EIV Compliance Under HOTMA

Master the latest HUD requirements, streamline your EIV documentation, and prepare your team for MOR success with HOTMA-driven policy improvements

HUD properties often face MOR findings, audit failures, or compliance risks due to poorly written or outdated EIV Policies and Procedures—especially with the evolving requirements from HOTMA (Housing Opportunity Through Modernization Act). Staff are often unsure of report frequencies, data retention, or how to handle discrepancies without triggering findings or violating data security requirements.

This training session provides a deep dive into the regulatory and operational requirements of EIV (Enterprise Income Verification) system use at HUD Multifamily properties, with a specific focus on integrating upcoming HOTMA changes. Participants will explore the full scope of required policies and procedures (P&Ps) for using EIV—ranging from access and security protocols to appropriate data use, retention, and destruction. The session clarifies the distinctions between master and tenant file reports and teaches attendees how to document and manage discrepancies effectively.

Emphasis is placed on compliance pitfalls—particularly those that trigger findings during Management and Occupancy Reviews (MORs)—and how to write procedures that both meet HUD expectations and reduce audit risk. Participants will be guided through the timing and proper use of tenant and master reports, including how frequencies are shifting under HOTMA.

The session offers practical guidance for how to align EIV P&Ps with other critical documents, such as the Tenant Selection Plan, MOR readiness checklists, and cyber security certification requirements. The webinar is designed to demystify key areas where EIV compliance overlaps with broader HUD regulations and to empower site and compliance staff to build or update their policies confidently.

Webinar Objectives

Clear guidance on what must be included in compliant EIV policies
Explanation of HOTMA-driven changes to EIV use and timing
Instructions on report storage, data destruction, and security safeguards
Tips to avoid common MOR findings
Integration of EIV with Tenant Selection Plans and interim re-examination policies

Webinar Agenda

Foundational EIV Policy Elements
- Essential components of EIV Policies and Procedures
- Updating outdated or vague documentation to meet HUD standards
- Adapting policies in anticipation of HOTMA changes
Structuring Effective EIV Documentation
- Clear guidance on:
  - Report usage
  - Consent forms
  - Security protocols
- Alignment with other property documents (e.g., Tenant Selection Plan)
Clarifying EIV Report Usage
- When and how to run EIV reports
- Frequency under current rules vs. HOTMA
- Proper filing: master vs. tenant files
- Resolving common MOR (Management and Occupancy Review) issues
Risk Mitigation & Security Protocols
- Addressing data security and discrepancy resolution
- Avoiding pitfalls: mishandled reports, unauthorized access, and poor documentation
- Step-by-step safeguards: technical, administrative, and physical
MOR Preparation and Follow-Up
- Understanding MOR reviewer expectations
- Preparing EIV user forms and cyber training records
- Resolving EIV-related findings post-review
Key Takeaway
- Walk away with a clear, compliant, and up-to-date blueprint for managing EIV under HUD’s evolving requirements

Webinar Highlights

Identify the mandatory elements that must be included in EIV Policies and Procedures under HUD regulations and HOTMA.
Compare current and HOTMA-modified EIV reporting frequencies and documentation requirements.
Implement security measures—technical, administrative, and physical—to protect EIV data and ensure compliance.
Document appropriate storage, retention, and destruction procedures for EIV reports across master and tenant files.
Avoid common MOR findings by aligning EIV use with HUD Handbooks, TSP requirements, and audit expectations.