Verifying SS Debit Cards: Policy Clarification

RHIIP ListServ #296, issued in February, reminded us that Social Security benefits may now be paid via  Direct Express debit cards.  This ListServ revised previous guidance, saying that the current balance of this debit card is considered an asset, with verification of the current balance (similar to a savings account.)  Management can use the current balance that the tenant obtains from an ATM, or through the online account service or a paper statement, and the verification document must identify the account and the account holder.

But in real life, when tenants provide ATM statements they include only the last four digits of the account number, and do not include the tenant’s name.  Since the tenant must pay for the online or paper statements, these are not used as often as ATM statements.

In a May 2, 2013 email, Michael Sharkey in Policy clarified that the verification must show “a relationship between the verification document and the account holder”, and that HUD will not define verification any further than that.  He did agree that, if management makes a copy of the Direct Express Card, showing the tenant’s name and full account number, and attaches the copy to the ATM printout, that would satisfy the requirement.

We recommend that you do exactly that. Do not forget to count the SS benefit payment as income too… just as employment pay counts as income, and bank accounts are assets.  Some managers have mentioned that debit card balances will be lower at the end of the month after tenants have bought their monthly groceries and paid their bills.  Since verifications are valid for 120 days, ATM statements printed any time of the month will be valid for verifications.