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Property Compliance News Briefs – April 2019

The California Tax Credit Allocation Committee posted a resyndication questionnaire and memorandum Feb. 8 for developments requesting a new reservation of low-income housing tax credits (LIHTCs). The questionnaire must be submitted for those who have existing LIHTC properties and are applying for a new allocation. The memo is available at 


The Ohio Housing Finance Agency (OHFA) issued a memo Feb. 14 on several additions for the agency. OHFA will expand its focus on training and technical assistance with the new multifamily training and compliance technical assistance office. A new associated webpage provides information and resources related to new or improved services for the industry. The first in-person OHFA policy and procedure training was March 12 in Columbus, followed by one scheduled April 16 near Cleveland. In addition, the DevCo videos page has new recorded webinars on the annual owner certification process.


IRS final utility allowance regulations for LIHTC properties were published and effective March 4. The final regulations make permanent the temporary rules under which charges for utilities are treated as paid to the utility company in situations where tenants pay the building owner for utilities based on actual consumption and the building owner pays the utility company. The final regulations extend those principles to renewable energy sources that are not purchased from a utility company. The regulations affect owners, tenants and housing agencies that administer the LIHTC. 


OHFA released a memo March 4 providing more detail on the 2019 OHFA policy, procedure and regulation training. The three-hour training will provide industry professionals with tools and knowledge of OHFA specific requirements, policies, best practices and an overview of the LIHTC program. Participants will learn OHFA multifamily basics, credit delivery and compliance consequences, verifications, forms and tenant files and VAWA regulations. The training will fulfill OHFA’s qualified allocation plan training requirement in order to obtain IRS Form 8609. Training dates are March 12 through Sept. 10.


The Internal Revenue Service (IRS) published Feb. 26 final regulations in the Federal Register to amend compliance monitoring regulations for LIHTC properties concerning physical inspections and the review of documentation. The regulations adopt temporary regulations published Feb. 25, 2016. The final regulations provide that the minimum number of units that must undergo physical inspection is the of low-income units listed in the reference chart in Rev. Proc. 2016-15. The state housing agency can choose different units for physical inspection and for low-income certification review, as long as both meet the minimum. The requirement that all buildings in a low-income property be inspected is amended to include that if the randomly selected minimum number of low-income units doesn’t include every building, some aspect of each omitted building must be inspected. Inspections must begin by the end of the second calendar year following the year the property is placed in service and continue at least every three years thereafter. The document is available at

Journal Category:

Property Compliance



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