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Several housing finance agencies have announced suspensions to physical property inspections of occupied units, in consideration of the COVID-19 public health emergency. Visit www.novoco.com/coronavirus for updates.
A private letter ruling from the Colorado Department of Revenue concluded that the state law for partnerships formed for investment in federal and state low-income housing tax credit (LIHTC) developments follows the federal law.
The Kentucky Housing Corporation announced in an email Dec. 19, 2019, that it released the income averaging compliance policy. The federal Consolidated Appropriations Act of 2018 established income averaging as a permanent third set-aside election for new low-income housing tax credit developments.
The Georgia Department of Community Affairs (DCA) sent a notice Dec. 13, 2019, regarding utility allowances and other services for rental housing tenants.
The National Council of State Housing Agencies (NCSHA) released updated model forms Oct. 4 for low-income housing tax credit (LIHTC) compliance monitoring.
The National Council of State Housing Agencies released April 6 its list of frequently asked questions on housing credit income averaging. Questions include what is income averaging, must a state allow income averaging for developments applying for credits (or seeking bond-financed credits) in 2018 and subsequent years, must a state modify its qualified allocation plan or related regulatory document(s) before allowing income averaging, must the Internal Revenue Service (IRS) issue guidance before states can allow income averaging, must IRS revise Form 8609 before states can allow income averaging and how does income averaging apply to tax-exempt bond-financed 4 percent credit deals? The FAQs are available at www.ncsha.org.
The Ohio Housing Finance Agency (OHFA) issued a program compliance update Dec. 1, 2017, reminding low-income housing tax credit (LIHTC) property owners that 2017 Annual Owner Certifications and tenant data are due March 1. LIHTC extended-use properties have completed 15 years of the compliance period and are required to submit tenant data on all rental activity for the reporting year. If any new properties or lease-up phases are qualified during the 2017 reporting period, the owner is required to submit the tenant data and annual certification. If the property was sold during the reporting period, the owner of record at the end of the reporting period is responsible for annual reporting. Owners are required to submit the 2017 certifications and tenant data via OHFA’s online reporting system, DevCo Online.
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Novogradac Expands Multifamily Compliance Expertise
New Hampshire Housing (NHH) issued a memo March 24 to owners and management agents with Section 8, Section 202 or Section 811 properties to obtain a Dun and Bradstreet Numbering System (DUNS) number and to register with sam.gov, as well as to renew the sam.gov registration annually. NHH stated that having an active DUNS number and being currently registered is critical for Section 8 contracts to be paid housing assistance payments (HAP) and for the U.S. Department of Housing and Urban Development’s (HUD’s) Fort Worth Accounting Office to renew expiring contracts. NHH addressed on March 20 the transmission of confidential information and management review response documentation. NHH stated that owners and management agents have a moral and legal obligation to protect this information. As a reminder, NHH asked for cooperation with its information security program to ensure that the personally identifiable information of residents is not inadvertently disclosed to the wrong parties. This includes personal home address, Social Security number and medical information, among other items.
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