Q&A: EIV Violations

Question: Our owner has just been issued two EIV non-compliance letters for properties that have MOR’s coming up next month. Our CA had requested information in advance of the MOR. We sent her our TRACS ROBs and Security Awareness Training certificates as requested, but there was a clerical error in the advance documents – some had dates that were expired. We have the correct items and will submit them. I am confused as to how we can be out of compliance when the MORs have not even occurred yet. ~ Rita in NH

Answer: Change 4 (4350.3, 9-19 A 1) says that an EIV violation can be identified at times other than during an MOR. The reason for that addition was that HUD Headquarters can now see properties whose contract/project numbers have never been assigned EIV access, and Policy wanted to be able to issue violations to those sites. However, the way it’s written, this section also allows HUD Field Offices and Contract Administrators to issue violations outside of MORs as well. After you submit the corrected documents the violations will be cured – and sending them in advance will avoid MOR findings.