provide the necessary required documentation.  HUD’s stance is no social security, no subsidy. This is a pretty clear rule, lacking no grey areas. For those assisted residents who have never had a SSN or who have lost their card, they must do their due diligence and submit to SSA a SS5 form.

Many of you may have waiting lists full of potential applicants, and perhaps may be wondering what if the applicant has everything they need but the SSN? The applicants are able to keep their place on the waiting list; however every assisted household member must provide SSN documentation prior to occupying the unit. For example, if Family 1 makes their way to the top of the waiting list and a household member(s) cannot provide SSN documentation, Family 2, who are second on the waiting list, will then be able to move into the unit first, while Family 1 will remain on the list until they can provide the required documentation.

There are some household members who were 62 years of age of older as of 1/31/2010 and are exempt from the SSN requirement. Furthermore, non-citizens are also exempt from needing a SSN. It is important to note that you are not to add a new assisted household member to your site until all SSNs have been recorded and documented. Another helpful tip is to add a question to your recertification questionnaire asking if anyone has changed their SSN or if there has been a change to anyone’s SSN.

3 Responses

  1. Briana Castillo says:

    Can you please clarify? It is my understanding that 221(d)(3) BMIR, 202 PAC, 202 PRAC and 811 PRAC do not have restrictions on assistance to non-citizens so in these programs there would not be the same disclosure requirements as in other programs covered in 4350.3, but I thought that the only other instances where non-citizens are exempt from SSN disclosure is if the non-citizen is not contending to have eligible immigration status. The last paragraph above states that, “non-citizens are also exempt from needing a SSN.” Does this mean all non-citizens, regardless of whether they claim to have eligible immigration status, are exempt from having to disclose a SSN?

    • Christa Landram says:

      Thank you so much for your inquiry, Briana! We would love to help you answer your question. But, in order to better assist, would you be able to further clarify the statement regarding “no restrictions on assistance”?

    • Christa Landram says:

      Briana, to clarify the non-citizens statement this is referring to ineligible non-citizens since they are not getting HUD assistance. Eligible non-citizens will have SSNs. So, if anyone in a PRAC (for example) does not have an SSN, the exemption states that s/he would sign a statement saying that the reason for not having one is that s/he is an ineligible non-citizen.

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