Compliance Update | May 2020

Are tenants responsible for paying rent during the COVID-19 emergency? How long does the moratorium on eviction last? Are property managers responsible for maintenance and repairs during the pandemic? HUD's new resource for residents of multifamily properties, Addressing Tenant Concerns during the COVID-19 Emergency , provides these answers and more. This online brochure shares the steps residents should take if they experience a loss of income during the COVID-19 national emergency, provides local contact information, and explains the eviction moratorium in the CARES Act. Please distribute this resource widely. We suggest sending the brochure directly to residents via email, and posting it in public areas of apartment buildings (lobby, laundry, and meeting rooms for example).
Fair Housing Month Training
On April 16 th , in a salute to Fair Housing month, Scott P. Moore, attorney-at-law with Baird Holm, LLP and trainer for E&A Team, provided a live one-hour webinar on Fair Housing and the issues that face affordable properties. If you were unable to attend the live session or would like to access the webinar again, view the presentation online.



CARES Act Eviction Moratorium
Several provisions of the Coronavirus Aid, Relief, and. Economic Security (CARES) Act apply to the administration of affordable housing. The act imposes a 120-day moratorium on tenant eviction filings and charging late fees for almost all of the nation’s affordable housing properties.

Section 4024 of the act applies to properties that either 1) have a federally backed mortgage loan or 2) participate in a covered housing program as defined in the Violence Against Women Act (VAWA). 

Under VAWA, covered programs include:

  • the low-income housing tax credit (LIHTC),
  • public housing,
  • Section 8 Housing Choice Voucher program,
  • project-based Section 8 housing,
  • Section 202 supportive housing for the elderly,
  • Section 811 supportive housing for persons with disabilities,
  • Section 236 multifamily rental housing,
  • Section 221(d)(3) Below Market Interest Rate housing,
  • HOME Investment Partnerships
  • Housing Opportunities for Persons with AIDS,
  • McKinney-Vento Act programs, and
  • USDA Rural Development.
HUD Stimulus and Unemployment Enhancement Payments
Household stimulus payments of up to $1,200 (which are technically an advance tax credit) and the temporary $600 per week federal enhancement to unemployment insurance provided by the CARES Act are not to be included in calculations of income. However, HUD notes that regular payments of unemployment insurance (issued by the state) are treated as income, as is customary under program rules.
Compliance Cues



  • Most KHRC staff are currently working remotely. If you are having trouble reaching a KHRC staff member, please post your questions in Procorem.