Property Compliance News Briefs - July 2017
Mississippi Home Corporation’s (MHC’s) additions to the compliance monitoring plan for 2017 were effective May 1. Changes were made to the general policies and procedures section; Chapter 3: State Compliance Requirements; Chapter 4: Determining and Documenting Household Eligibility; Chapter 5, Income and Asset Determination and Responsibilities; and Chapter 7, Compliance Reporting and Administrative Responsibilities. In addition, one form was introduced, the Office of Rent Administration Lease Addendum, and two were revised, the Certification of Tip Income and the Employment Verification form. The additions were announced April 11-13 at its Annual Affordable Housing Conference in Biloxi, Miss.
The California Tax Credit Allocation Committee (CTCAC) updated May 19 its online compliance reference manual. Language was added in Part 5.5, Section I on the pay-stub requirements for tenants returning from medical, maternity/paternity or disability leave. CTCAC stated that if an applicant is returning from a medical, maternity/paternity or disability leave into the same job they were doing before the leave and the Verification of Employment (VOE) clearly indicates that they were continuously employed during their leave period, CTCAC will accept a lesser amount of paystubs or a W-2 for the applicant as long as the paystub income provided reflects the wage amounts noted on the VOE. In addition, CTCAC released a memo May 17 announcing that it has broken the backlog on processing placed-in-service packages. CTCAC is caught up on starting and completing initial reviews. Both the manual and the memo are available at www.taxcredithousing.com.
The Ohio Housing Finance Agency (OHFA) announced a revision to its Affirmative Fair Housing Marketing Plan Policy will be effective July 3. The policy on the submission of Affirmative Fair Housing Market Plans (AFHMPs) was updated to align with U.S. Department of Housing and Urban Development (HUD) guidance. HUD provided clarification that existing AFHMPs must be reviewed by the owner when at least five years have elapsed since the last review, the local jurisdictions’ consolidated plan is updated or significant demographic changes have occurred in the housing market area. If the owner’s analysis finds that a property’s plan is satisfactory, the OHFA AFHMP Review Verification (PC-46) form should be completed and attached to the existing AFHMP. If the owner’s analysis determines that the current AFHMP requires modifications or updates, the owner must submit the updated AFHMP for approval. In addition to the change in submission requirements, a full policy is now published and changes were made to the PC-E45 form. Changes to the PC-E45 form include the addition of questions in the “Training of Staff” section specific to tenant selection and changes to the housing marketing area to being selected based on what is best suited to the project.