Comment Submitted by Erik Whitton, Spectrum Enterprises, Inc.

I am concerned about the HUD revisions to rely heavily on the EIV system. This may be a good idea for the various HUD programs but other housing programs 'borrow' the HUD income definitions without providing EIV access. The LIHTC program is one example. Owners and managers of LIHTC properties will not be able to use EIV to document household income. Also, with regard the the definition of income being changed - this will impact tens of thousands of LIHTC properties across the nation. I believe income should still be defined as anticipated income for the 12 month period following move in /certification. By changing this to reflect current or past income I believe you would provide housing assistance to households who do not require it for the duration of their occupancy. Also, managers & owners will have a very tough time implementing the new definition since you are asking them to use more discretion (past/current/ or projected income). All of the state allocating agencies will need to updated their compliance manuals; they will need to retrain their staff and offer trainings to all managers/owners in their states; and the IRS will need to update its materials such as the 8823 audit guide. In conclusions, while the proposed rule may work for HUD programs I believe other housing programs which rely on HUD income definitions will suffer.