To Count or Not to Count: Unemployment, Child Tax Credit, and Emergency Rental Assistance Updates
- Jun 22, 2021
7 Simple Steps to Get your LIHTC Paperwork Under Control
- Jun 03, 2021
PART 4: WHAT TO DO IF YOU’VE BEEN DUPED BY FAKE PAY STUBS
- May 15, 2020
PART 3: PREVENTING FAKE PAY STUBS
- Mar 07, 2020
PART 2: DETECTING FAKE PAY STUBS
- Oct 24, 2019
PART 3: PREVENTING FAKE PAY STUBS
In previous articles, we discussed fake pay stubs being presented by applicants and how to detect them. Here we will discuss how to be proactive so you are not duped with fake pay stubs. Let's dive in and see how we can prevent fake pay stubs.
The most pervasive pay stub fraud we’ve detected to date wasn’t an individual.
During a recent multi-site affordable housing file audit we uncovered a systemic issue with pay stubs. At first glance the stubs didn’t raise any eyebrows, the format of the stubs was just unique. However, we noticed the same, unique format for several different employers in several different files. They were small employers that were part of the same industry. Ends up, the same “accountant” had produced fake stubs for them. It was not clear if the employer or employees initiated this. Nonetheless, these communities had to deal with multiple resident files with falsified income documents. It was a lengthy, expensive process to address.
As affordable housing providers, we need to ensure income documents are legit, so here are some steps you can take to prevent fake pay stubs:
Do routine file audits.
We all know we should do routine property file audits. As you are reviewing files, make a mental note of the pay stub formats from one file to the next. Our team has already added this to our on-site audit file review checklist.
- Notable pay stub format from one applicant/resident to the next?
- Notable pay stub format from one file to the next?
- Notable pay stub format from one certification to the next?
- Are pay stubs from a common employer different or the same?
Use a checklist. We do.
We recommend you look for, identify, and address fake stubs as you are processing your file for approval. Here are some checklist items that could help:
- Inspect the stubs – here is a previous article on Detecting Fake Pay Stubs
- Get to know stub formats for employers in your area. This makes it easier to identify fake stubs when you are familiar with the real ones.
- Look for patterns:
- Compare stub to stub within a certification
- Compare stubs from one certification to the next (move in certification to recertification, for example)
- Same employer, different stubs?
- Different employer, same stubs?
- Compare stubs from employers in one application or file to the next
- Request URL or online pay stub download documentation from the applicant/resident.
- Call the employer to verify.
When in doubt, pull your compliance support department in as a partner for a second look. Do a little research online. If things are not adding up, you may want to request additional information. No matter what, be consistent holding all applicants to the same criteria.
Stay tuned for our next article where we will take an in depth look at what to do if you discover you’ve already fallen victim.
Have you encountered fake pay stubs? Can you share how you handled it?
Did you know that we are approved distributors of the HCCP exam?
Read our entire series on "Fake Pay Stubs"
- Part 1: Fake Pay Stubs Are Mucking Up Income Verifications
- Part 2: Detecting Fake Pay Stubs
- Part 4: What To Do If You've Been Duped By Fake Pay Stubs
keep on complying with quality -kg