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HUD Tenant Demographic data and Spectrum’s End of Year Data Collection Software

Friday, September 18th, 2015

Written by Paul Perpich, Spectrum Enterprises

The 2014 Spectrum End of Year data collection cycle has been completed and the tenant demographic data has been submitted to HUD. The 2014 cycle marked the end of significant updates HUD has made over the past two years to the tenant demographic and income data that was collected as a result of the congressional mandate embodied in the 2008 Housing and Economic Recovery Act (HERA). For the most part the recent major updates that you saw in our End of Year (EOY) software, primarily version 5.0.0 and later, have been stabilized and you shouldn’t see any changes to the dataset for awhile.

In 2014 HUD published their first final report on the tenant demographic and income data that has been submitted to date and included only the 2012 collected data. The initial report on 2013 data was published earlier this summer. It became apparent early in the process that the effort required of HFAs, property owners and managers as well as management software system vendors to ramp up their systems and personnel to collect tenant demographic data that was previously not collected for tax credit compliance was significant. Consequently, HUD decided that the 2009 to 2011 data submitted was not suitable for publication.

One aspect of the data collection process that has been problematic for HUD and is something we’ll be continuing to focus on is the submission of incorrect Building Identification Numbers (BIN). For this past 2014 cycle we added information in the Building form in our software that provided information about the correct format for the BIN as well as a tool to check the format of the BIN that had been entered. While we provided this guidance we did not require that the BIN be correct and the file could be submitted to us with the incorrect BIN. Moving forward we’ll be stiffening the requirement to submit correct BINs.

For the 2015 collection cycle we will still allow incorrectly formatted BINs to be submitted to us but we will be providing a report of those properties that have submitted incorrect BINs to the state HFAs. That report will also include statistics on the completeness of the rest of the HUD required data that was submitted. Our expectation is that by the 2016 collection cycle report files with incorrect BINs will not be allowed to be submitted to us.

Importing data using XML

The ability to import data directly from property management software systems into the Spectrum EOY software has been steadily increasing since the introduction of the State Housing Finance Agency Low Income Housing Tax Credit Data Transfer Standard in 2006. The development of the standard has been sponsored by the National Affordable Housing Management Association (NAHMA) and is commonly referred to as the NAHMA LIHTC XML Data Transfer Standard.

Spectrum included the ability to import data using the XML standard in 2009 with version 3.1.1 of our software. After a slow start use of the XML standard has increased significantly over time with the greatest increase occurring during the past two years. Spectrum has been working closely with the standards group since inception of the standard and has taken a leadership role in working with the HUD and the standards group to ensure that the standard includes all of the data elements is HUD requesting as part of their Low-Income Housing Tax Credit (LIHTC) Tenant Demographic and Income Data Collection program.

Using the XML import process to move event data from a management software system to the EOY software is a quick and relatively easy process that once correctly setup eliminates the need to manually enter tenant demographic and income data into the EOY software. An entire year’s worth of data can be processed and moved in just a few minutes. The XML standard is supported by Yardi, Real Page and Boston Post (now MRI) as well as other vendors. If you’re not using the XML process and would like to learn more about it please contact me at EOYHelp@SpectrumLIHTC.com or 517-277-0120.

Here’s a breakdown by Spectrum monitored states of the use of the XML import process:





































Important Reminders

Before submitting your EOY file to Spectrum please be sure to remember the following:

  1. Make sure the BIN numbers are correct (e.g. MA-12-00001) and match what’s on the 8609.
  2. Make sure the Placed in Service Date (PISD) is accurate (building form).
  3. Make sure the BIN address is complete and matches what’s on IRS form 8609 (building form).
  4. If you’re using XML to import data from your management system be sure to verify all the data that is not included in the XML import file such as the following:

– Management agent, owner and general partner data especially contact information

– All the property information, building and unit counts as well as the set aside information located in Property form.

  1. Missing TIC information to avoid 8823s
  2. Keep in mind that HUD is now requiring Live in Caretakers be reported on the TIC even though they aren’t included in the number of occupants count for the unit.
  3. Also keep in mind that all household members need to be entered not just the head of household.

New Compliance Bulletin Board

Thursday, May 19th, 2011

Written by Jessica Verry, Spectrum Enterprises Web Administrator

Spectrum Enterprises now has another tool for you to improve your LIHTC knowledge and information base.  We are proud to offer you an online Compliance Bulletin Board.  It is a simple way to ask questions, start discussions and work out any issues you may have with your LIHTC properties in a community forum.

Here at Spectrum we are always asking peer to peer questions and value community effort when solving a problem.  We hope that our Bulletin Board will help guide you when you run into an issue or you have a simple question that you would like one of our compliance experts to take a look at.

There are two forums within the Compliance Bulletin Board.  First is the Private Monitoring LIHTC Discussion board for anything related to LIHTC and our private monitoring services.  Following that is the State Monitoring Discussion Board.  If you are in one of the states that we monitor that is where you should post your questions.

Simply register with an email address (we will never send you SPAM) and you will be ready to join our community.

NAHMA XML Standard to be Modified to Accommodate HUD’s Tenant Data Collection Initiative (2008 HERA)

Friday, May 13th, 2011

Written by Paul Perpich Director of Software Developement

In order to accommodate the specific demographic data HUD is requesting, the State Housing Finance Agency Low Income Housing Tax Credit Data Transfer Standard (commonly known as the NAHMA XML standard) is being modified. I have been working closely with the standards group and Michael Hollar at HUD over the past eight months on updating the standard and it looks like a final draft will be completed within the next 30 days.

