Affordable Housing Compliance Update: TRACS 202D

Editor’s note: Jed Graef, Bostonpost Product Manager, provides the latest information on the upcoming TRACS 202D affordable housing industry specification update. For more on the pending TRACS 202D changes, read Jed’s previous post.

An update to the TRACS 202D Industry Specification was released to software developers on February 15. There is one substantive change along with new clarifications.

The new requirement is that if a DUNS number is reported for a subsidy contract (currently mandatory in 202D for Section 8, Rent Supplement, RAP and 202 and 811 PRACS) then the Taxpayer Identification Number (TIN) for the entity whose DUNS number is reported must also be transmitted.  There are two DUNS number fields—one for the owner of the project and one for the parent company of the owner if applicable. There are also two new TIN fields that are paired with the DUNS fields.  If you only have an owner with no parent company, you would report a DUNS number and a TIN.  If you also have a parent company you would report two DUNS numbers and two TINs.

The clarifications are in two areas:

First, a few months ago a new Termination Code (TM 15) was added to identify the case where a certification is not complete after 15 months from the prior annual recert as a result of legitimate extenuating circumstances or owner/agent or third party delay.  The rule is that subsidy billing must stop at that point and any subsidy received after the recert due date must be refunded to HUD.  The TM 15 code is unique in that it stops subsidy but does not raise the tenant to contract or market rent.  The tenant continues to pay the regular assisted rent.  The logic is that the tenant is not at fault for the delay and should not be penalized with higher rent until the cert is finished. The question had come up as to what should be done in the case where the certification is finally complete and the tenant fails to sign the form to finish the process.  HUD policy has ruled that the original TM 15 termination should be corrected to become a full termination raising the tenant to contract or market rent as applicable.

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Second, clarifications to the rules pertaining to Repayment Agreements have been added. One is that different instances of tenant misreporting of income need to be tracked on separate subsidy repayment agreements.  The amounts owed should not be combined in one agreement.  So, if a tenant is found to have misreported income in 2012 and an agreement created because the tenant cannot repay in full immediately and the tenant also misreports in 2013, the 2013 misreporting would be subject to a second repayment agreement.  Payments are to be recorded and reported separately for each agreement. There is also guidance on how to transition from the current reporting of repayment agreement transactions through the use of Miscellaneous Accounting Requests of type OARQ to the use of the new Repayment Agreement records.  In 202D the old OARQ reporting method is not permitted.  The first time a payment is reported for a preexisting agreement, an Agreement ID must be assigned that is unique within the project/community and the original agreement date and amount must be transmitted.  These bits of information will be part of all subsequent transactions for an agreement.  The ending balance after the payment is also part of the submission.

A TRACS Industry Meeting is scheduled at HUD headquarters for March 27-28.  During that time the 202D specification will be reviewed along with testing plans and release dates.  At this moment, the 202D go-live date is still September 1 with an end of transition date of February 28, 2014.

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