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Income Limits Working Group

Who We Are

The Income Limits Working Group was founded by Novogradac in 2021 to examine the effects of a surprise announcement by the U.S. Census Bureau that it would not publish 1-year American Community Survey (ACS) data for 2020. The 2020 ACS data, if available, would have been used to calculate 2023 median incomes, which in turn would have been used to determine 2023 income and rent limits for low-income housing tax credit- (LIHTC-) and private activity bond- (PAB-) financed residential rental properties. The Novogradac working group is analyzing the effects of this announcement on LIHTC- and PAB-financed properties and assessing the short- and longer-term effects of the Census announcement. Most importantly, the Income Limits Working Group will develop possible policy options for U.S. Department of Housing and Urban Development (HUD) and Congress to consider.

The Income Limits Working Group’s members primarily include investors, syndicators, lenders, for-profit and nonprofit developers, consultants, property owners, managers and underwriters who work together to suggest consensus solutions to technical issues involving HUD income limit policies.

What We Do

Established to provide a platform for affordable housing industry participants who to be proactive in seeking policy solutions, the Income Limit Working Group encourages and facilitates the collaboration of industry stakeholders in their efforts to understand the possible effects of the Census Bureau’s and HUD’s decisions and provide recommendations to resolve technical and administrative issues. Each month, members of the group participate in a conference call to discuss issues, answers to frequently asked questions, and recommended practices for addressing the lack of ACS data for 2020, and–based on those discussions–provide comments and suggestions that are submitted in writing to the Census Bureau, HUD and other federal and state agencies.

Benefits of Membership

Membership in the Income Limits Working Group provides:

  • Access to a platform where members can collaborate on resolving similar issues to better understand how they can respond to HUD and Census Bureau decisions.
  • Access to Novogradac economic analysis of key issues around the calculation of income limits.
  • The ability to keep abreast of emerging issues and provide input for shaping proposed recommendations.
  • The ability to cost share in resolving similar issues more efficiently as a group rather than having to address them individually.
  • The chance to participate directly but have ideas and suggestions included anonymously in letters submitted to governmental agencies, including the Census Bureau and HUD.
  • Access to conceptual models and analysis to assist in the understanding of the effects of the Census Bureau’s decisions.

Priority Issues

The Income Limits Working Group’s priority issues include:

  • Analyzing the effects on 2023 income limits on LIHTC properties, most particularly the qualifying income levels and rent levels.
  • Proposing alternatives approaches to using the five-year data to calculate median income for HUD.


For information regarding the group and how to become a member, complete this form or contact Thomas Stagg at (425) 519-1234 or [email protected].  Membership fees cover the time incurred by Novogradac professionals to research, collaborate and prepare written and verbal communications to the respective agencies. Each month, Novogradac updates the group on the status of each issue and the necessary actions to address them.  

Public Input

The Income Limits Working Group does consider input from non-members when drafting of comment letters, recommended practices and other content. To submit input on an income limit topic, contact Thomas Stagg at (425) 519-1234 or [email protected].

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