Submitted by: Serenity Lay
The days of brick-and-mortar banking may be in the past. More and more applicants are choosing to use digital banking options such as an app over a visit to a physical bank, but did you know that many applicants don’t consider these an asset when asked?!
A sticky situation for affordable housing professionals indeed! We must be diligent in our processes to ensure we capture income from all sources, knowledge is power so let’s check in on those electronic asset sources…
Smartphone app-based asset sources and accounts are super-easy to open and are rife with the information needed for our tenant certs. Apps such as Venmo, PayPal, CashApp, Chime, GreenDot, E-Trade, etc. can be downloaded in seconds, hold applicant funds, AND allow for ‘person-to-person’ or ‘P2P’ fund transfers. This means we’re looking at assets with the potential for other unreported income to be discovered!
What to look for:
Digital assets are still assets so they must be disclosed (and TOTAL ASSETS MUST BE 3RD-PARTY VERIFIED if THE total CASH VALUE OF assets is over $5000 or if required by your state agency). Keep an eye out for known digital asset apps referenced on the application, income/asset checklists, ON bank statements, or other documents in the file. You’ll need to put that detective cap back on AND ask your applicant to give additional information and update docs to include these assets accordingly. Contributions from outside sources will look like fund transfers (ETF?) coming into the applicant’s account…if you see this, be sure to verify the source and purpose of these deposits so you can calculate and include newly discovered income on your TIC/HEC.
Need to verify?
If you need to third-party verify the asset, there’s no ‘address’ to send an asset verification to, so you’ll need to resort to other approved methods. Most of these apps provide a ‘dashboard’ with account summary data in one place which is great! You can use this dashboard to obtain the value of the account then do a quick search to see if they pay any interest or dividends on the accounts.
Knowledge is power As technology changes the industry, we need to stay abreast of the new assets and income sources so we can better handle them going forward.
Common electronic fund apps are Venmo, CashApp, PayPal, Chime. Zelle can also be considered as an asset depending on if their Zelle account is connected to their bank account or not.
Common electronic trading apps are E-Trade, RobinHood, Acorn, Twine, and Stash and allow accounts owners to trade stocks and cryptocurrency such as bitcoin.
Did you know funds can be held with credit card companies? Creditors such as American Express and Discover have been offering high-yield savings account options too!
Don’t forget about debit card assets! Payroll, tax refunds (ARE THESE INCOME?), child support, and social security are often paid only on debit cards which also need to be disclosed and included in the file.
Keeping up to date on digital assets as they pop up will be important. Good due diligence practices will help catch unreported income and prevent non-compliance down the road.
Do you have a digital asset tip to share? Let us know!