Transcript Low Income Housing Tax Credit Program NOP

NEAHMA March Meeting
March 19, 2014
Rhode Island Housing Updates
• WCMS/ HDS Updates
• Pilot program
• Technology
WCMS/HDS Updates
• New Requirements for CAPs
• NEW - Set Owner Income Designation and
Owner Rent Designation on each LIHTC
tenant/unit
• Training to be provided in Spring 2014
HUD's Physical Inspection Alignment Pilot
Program (Pilot Program)
• Partnership with HUD, the IRS and Rural Development
• Meets the criteria of all three agencies
• Satisfies the UPCS inspection requirements for the Low
Income Housing Tax Credit Housing (LIHTC) program
• Sample will be drawn from the entire project
• All agencies involved will utilize the inspection results
• REAC inspection results will determine if further action is
required
Pilot Program
(continued)
What this means for RI Housing:
• Use of technology
• More scrutiny – 8823 ?
Pilot Program
(continued)
What this means for you:
• Reduced administrative and tenant burden
• No more duplicate inspections
• R I Housing may inspect all vacant units
• RI Housing will conduct a “look around”
• Health and Safety (EH& S) items will be noted
• More 8823s
Non-compliance 8823
When noncompliance is identified Rhode Island Housing is
required to notify the Internal Revenue Service using Form
8823, Low-Income Housing Credit Agencies Report of
Noncompliance or Building Disposition.
Findings worthy of an 8823 include (but not limited to):
-
Failed REAC inspection
Physical deficiencies, uncorrected EH&S
Fires
Fair Housing violations
Over income households
Full time students – not meeting an exemption
Students
A “student” is an individual (regardless of age) who
during any five calendar months of a calendar year
(5 calendar months do not need to be consecutive)
is a full-time student at an educational organization.
- Educational organization is described in IR §170(b)(1)(A)(ii)
Students
(continued)
• Full time or part time? Must be stated by the educational
organization and is based on their criteria.
• Educational organization includes elementary, junior and
senior high schools, colleges, universities, on-line
universities, and technical, trade and mechanical schools.
• On-the-job training courses – not applicable
Students
(continued)
Households made up of all full-time students (regardless of age) do not qualify for the LIHTC
program unless they meet one of the exceptions. There are five (5) exceptions to this rule
and they are:
1.
2.
3.
4.
5.
At least one individual is receiving assistance under Title IV of the Social
Security Act (i.e.TANF);
At least one individual is enrolled in a job training program receiving
assistance under the Workforce Investment Act or under other similar
federal, state, or local laws;
Household consisting of a single parent and his/her dependents, where
neither the single parent nor their children are dependents of another
individual (other than a parent of such children);
Household consisting of persons who are married and eligible to file a joint
tax return;
At least one individual was previously under the care of a state foster care
program.
Students
(continued)
• Remember the 5 month rule – any 5 months of a calendar
year (5 months do not need to be consecutive.)
• Ensure your rental application form asks the student
question and include the 5 month rule
• Determine student status at time of application
• Determine student status at time of move-in
Who's Who at Rhode Island Housing
Divisions:
• Loan Servicing
• Development
• Resident Services
Loan Servicing Division
• Leslie McKnight, Director
[email protected]
401-457- 1184
• Michael DiChiaro, Assistant Director
[email protected]
401-457-1274
• Kathleen Millerick, Multifamily Compliance Supervisor
[email protected]
401-457-1241
• Kathleen Stewart, Multifamily Finance Supervisor
[email protected]
•
401-457-1143
Susan Halloran, Multifamily Work Out Specialist & Quality Control Manager
[email protected]
401- 450-1339
• Multifamily Compliance Specialists:
Jamie Wolcott, [email protected]
Dotty Valentini, [email protected]
Glen Turner, [email protected]
Lynne Crowell, [email protected]
401-450- 1343
401-457- 1211
401-457-1154
401-457-1108
Loan Servicing
(continued)
Loan Servicing - Responsible for the servicing of the Corporation’s single
and multi-family loan portfolio.
• Loan servicing staff services a portfolio of more than 12,300 single
family loans totaling more than 1.2 billion dollars.
• Provide customer service and mortgage counseling support to more
than 8,100 Rhode Island homeowners.
• In 2007, Loan Servicing assumed responsibility for the purchase of
municipal tax liens for residential owner-occupied properties. To date,
we have assisted more than 1,800 homeowners facing the possible loss
of their home from tax sale.
Loan Servicing (continued)
• Oversee the physical and financial condition of more than 20,000
affordable rental homes funded under the Low Income Housing Tax
Credit program (LIHTC), The tax-exempt and taxable Bond programs,
the Tax Credit Exchange Program (TCEP), the Tax Credit Assistance
Program (TCAP), and the HUD Risk Share Program.
• Primary responsibilities include compliance with Federal, State,
investor and insurer regulatory requirements.
• Multifamily compliance staff perform compliance reviews on more than
154 LIHTC projects and 12,000 LIHTC files and units.
• Multifamily financial staff services a portfolio of more than 500
multifamily loans totaling more than half a billion dollars.
