Message from the Chair
Greetings and happy holidays HCCP® Professionals — and welcome to the December edition of The Credential.
It’s hard to believe that this year is coming to a close, however as we are preparing for the upcoming holiday season, we also need to remember that audit season is right around the corner. As LIHTC professionals, it is our duty to ensure that our properties meet the requirements of Section 42 of the IRS Code and the Extended Use Agreement for specific eligibility requirements. As we close out this year, take time now to review your management policies and tenant files to ensure your property is in compliance. These reviews will also assist you in beginning to prepare your annual owner reports. Taking these actions now helps to ensure a strong start to the upcoming year and an efficient audit process.
As we reported in June 2018, the Consolidated Appropriations Act of 2018, enacted on March 23, 2018, established income averaging as a third minimum set-aside election for new Housing Credit developments. Owners of new developments could choose this option over the two existing minimum set-aside elections (40/60 and 20/50). Income averaging allows credit-qualified units to serve households earning as much as 80% of Area Median Income (AMI), as long as the average income/rent limit in the property is 60% or less of AMI. During a recent National Council of State Housing Agencies 2018 Conference & Showplace in Austin, Capital One conducted a survey of affordable housing leaders and lenders. While in support of the Act many respondents raised questions about the new rules, with 33% identifying “lack of clarity about state and local implementation” and 32% citing “gray areas in the legisla¬tion” as the greatest impediments to its adoption. NAHB also hosted a webinar in July 2018 on “How to Avoid Costly Mistakes with the New Average Set-Aside Option.” We received quite a few questions during the webinar therefore in our continuing effort to provide educational opportunities to our HCCP members we will present Income Averaging Part II: Crucial Update for our December webinar. Please find additional details about this timely webinar below.
In this edition of “The Credential,” you will also find articles to assist you with ensuring ongoing compliance in the LIHTC program. The first article comes from Karen A. Graham, president and CEO of Karen A. Graham Consulting & 42U LIHTC On-Line Learning, titled The Hunt for Information. In this article, Karen shares the importance of having a Property History Binder or Property History File with the required documents. The second article is titled Important Elements of Low-Income Housing Tax Credit Leases by A.J. Johnson, president of A.J. Johnson Consulting Services Inc. of Williamsburg, Va., and a longstanding member of the HCCP Board of Governors Technical Advisory Group. A.J. provides a listing of important clauses that should be considered when preparing a LIHTC lease. And the third article is titled Congratulations: You Qualify by Star Storey, director of Housing Preservation Trust. Star’s article will help you create positive experiences for your applicants entering the LIHTC program.
Finally, in our regular spotlight articles, you will get the chance to learn more about HCCP Board of Governors member Jennifer Marchand, multifamily compliance technical advisor for Oregon Housing and Community Services, and HCCP Elizabeth Dziak, vice president of asset management operations for RBC Capital Markets.
I would also like to remind our members that the 2018/19 HCCP webinars are free of charge and provide a great way to meet your continuing education requirements while learning new things about our industry. As noted above our next webinar will focus on Income Averaging – Part II: Crucial Updates, presented by Scott Michael Dunn, CEO of Costello Compliance and director of policy for the Costello Companies in Sioux Falls, S.D., and member of the Technical Advisory Group to the Board. The webinar will be held on Wednesday, Dec. 12, 2018. Click here to register. Remember to log in to http://nahb.org/ with your regular username and password, and the webinar price will be "$0" when added to your cart. We hope you will be able to join us.
As always, the Board of Governors is here to serve you and the HCCP credential. Let us know how we can support you in your professional endeavors and if there are topics you would like to see covered in The Credential or as a webinar.
Finally, my term as chairperson of the HCCP Board of Governors will conclude in February 2019. It has been an honor serving as chairperson for the past year. I give my sincere thanks for professional support from the NAHB staff, most especially Crystal Jackson, and fellow board and Technical Advisory Group members. I would also like to thank Bob Landis, former HCCP Board of Governors chairperson, for his assistance during my tenure as chairperson. It is a true honor to serve in support of a wonderful credential and highly dedicated professionals in the HCCP community. Keep up the great work!
On behalf of the board, thank you for all that you do to promote the HCCP designation and the LIHTC program. We wish you and your families a safe and happy holiday season.
Donna Mills, HCCP
Chair, HCCP Board of Governors