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October TRACS Industry Working Group Meeting

Our TRACS industry meeting began on a sad note:  Willie Spearman, Gail Williamson and Deb Lear have announced their retirement from HUD.    These three individuals have made large contributions to the multifamily housing industry.  They will be sorely missed!

Also discussed at the TRACS industry 202D working group meeting last week was how to address tenants who either skipped on their repayment agreement or did not want to sign their repayment agreement. Lanier Hylton from HUD spoke about HUD’s and OIG’s ongoing concern about recovery of these funds. This concern spurred conversation about tracking tenants who have left their property owing money to HUD as well as perhaps flagging these tenants as ineligible for any government assistance on any kind. What do you all think?

Some of our meeting time was done discussing the DUNS number which is a requirement for TRACS 202D.  The DUNS number is a nine-digit number, issued by D&B, assigned to each business location in the D&B database, having a unique, separate, and distinct operation for the purpose of identifying them. The DUNS number is random, and the digits have no apparent significance.

Unlike national employer identification numbers, a DUNS number may be issued to any business worldwide. Certain U.S. government agencies like HUD now require that a vendor have a DUNS number as well as a U.S. Employer Identification Number (EIN).

A DUNS number is also a way in which separate corporate entities, having no official relationship, can be branded as one by sharing one DUNS number among the affiliated companies.

The U.S. Office of Management and Budget (OMB), a United States federal agency, announced in the June 27, 2003 issue of the Federal Register (68 FR 38402) that a DUNS number would be required for all grant applicants for new or renewal awards submitted on or after October 1, 2003. The DUNS number is a supplement to other identifiers, such as the EIN, and is required whether the application is made electronically or on paper.

That said; HUD now needs to figure out how to best integrate this requirement in to the multifamily housing industry.  It was suggested the DUNS number be included in the HUD form 50059 and to make sure affordable housing properties were entering their DUNS number when they upgraded their software to TRACS 202D.  In addition, I suggested they include the DUNS number in the TRACS header record, and others wanted to make sure it was a field which was available in the vendor software so the DUNS number could be edited if it was entered incorrectly.  Of course if TRACS has no way of validating the field it could be for naught.  It would be useless if there was no way to make sure that it was a viable and true entry.  The DUNS number will be a requirement of the Section 8 Renewal Guide as an element of the contract renewal and logged into eLOCCS and iREMS.  This DUNS number is to be considered as a Mandatory on Condition since it does not apply to Tax Credit and Plan of Action contracts.  It could very well be linked to the Tax ID number…we will see what happens.

There was some clamor about the PBCA contract process being reviewed.  Until it is hammered out by HUD staff, Management Occupancy Reviews (MOR’s) will be suspended for a 6 month period commencing on October 1, 2011.  During this time, funding for these contracts has been reduced.  The only way for these PBCA to continue was to reduce their most costly duties.  Personally I am not sure why they had to announce this break in MOR’s while some properties still struggle in their compliance.

There will be more to come on this TRACS industry meeting we just had so stay tuned and take some of our classes where we can fill you in on those new EIV changes (HUD Notice H11-21), and so much more.

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