Household Stimulus Payments, Other Income, and Unemployment Compensation

Household Stimulus Payments, Other Income, and Unemployment Compensation

Q5: Are household payments under the CARES Act reportable as tenant income?

A: The Economic Impact Payment (which is technically an advance payment of a tax credit that may be claimed on a 2020 tax return) provided by the CARES Act is not to be included in calculations of tenant income. (Updated on 7/31/20)

Q6: The CARES Act identifies different types of unemployment compensation. Can HUD clarify which payments are to be included in tenant income calculations for HUD assisted Multifamily housing?

A: The CARES Act contains the following three types of unemployment compensation: • Section 2102: Pandemic Unemployment Assistance (PUA). This is an unemployment benefit for individuals who are self-employed, seeking part-time employment, or whom otherwise would not qualify for regular unemployment insurance (UI). HUD has determined that PUA benefits must be included as annual income. In instances where the tenant was required to repay PUA because s/he was not entitled to the payment, and evidence of the repayment can be provided by the tenant, then the amounts of PUA repaid must not be counted as income. • Section 2104: Federal Pandemic Unemployment Compensation (FPUC) program. This program provides eligible individuals who are collecting certain UI benefits, including regular unemployment compensation to receive an additional $600 in federal benefits per week for weeks of unemployment ending on or before July 31, 2020. FPUC was reauthorized by the 2021 Appropriations for a reduced amount and then extended by the American Rescue Plan (ARP). FPUC benefits are now available under the 2021 Appropriations at $300/week through the week ending on or before September 26, 2021. HUD has determined that FPUC benefits meet the definition of temporary income and must NOT be included in annual income.

• Section 2107: Pandemic Emergency Unemployment Compensation (PEUC) program.

This program provides an extension to regular unemployment insurance benefits for eligible individuals. This program was extended to reflect the actual number of weeks of unemployment ending on or before September 6, 2021. HUD has determined that

PEUC benefits must be included in annual income.

HUD also notes that regular payments of unemployment insurance (issued by the state) are treated as annual income according to existing HUD regulations. (Updated on 7/29/21)

Q7: The American Rescue Plan of 2021 (ARP) provides a monthly payment from the enhanced child tax credit that will begin being distributed to families in July 2021. Can HUD clarify