Words Count

The Thomas Howell Ferguson Blog

CARES Act II – Emergency Rental Assistance Program Q&A

Recently, Municode hosted a webinar on the CARES Act II – Emergency Rental Assistance Program. THF’s Steve Stevens and Government Services Group (GSG)’s Dave Jahosky had the opportunity to be panelists on this virtual discussion.

There were great questions about the new CARES Act funding being provided by the IRS Treasury during the session. Continue reading for a recap of the Q&A session from our webinar.

Frequently Asked Questions

FAQ #1 states that utilities and home energy costs must be separately stated charges. What are the “separately-stated charges”?

That is to say, within the invoice, the individual utilities must be separately stated. This includes electric, water, gas, sewer, etc.

We have used our CDBG funds to provide emergency housing payments for a maximum of three months. Can households that have received funding through our program be assisted through this new program? Assuming they are still experiencing hardship?

Yes, they can receive funding through the program. Although they can receive both funds, there cannot be a duplication of benefits. In short, a person cannot receive funding from two or more different sources for the same expense.

Required Documentation

FAQ #6 states that applicants must document that they have either qualified for unemployment or experienced financial hardship. What source of documentation will be required to document financial hardship?

There are several types of documentation that are acceptable. For example, prior-year tax returns, current pay stubs, previous month pay stubs, showing a reduction in work hours, etcetera will be sufficient.

Documented letters that show eligibility for unemployment are also acceptable.

Based on how the law reads, most all requirements may use self-certification or self-attestation. When is self-certification or self-attestation not allowed?

There must be other documentation that substantiates the loss. The local governments are to gather that documentation as evidence documenting that loss. Essentially, self-certification or self-attestation is always allowed. However, you always need other documentation to supplement the self-certification or self-attestation.

How do we know who all is giving assistance in our area?

Local governments should be communicating this to other local governments within the same county. Additionally, they should communicate with non-profits that handle rental assistance funds. They should continue to keep in contact, update each other on the process, and keep documentation to help prevent duplication of benefits.

Emergency Rental Assistance

You mentioned DUNS numbers for landlords.  Are landlords required to have a DUNS number?

No. The information that needs to be provided could include a DUNS number, Tax ID number, FEIN number, Social Security Number, etc.

Is it sufficient for a household to self-certify that they are not receiving a duplication of benefits?

The application process should include information needed to certify that the household is not receiving a duplication of benefits. However, the process should not be the only test for duplication of benefits.

The other entities within the local government should be communicating with each other so that duplication of benefits does not occur. To sum up, duplication of benefits is funding that comes from two or three different sources but is used for the same expense.

Landlord Requirements

Prior to making rent payments, will the DUNS number be required for all landlords? That will exclude many private landlords.

In short, no. To clarify, if a landlord does not have a DUNS number, a FEIN number or a social security number would be sufficient information.

In a situation where the employer will not provide proof and they state they have no paystubs, can we request bank statements? How do we prove hardship?

To prove hardship, there are many forms of documentation that can be used. For example, this includes W-2s, 1099s, bank statements, and prior-year tax returns.

Is relocation assistance eligible?


Are you referring to the frequently asked questions from the January 19, 2021 release from the Treasury?


For additional information on the CARES Act – Emergency Rental Assistance Program, click here. Always consult a government consultant with any questions. Contact Steve Stevens here or Dave Jahosky here.

Related Blog Posts