4-1 SUBMISSION ANNUAL ADMIN PLAN_EXHIBIT 3

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6-I.C.ANTICIPATING ANNUAL INCOME The PHA family during the 12- \[24 CFR 5.609(a)(2)\]. Policies related to anticipating annual income are provided below. Basis of Annual Income Projection The PHA generally will use current circumstances to determine anticipated income for the coming 12-month period. HUD authorizes the PHA to use other than current circumstances to anticipate income when: An imminent change in circumstances is expected \[HCV GB, p. 5-17\] It is not feasible to anticipate a level of income over a 12-month period (e.g., seasonal or cyclic income) \[24 CFR 5.609(d)\] The PHA believes that past income is the best available indicator of expected future income \[24 CFR 5.609(d)\] Income Verification (EIV) system in its entirety as a third party source to verify employment and income information, and to reduce administrative subsidy payments errors in accordance with HUD administrative guidance \[24 CFR 5.233(a)(2)\]. HUD allows PHAs to use pay-stubs to project income once EIV data has been received in such cases where the family does not dispute the EIV employer data and where the PHA does not determine it is necessary to obtain additional third-party data. SAHA Policy When EIV is obtained and the family does not dispute the EIV employer data, SAHA will use current tenant-provided documents to project annual income. When the tenant- provided documents are pay stubs, SAHA will make every effort to obtain current and consecutive pay stubs dated within the last 90 days. SAHA will obtain written and/or oral third-party verification in accordance with the verification requirements and policy in Chapter 7 in the following cases: If EIV or other UIV data is not available, If the family disputes the accuracy of the EIV employer data, and/or If the PHA determines additional information is need. In such cases, SAHA will review and analyze current data to anticipate annual income. In all cases, the family file will be documented with a clear record of the reason for the decision, and a clear audit trail will be left as to how the PHA annualized projected income. When SAHA cannot readily anticipate income based upon current circumstances (e.g., in the case of seasonal employment, unstable working hours, or suspected fraud), SAHA Page 6-5 04/01/14