Income, assets and expenses must be verified down HUD's six-level HOTMA hierarchy (Notice H 2023-10 Table J2), documenting why third-party verification was unavailable
s8.income.verification_hierarchy_hotma_j2 · v1.0.0
The owner must verify annual income, the value of assets, expenses related to deductions from annual income, and other factors affecting adjusted income by working down HUD's six-level verification hierarchy at Table J2 of Notice H 2023-10/PIH 2023-27, from most to least acceptable: LEVEL 6, upfront income verification through HUD's EIV system, with the EIV Income Report pulled for every family at every annual reexamination unless Safe Harbor documentation is used, and usable as the sole verification of Social Security income; LEVEL 5, upfront income verification through a non-EIV system such as The Work Number or a web-based state benefits system; LEVEL 4, written third-party verification from the source, an original or authentic third-party document dated within 120 days of receipt and commonly held by the tenant (tenant-provided documents such as pay stubs, benefit letters, bank statements or a tax return with its transmittal receipt), or in the alternative EIV plus self-certification where the family agrees the EIV amount is accurate and representative of current income; LEVEL 3, the owner's own written third-party verification form, completed by the third party and sent directly to and from the source by mail, fax or email; LEVEL 2, oral third-party verification by telephone or in-person contact, documented with the date, time, name and telephone number of the person contacted and the information confirmed; and LEVEL 1, self-certification, which is not third-party verification and is a last resort. The owner must demonstrate efforts to obtain third-party verification before accepting a self-certification, and must document in the tenant file the reason third-party verification was not available, unless HUD's regulations expressly permit self-certification of that item (net family assets not exceeding the HOTMA threshold, or zero reported income at admission and reexamination). Levels 3 and 2 are individually skippable: the owner must complete one of the two, not both, before moving to self-certification. Where pay stubs are relied on for Level 4 documentation the owner must obtain a minimum of two current and consecutive stubs, and where assets must be verified a minimum of one statement reflecting the current balance of the account.
- Confidence
- high
- Effective from
- 2024-01-01
- Compliance date
- 2027-01-01
- 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)
- Zero income certification(conditional)
Citations
All sources verified within 1 day- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Attachment J, paragraph J.5 (Verification Hierarchy), Table J2, printed p. 122 (Revision 3, issued 16 April 2026)
- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Attachment J, paragraph J.5, second paragraph, printed p. 120
- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Attachment J, paragraph J.5.a, Non-Third-Party Verification Technique: Self-Certification (Level 1), printed p. 124
- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Attachment J, paragraph J.5.a, Written, Third-Party Verification (Level 4), printed p. 123
- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Attachment J, paragraph J.5.a, Written, Third-Party Verification Form (Level 3) and Oral Third-Party Verification (Level 2), printed pp. 123-124
- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Attachment J, paragraph J.5.a, Level 4 pay stub minimum, printed p. 123
- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Attachment J, paragraph J.5.a, asset statement minimum, printed p. 124
- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Attachment J, paragraph J.8 (Zero Income Procedures), printed p. 126
- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Section 4 (Notice Applicability), printed pp. 6-7
- Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Revision 3Section 6.2 (Compliance Date and Required Actions for MFH Owners), printed pp. 8-9
- Implementation Guidance: HOTMA Sections 102 and 104Notice H 2023-10/PIH 2023-27, Attachment J, paragraph J.5 and Table J2
- Housing Opportunity Through Modernization Act of 2016: Implementation of Sections 102, 103, and 10488 FR 9600 (14 February 2023); the regulations J.5 names are 24 CFR 5.240(c), 5.659(d), 891.105, 891.410(b)-(c) and (g), 891.610(b)-(c) and (g), 960.259(c), 982.201(e) and 982.516(a)(2)