Development Division
• Carol Ventura, Director
[email protected] 401-457-1129
• Anne Berman, Assistant Director
[email protected] 401-457-1269
• Paula Coleman, Assistant Director
[email protected] 401-457-1134
• Brenda Cianciolo, HOME Program Support Specialist
[email protected] 401-450-1332
• Edison Bedoya, HOME Program Support Specialist
[email protected] 401-457-1102
• Diane Benjamin, NOP, SHP, Thresholds Program Coordinator
[email protected] 401-450-1347
Development
(continued)
Development - Responsible for the construction, rehabilitation and
preservation of affordable rental housing.
• Administers the Rental Housing Production Program, which includes
federal Housing Tax Credits, tax-exempt and taxable bonds and our own
deferred-payment loans. Also the Tax Credit Assistance Program (TCAP)
and the Tax Credit Exchange Program (TCEP).
• Oversees our Preservation Program and a pilot program that used
Medicaid-waivers to create 200 apartments dedicated to assisted living.
• Responsible for administering federal programs including HOME, NOP,
the Lead Hazard Reduction Program, and the Neighborhood
Stabilization Program (NSP), SNRPE, SHP, and Thresholds.
• Monitors the construction or rehabilitation of affordable projects.
Funding Sources
PROGRAM
Road Home
(RI Housing)
INCOME LIMITS
Less than 80% of State
median income
TENANT RENTS
greater of 30% monthly gross or a
minimum rent of $50 (unless the
development has a pre-existing
minimum rent less than $50)
OTHER
Applicant must be homeless, agree to case
management and agree to work on meeting
benchmarks of case management plan.
NOP
(State)
Less than 40% State median
greater of 30% monthly gross or
minimum NOP rent {family limit or
individual limit}
Two categories: FHF - Family Housing
Fund or PSH – Permanent Supportive
Housing
Rental Production
(LIHTC)
Section 42
(Federal)
40% of units at 60% AMI or
lower
20% of units at 50% AMI or
lower
50% and 60% of AMI
Some 80%
maximum of 30% of 60% rents
maximum of 30% of 50% rents
maximum household income of 140% of
AMI
greater of 30% adjusted, 10% gross,
welfare rent, or minimum rent set by
housing authority (if applicable)
Section 202 (HUD)
30% of AMI
(extremely low) (75% target)
50% of AMI (very low)
80% of AMI (low)
50% of AMI (very low)
Section 811 (HUD)
50% of AMI (very low)
HOME
(Federal / HUD and
some Local PJs)
HCVP
(HUD)
low or high HOME rents
greater of 30% adjusted, 10% gross, or
welfare rent
greater of 30% adjusted, 10% gross, or
welfare rent
elderly (62+)
Disabled
Resident Services Division
• Carlos Hernandez, Director
[email protected] 401-457-1223
• Gary Monroe, Operations Manager
[email protected] 401-457-1237
• Vanessa Galarza, Section 8 Program Manager
[email protected] 401-457-1157
• Joanne Curtis, Officer
[email protected] 401-457-1117
• Christine Smith, Officer
[email protected] 401-450-1383
Resident Services
(continued)
• Resident Services – A.K.A. – asset management, housing management,
section 8, Carlos’s department – Responsible for monitoring the
financial and physical condition of about 20,000 subsidized apartments.
• Rhode Island Housing – Resident Services Division - is the public
housing authority for 15 Rhode Island cities and towns
• Administers the state’s Section 8 Housing Choice Vouchers program for
these 15 municipalities, serving more than 1,400 low-income
households.
• Administers the Family Self-Sufficiency Program (FSS) which provides
up to five years of rental subsidies and supportive services to families
that agree to obtain education or job training necessary to achieve
independence.
Acronyms
•
•
•
•
•
HCVP – Housing Choice Voucher Program
HOME – not an acronym!
FHF – Family Housing Fund
PSH – Permanent Supportive Housing
PBCA – Performance Based Contract
Administration
• PBV – Project Based Vouchers
Acronyms
•
•
•
•
•
•
•
(continued)
LIHTC – Low Income Housing Tax Credit Program
NOP – Neighborhood Opportunities Program
PIS – Placed in Service
TIC – Tenant Income Certification
BIN – Building Identification Number
UA – Utility Allowance
LURA – Declaration of Land Use Restrictive Covenants for Low
Income Housing Tax Credits
• PJ – Participating Jurisdiction
TIPS for Property Managers
• Know the programs in your project
• Follow your tenant selection plan
• Evidence of 3rd party verification attempts
• Verifications – Signed, dated, original
• Verifications – Follow 120 day rule
TIPs
(continued)
• Anticipated income – must be verifiable
• Methods of determining income must be
used consistently
• Demonstrate income and asset calculations
• NEVER back date
• Do not use White-Out®
Extended Use Period
Owner commits to maintain the development as low-income
housing for at least 30 years beginning with the 1st day of the
15-year compliance period.
– Reviews at least once every three years
– 20% of tenant files and units
– All buildings, common areas and grounds
– Compliance monitoring fees
– Tenant data collection
Rent and Income Limits
• Rent and Income limits may be found on the HUD
website:
www.huduser.org/portal/datasets/mtsp.html
OR
• Using the rent and income limit calculator found
at: www.novoco.com/products/rentincome.php
Reference Materials
• Guide for Completing Form 8823, Low Income Housing
Credit Agencies Report of Noncompliance or Building
Disposition http://www.irs.gov/pub/irs-utl/lihcform8823guide.pdf
• HUD Handbook 4350.3 revision 1 change 3
•
http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/aff
ordablehousing/programs/home/
Questions?
Thank You !