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federalUnited StatesSection 221(d)(3) Below Market Interest Ratecertification

Section 221(d)(3) BMIR verification stays on Handbook 4350.3's four-level hierarchy, because Notice H 2023-10's Section 4 program list does not reach BMIR

bmir.certification.verification_hierarchy_handbook_4350_3 · v1.0.0

For a Section 221(d)(3) BMIR unit the owner must verify all income, assets, expenses, deductions, family characteristics and circumstances that affect family eligibility or level of assistance, using HUD Handbook 4350.3 REV-1 Chg-4's four acceptable methods in the handbook's order of acceptability: first upfront-income verification, with use of HUD's EIV system mandatory as the third-party source for tenant employment and income at annual and interim recertification and use of a non-EIV upfront system such as The Work Number optional; then written third-party verification from the source, which covers both an original or authentic third-party document dated within 120 days of the date the owner received it and held by the tenant, and written documentation sent directly by the source by mail, fax, email or internet; then oral third-party verification, documented in the file; and last family certification, which the owner may accept only if the information cannot be verified by another acceptable method. Where third-party verification is not available the owner must document in the file the efforts made and the reason it was not obtained. Verifications are valid for 120 days from the date of RECEIPT by the owner and expressly not from the effective date of the form HUD-50059; a verification older than that on the effective date must be replaced. Where pay stubs document employment income the owner may not accept them unless the tenant provides the most recent four to six consecutive stubs. This is the pre-HOTMA hierarchy and it is not Table J2: Notice H 2023-10 / PIH 2023-27 supersedes relevant portions of 4350.3 Chapter 5, but its Section 4 lists the eleven programs it applies to and 221(d)(3) BMIR is not one of them, so the notice's six-level hierarchy, its two-pay-stub minimum and its 120-days-from-receipt-of-an-EIV-report mechanics do not reach a BMIR-only unit.

WRITTEN TO CLOSE A GAP THIS CORPUS CREATED. Closing s8.income.verification_hierarchy at 2023-12-31 and scoping its successor to the eleven programs Notice H 2023-10 Section 4 lists left 221(d)(3) BMIR with no verification-hierarchy rule for any date after that. The successor rule recorded the gap in its own open questions rather than papering over it by asserting the notice covered a program it says it does not; this is the rule that answer required. HUD Handbook 4350.3 REV-1 Chg-4 was re-fetched 2026-08-28 and is byte-identical to the hash on src.hud.handbook_4350_3 (8,382,820 bytes, sha256 f58e4281302695a1d252bc3e4f51547806e137738a073cb94fd115920ba00adc, 794 pages), and the record's stated edition was confirmed against the document's own transmittal page rather than its URL. The whole of Chapter 5 Section 3 was read: the string 'BMIR' does not occur anywhere between the Section 3 heading and the Section 4 heading, while Section 2 carries an express BMIR carve-out printed under its heading. That asymmetry, plus Figure 1-1 and para 1-2.D, is the evidence.
Confidence
medium
Effective from
2024-01-01
Consequence model
agency finding with cure
Last reviewed
2026-08-28

Evidence required

  • EIV Income Report(at_least_one)
  • Third-party employment verification(one_per_income_source)
  • Asset verification(one_per_asset)
  • HUD-50059 Owner's Certification of Compliance(at_least_one)

Citations

All sources verified within 1 day
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 1, paragraph 1-2.A, Applicable Programs, printed p. 1-1
    binding_agency_guidanceSource ↗verified 1d ago
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 1, Figure 1-1, Programs Subject to This Handbook, printed p. 1-2 - first entry in the figure
    binding_agency_guidanceSource ↗verified 1d ago
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 1, paragraph 1-2.D, Programs and Properties Not Subject to This Handbook, printed p. 1-2 - BMIR does not appear in this list
    binding_agency_guidanceSource ↗verified 1d ago
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 5, Section 3, paragraph 5-12.A.1, Key Requirements, printed p. 5-52
    binding_agency_guidanceSource ↗verified 1d ago
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 5, Section 3, paragraph 5-13.A, Methods of Verification, printed p. 5-54. The asterisks are the handbook's own change markers for Change 4 text and are reproduced as printed.
    binding_agency_guidanceSource ↗verified 1d ago
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 5, Section 3, paragraph 5-16.B.1-2, Effective Term of Verifications, printed p. 5-60
    binding_agency_guidanceSource ↗verified 1d ago
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 5, Section 3, paragraph 5-13.B.1.b.(1)(b), printed p. 5-55 - the pay stub minimum that HOTMA replaced with two stubs for the programs Notice H 2023-10 reaches
    binding_agency_guidanceSource ↗verified 1d ago
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 5, Section 3, paragraph 5-18.E, Documenting Why Third-Party Verification Is Not Available, printed p. 5-62
    binding_agency_guidanceSource ↗verified 1d ago
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 9, paragraph 9-5.A, Mandatory Use of the EIV System, printed p. 9-2
    binding_agency_guidanceSource ↗verified 1d ago
  • Occupancy Requirements of Subsidized Multifamily Housing Programs
    Chapter 5, Section 2, applicability line printed immediately under the Section 2 heading, printed p. 5-40 - the handbook's express BMIR carve-out, which Section 3 does not have
    binding_agency_guidanceSource ↗verified 1d ago
  • Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3
    Section 4 (Notice Applicability), printed pp. 6-7 - the eleven programs the HOTMA verification hierarchy reaches. 221(d)(3) BMIR is not among them.
    binding_agency_guidanceSource ↗verified 1d ago
  • Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3
    Section 7.1 (Guidebooks and Handbooks), printed p. 10 - the supersession is of 'relevant portions', and operates only within the Section 4 applicability above
    binding_agency_guidanceSource ↗verified 1d ago