On 2/26/19, the Treasury Department will officially publish significant changes to LIHTC monitoring requirements. A copy of the publication can be found HERE
* Advance notice of file reviews and inspections will be limited to no more than 15 days.
* Same day notification of the particular units and files to be reviewed.
* The number of units and files reviewed will increase for properties with 100 or fewer units, decrease for properties with more than 100 units.
The IRS has severely limited the amount of advance notice monitoring agencies are allowed to give LIHTC property owners of upcoming file reviews and physical inspections. This is presumably because some owners have used the advance notice to make deferred repairs and improvements they otherwise would have put off. As a result, the conditions noted at the time of the inspections do not accurately reflect the conditions the tenants experience on a regular basis. The IRS believes giving Owners no more than 15 days advance notice of an inspection and/or file review will help eliminate this gaming of the system. By using same-day notice of which units/files in particular will be reviewed, the IRS believes the results of the reviews will better reflect actual conditions.
These changes present significant logistical issues for Owners, Managers, and Monitoring Agents. Allocating Agencies are required to implement these changes no later than 12/31/2020. You should review your policies and procedures now as these changes can be put in place any time before then.
The Connecticut Housing Finance Authority (CHFA) is pleased to provide you with the Low-Income Housing Tax Credit Compliance Manual for the State of Connecticut.
The Compliance Monitoring Manual is provided as a reference for Low-Income Housing Tax Credit compliance monitoring procedures and, to inform developers, owners and managers of the reporting requirements implemented by CHFA and SPECTRUM. This Manual is not a substitute for existing federal laws and regulations.
With passage of the HR 3221, HUD is required to gather demographic information for LIHTC properties. It is optional on tenants’ past but management must make a ‘best guess’ if not provided. Please begin using this TIC immediately.
- TIC Form Effective January 1, 2017 (PDF)
- CT Owner Letter 2020 Including EOY instructions and important notice(PDF)
- Owner’s Certification of Continuing LIHTC Program Compliance (PDF)
- Post Year 15 Owner’s Certification of Continuing LIHTC Program Compliance (PDF)
- Spectrum Status Software
- Status Report Software Instructions
- Utility Allowance
- Certificate of Continuing Education
CHFA has established a policy regarding how properties will be monitored and consequences for noncompliance during the Extended Use Period. The purpose of this policy is to ensure compliance with the Extended Low-Income Housing Commitment (ELIHC).
All End of Year Documentation must continue to be submitted annually. This includes the End Of Year Database, Post 15 Year Owner Certification, and Utility Allowance. Please refer to the Policy below for more details. The documents below serve as Connecticut Housing Finance Authority’s Post Year-15 Compliance Monitoring Policy
- All end of year materials due April 1st annually.
- Spectrum Status Report Software
- Status Report Software Instructions
- Post Year 15 Compliance Monitoring Policy (WORD) (PDF)
- Post Year 15 Owners Certification (PDF)
