EIV Income Discrepancies: Thresholds, Deadlines and the Verification Hierarchy
EIV is HUD's Enterprise Income Verification system. Its use is mandatory at every annual reexamination: the PHA compares what EIV reports against what the family declared, resolves anything that does not match, and documents how it resolved it. A discrepancy is not itself a finding — failing to chase it is.
The numbers that decide a file
Substantial discrepancy
$2,400
annual gap between EIV and declared
Resolution window
60 days
from identifying the discrepancy
Document currency
120 days
age limit for third-party documents
Repayment affordability
40%
cap as a share of monthly adjusted income
Mandated use: 24 CFR 5.233. The comparison requirement at reexamination: 24 CFR 5.236(b)(3). Administrative guidance: Notice PIH 2018-18.
The verification hierarchy, strongest first
24 CFR 5.236 ranks the evidence. Using a lower level when a higher one was obtainable is the finding a file review writes up — not the discrepancy itself.
- 01EIV report / up-front income verification — HUD's EIV system as the third-party source (highest level).
- 02Up-front written third-party verification — an original or authentic source document the tenant provides (e.g. recent pay stubs, benefit letter), dated within 120 days of receipt.
- 03Written third-party verification form — verification requested directly from, and returned by, the income source.
- 04Oral third-party verification — verify with the source by phone or in person; document the date, person contacted, and information confirmed.
- 05Tenant declaration / self-certification — a signed statement from the family, used only as a last resort when no higher level is obtainable.
The period of income
EIV reports on a lag, so the window it covers is not the window you are certifying. The period runs from 15 months before the effective date to 3 months before it — see HUD Handbook 4350.3 REV-1, Exhibit 9-7. Reading a report as though it covered the certification period is how a clean family file acquires a discrepancy that was never there.
Common questions
- Is using EIV optional?
- No. 24 CFR 5.233 makes EIV use mandatory for PHAs administering the covered programmes, and 24 CFR 5.236(b)(3) requires the PHA to compare EIV data against the family's declared income at reexamination.
- What counts as a substantial discrepancy?
- A gap between EIV-reported and family-declared annual income above the threshold shown on this page. Above it the file needs a documented resolution rather than a note; below it the PHA still reviews, but the evidentiary bar is different.
- How long do we have to resolve a discrepancy?
- The resolution window shown on this page runs from when the discrepancy is identified. Notice PIH 2018-18 is the administrative guidance; the underlying comparison requirement is in 24 CFR 5.236.
- What is the verification hierarchy?
- A ranked order of evidence, strongest first, with tenant self-certification last and only where nothing higher can be obtained. This page lists all five levels as the engine applies them. Using a lower level when a higher one was available is the common file-review finding.
- What is the period of income?
- EIV reports wage and benefit data on a lag, so the window it covers is not the window you are certifying. This page shows the months before the effective date that the period spans, per HUD Handbook 4350.3 REV-1, Exhibit 9-7.
- How is a repayment agreement sized?
- Affordability is capped as a share of the family's monthly adjusted income — the percentage this tool applies is shown on this page. A repayment agreement that ignores affordability is one the family defaults on, which converts a recovered overpayment into a termination.
What this page is
A reference, not legal advice. Every figure above is read from the same module the Honestkey™ agency tools compute with, and each names the rule it comes from so your staff can check it. Honestkey™ prepares and documents determinations — it does not submit to PIC or TRACS and it is not a substitute for HUD systems or your own counsel.