What this means is that those properties that are using management system software (e.g. Yardi, Real Page, Boston Post and others) that support the NAHMA XML standard will be able to make a single transfer of tax credit data into the Spectrum End of Year software in the same manner as they are doing now and that transfer will contain the data HUD is requesting.

It is expected that the updated XML export process will be available in those management systems that support it in time for the collection and submission of 2011 TIC data. Contact your vendor for information. At Spectrum we’ll have the new standard incorporated into our End of Year software sometime during the 4th quarter of 2011.

As part of the this ongoing process, HUD is in the final phase of modifying their TIC form in order to clarify some of the data elements as well as their instructions. Below are pending changes to the form. While HUD is also making changes to the instructions that accompany the TIC form, they have not been completed and a draft is not yet available.

Initial TIC Form
Pending Updated TIC Form
Move-in Date:
LIHTC Qualification Date:
Replaced with PIN:
Vacant Unit
Was Unit Vacant on December 31, 2010?  Yes;  No
(Is Yes, no other information required.)
Added – Did Not Respond
Added – Did Not Respond
Is Disabled:
Added – Did Not Respond
Part III: Gross Annual Income
Added – Individual Household Member Income is optional
Part IV: Income From Assets
Added – Individual Household Member Income is optional
Effective Date of Income Certification:
Effective Date of LIHTC Income Certification:
Household Size at Certification:
Household Size at LIHTC Certification:
Household Meets Income Restriction at:
 60%• 50%    40%• 30%  ____%
Household Meets LIHTC Income Restriction at:
 50% AMGI;
 60% AMGI
Household Income at Move-in:
Household Income at LIHTC Qualification Date:
Household Size at Move-in:
Household Size at LIHTC Qualification Date:
Maximum Rent Limit for this unit:
Maximum LIHTC Rent for this Unit:
Unit Meets Rent Restriction at:
 60%• 50%    40%• 30%  ____%
Unit Meets LIHTC Rent Restriction at:    50% AMGI;
 60% AMGI
Part VII. Student Status
Added – #6. Extended-Use Period
Next time I will be covering how we’ll be implementing more extensive help and tutorials in our End of Year software including complete information on the HUD data requirements.

HUD’s Tenant Data Collection Initiative (2008 HERA)

Friday, April 22nd, 2011

Written by Paul Perpich, Director of Software Development

Greetings and welcome to my first blog entry on our updated web site! I’m excited to have an opportunity to communicate directly with you about our End of Year Reporting software as well as upcoming changes you can expect to see. I’ll also be providing tips on the use of our software as well as industry news regarding the data we need to collect as part of our compliance monitoring activities. Please stay tuned…

The 2008 Housing and Economic Recovery Act (HERA) included a provision directing state HFAs to collect and submit to HUD demographic and economic information on tenants living in LIHTC properties. The first set of tenant data was for 2009 and initially needed to be submitted to HUD by September 31, 2010. HUD first released it’s XML data specification documents and technical instructions in July of 2010 and continued to updated them until September. Consequently, they moved the deadline back to October 31st.

We were able to work closely with Mike Hollar at HUD on finalizing and testing our submissions to their new web site and were able to compile and successfully submit final tenant data for our client state FHAs by the deadline (HUD letter to Spectrum).

The two primary reasons we were able to meet this deadline for the 2009 data (as well as the upcoming 2010 submission) is that HUD relaxed some of the requirements regarding what was to be submitted in the first year(s) of the mandate and the reduced data they are accepting has been part of the data set we collect every year in our End of Year Status Report software that property managers use to report to Spectrum as part of their annual compliance requirements. Things will change for the 2011 data.

Starting with 2011 data HUD will be raising the bar regarding the data that needs to be collected. For example, for 2009/10 they didn’t specifically require demographic data (name, DOB, race, ethnicity, disability status, student status, and last four digits of the social security number) on each member of the household and only required a Head of Household name. For 2011 they will require demographic information on all household members.

Collection of this demographic data has become a sensitive issue for some states and consequently HUD has modified the options for some of the questions. For example, HUD’s original TIC form only included a Yes or No answer to the Disabled question and include the following instructions regarding identifying disability:

“The housing credit agency administering its low-income housing credit program must, to the best of its ability, provide this disability status information, pursuant to 42 U.S.C. 1437z-8. However, it is the tenant’s voluntary choice whether to provide such information, and questions to the tenant requesting the information must so state. If the tenant declines to provide the information, the housing credit agency shall use its best efforts to provide the information, such as by noting the appearance of a physical disability that is readily apparent and obvious, or by relying on a past year’s information. For purposes of gathering this information, no questions with respect to the nature or severity of the disability are appropriate.”

For 2011 and beyond HUD has modified the available answers to include ‘Did Not Respond’ to the Race, Ethnicity and Disability Status questions.

Consequently, our End of Year Reporting software will be updated to include these and other new requirements and will be released in the fourth quarter of 2011. Keep in mind that the data HUD is requesting is the status of the project as of December 31st. What this means to property mangers in Spectrum’s client states is that they’ll continue to enter and submit data with our End of Year software in their usual manner and on their same schedule during the first quarter of 2012 (either hand entering or importing XML files from their management software systems) only they’ll be using an updated version of the software.

Next time I’ll be covering changes to the NAHMA XML standard (to accommodate the new HUD data) used by  property management software systems to import data into our software.

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