Q & A: How long is paperwork good?

Question: On May 23, a tenant brought me in her pension statement dated March 31, 2017. Can I use it for her August 1, 2017 AR? Additional Info: The document appears to be an original document generated by a third party source that has not been altered.

Answer: Yes, the pension verification can be used for the August 1 AR under these circumstances.

The confusing issue with verifications is that there are two (2) 120-day requirements that have to be met to use a verification for an upcoming certification. Per HUD handbook 4350.3 REV-1 CHG-4, 5-13 B.1. b. (1) a third-party verification from source is acceptable as long as it is an original or authentic document generated by a third party source that is dated within 120 days from the date of receipt by the owner. In this example, the owner/agent must have received the document by July 29, 2017; so you meet the first 120-requirement, since you received the document on May 23.

But there’s another 120-day requirement regarding the usage of verification documents, Change 4, 5-16 B. says that verifications are valid for 120 days from the date of receipt by the owner, not the effective date of the 50059. Again, since you received the verification document on May 23, you comply with the second 120-day requirement and can use the verification for the August AR.

Had you been given the pension statement prior to April 3, 2017, the received date would be more than 120 days from the August 1 AR date, and the pension statement could not be used; a new verification would have to be obtained.

Here’s the key: Date stamp your third party verifications so the date received is clearly noted. If the tenant verification documents are not date stamped and they do not meet both 120-day requirements, you may be subject to a finding when HUD or your Contract Administrator does your Management and Occupancy Review (MOR).