IHCDA Compliance Updates & Highlights

OUTLINE OF PRESENTATION

Part 1: What is IHCDA Up to?•2013 Annual Owner Certifications•2014 Monitoring Schedule•Compliance Forms•Online Reporting Reminders•Upcoming HOME Manual Revisions

Part 2: Compliance Hot Topics•VRAP & Student Status•Recertification Dates•Recertification Exemption•Misc. Updates in 2014 Manual

Part 1: What is IHCDA Up To?

2013 OWNER CERTIFICATIONS &2014 MONITORING SCHEDULE2013 Annual Owner Certification reviews on track to be completed end of May•Following up on issues•Following up on OCs not submitted

2014 Monitoring is now underway•Expect summer to be heavy season for onsite file monitoring

COMPLIANCE FORMS

In 2014, IHCDA is reviewing all of its sample and mandatory compliance forms•Are any forms outdated?•Are any forms redundant/duplicative?•Do any forms collect unnecessary information?•General formatting and wording•Are any forms missing?

If you have suggestions on an IHCDA form that needs edited or a form you wish IHCDA provided, please contact us soon.

ONLINE REPORTING REMINDERS

All tenant events must be entered into IHCDA’s online reporting system at ihcdaonline.com

Every property must input tenant events every 30 days

IHCDA is now running reports on properties that are behind on reporting and sending quarterly reminder letters

Why is this important?•Easier on management to do throughout the year•Provides IHCDA with more accurate vacancy information

UPCOMING HOME MANUAL REVISIONSIHCDA has two compliance manuals that affect the HOME program and both are currently under revision

•CDBG & HOME Award Manual• Covers compliance from commitment of funds to closeout• Updated manual to be released with target date of 5/31/14

•Federal Programs Ongoing Rental Compliance Manual• Covers rental compliance during the affordability period• Updated manual to be released with target date of 6/30/14

Part 2: Compliance Hot Topics

VRAP & STUDENT STATUS

IHCDA considers the Veterans Retraining Assistance Program (VRAP) as an eligible student status exemption under the job training program exemption.

This policy is now in writing in the 2014 Compliance Manual.

CAUTION: VRAP appears to be a short-term program. Keep in mind student status eligibility (unlike income eligibility) is a continuous requirement. If a full-time student is no longer in VRAP but still a full-time student, another exemption will need to be met.

RECERTIFICATION DATES

The effective date listed on a recertification TIC should be the anniversary date of the initial move-in

Example: household moves into a unit on 5/22/14, first annual recertification has an effective date of 5/22/15

Verifications and signatures good for 120 days prior to the effective date

Lease term may have a different effective date

RECERTIFICATION EXEMPTION

All Indiana projects (8609 Line 8b definition) that are 100% tax credit are automatically eligible for the Recertification Exemption•No approval required•No requirement to do full recertification for first year

What documents are needed?•No income and asset verifications at recertification•Still complete student status forms and a one page TIC to report on household composition and rents

MISC. UPDATES IN 2014 MANUAL

The 2014 edition of the Tax Credit Compliance Manual includes the following important changes:

•Foster children/adults counted as household members per HUD Handbook Change 4•Applicability of “married and entitled” student exemption to same-sex couples per IRS guidance Rev Ruling 2013-17•Violence Against Women Reauthorization Act of 2013 requirements•Treatment of debit cards as assets •Steps to verify Social Security•For tax credit projects with HOME funds, various updates relating to the 2013 HOME Final Rule