File Reviews

File ReviewsTenant File Review

Identifying a non-eligible tenant or a single instance of non-compliance can completely offset the cost of having all of your files audited.

Our services can be tailored to meet the specific needs of any project’s stage of development. Our most commonly requested services are:

1. Lease-Up (New Construction): At the completion of lease-up for new properties, Spectrum reviews all LIHTC tenant files that make up the project’s initial qualified basis. We then prepare a comprehensive report detailing compliance and eligibility status on a unit-by-unit basis. The report also includes a project-wide evaluation of procedures.

The entire certification process is analyzed with supplemental forms, procedures, or corrective methods accompanying any findings.

2. Annual Review: This is typically an annually recurring review of tenant files to ensure that the property staff continues to meet LIHTC compliance expectations. We typically review 20% of the tenant files on an annual basis.

3. Acquisition Rehab: This is the most complex type of review. Spectrum will review all LIHTC tenant files that make up the project’s initial qualifying basis. We will audit the files to ensure compliance with the safe harbor rule based on the acquisition date. Spectrum will then prepare a comprehensive report detailing compliance and eligibility status on a unit-by-unit basis. The report issued also includes a project wide evaluation of procedural issues noted at the time of review.

4. Resyndication: Spectrum will review the new move-in files or a certification showing any period of income eligibility for current residents. We will then prepare a comprehensive report detailing compliance and eligibility status on a unit-by-unit basis. The report issued also includes a project wide evaluation of procedural issues noted at the time of review.

Spectrum’s LIHTC review includes a detailed analysis of the following:

  • Tenant applications, income verifications, certifications, and leases.
  • Income calculation methods.
  • Area income limits and rent-restrictions.
  • IRS Form 8609 for each building.
  • Regulatory Agreements, Restrictive Covenants, and Extended Use Agreements (or equivalent).
  • Student status documentation.
  • Vacant unit and 140% issues.
  • Deeper skewed set-asides.
  • Initial qualified basis.

Spectrum 2017 Sample Investor Report

Submitting files to Spectrum for Review

Property Compliance Profile

If your property or company could benefit from this service please contact Dan Warren, for more information.