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:
|
State |
Properties |
Use XML |
% |
|
CA |
2944 |
2151 |
73% |
|
CT |
234 |
111 |
47% |
|
HI |
84 |
29 |
35% |
|
MA |
651 |
433 |
67% |
|
MD |
375 |
285 |
76% |
|
WV |
242 |
142 |
59% |
|
VI |
24 |
9 |
38% |
|
Totals: |
4554 |
3160 |
69% |
Important Reminders
Before submitting your EOY file to Spectrum please be sure to remember the following:
- Make sure the BIN numbers are correct (e.g. MA-12-00001) and match what’s on the 8609.
- Make sure the Placed in Service Date (PISD) is accurate (building form).
- Make sure the BIN address is complete and matches what’s on IRS form 8609 (building form).
- 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.
- Missing TIC information to avoid 8823s
- 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.
- Also keep in mind that all household members need to be entered not just the head of household.
