The Credential - September 2020

Message from the Chair

Welcome to the September edition of The Credential.

First and foremost, I would like to pay tribute to members of the affordable housing community for their perseverance during this ongoing pandemic, through seemingly unrelenting natural disasters, and waves of social changes.

On July 1, as a result of concerted effort of various affordable housing industry advocacy groups and government agencies, the House of Representatives passed an historic infrastructure bill, the Moving Forward Act (H.R.2), with significant expansion of housing credits and private activity bonds. This bill is a work of bipartisan effort to prioritize affordable housing measures in the next COVID-19 bill to support affordable housing production and address disruptions caused by the current public health and economic crisis. Although the bill is expected to stall as it moves to the Senate, we remain hopeful that provisions from the legislation may be included in the next COVID-19 response bill the Senate is expected to consider later this month.

On the same day, the IRS had released an advance copy of proposed regulations on Low-Income Housing Tax Credit (LIHTC) compliance issues and IRS Notice 2020-53. In this edition of The Credential, A.J. Johnson with A.J. Johnson Consulting Services shares various up-to-date guidance from the IRS and state Housing Finance Agencies (HFAs) in “Update on COVID-19 Guidance for LIHTC Properties.” This includes in-depth examination on the IRS Notice 2020-53, which provides relief on time-sensitive requirements, tenant rent protections and exposure to owners of LIHTC properties.

Next up is Scott Michael Dunn with Costello Compliance, who will cover fundamental program concepts with a focus on “Back to Basics: Casualty Loss,” including guidance and definition of casualty loss, result of casualty events, treatment of losses based on federal declaration, reasonable period on restoration and potential impact on credits.

Continuing to explore different sources for utility allowance, Amanda Lee Gross from US Housing puts a spotlight on HUD Utility Schedule Model (HUSM) and Energy Consumption Model in “Conquering LIHTC Utility Allowances.” While exploring more options, it is important to take into consideration that State Housing Agencies may impose different procedures in requesting and implementing alternate method of utility allowances and may impose exclusions or limitations on certain properties.

To round out the current edition of The Credential, Gary Kirkman from E&A Team will share “Wrapping Up 2020: Year-End Reporting” to bring focus to four critical areas in preparation for the upcoming year-end reporting on LIHTC properties. This article gives consideration to owners and management in planning in advance and a timely reminder that despite the temporary suspension of tenant recertification, each LIHTC property must continue to maintain program compliance.

Finally, as part of our regular spotlight articles, we introduce

• HCCP Designee: Amanda Mistretta, compliance auditor at Raymond James Tax Credit Funds
• Board of Governors member: Carol Howard, vice president and director of housing compliance at Boston Capital
• HCCP exam distributor: Gary Kirkman, director of compliance training at E&A Team, Inc.

As a reminder, NAHB is hosting another webinar on “Casualty Loss on LIHTC Properties – IRS Guidance and the Impact of COVID-19” on Sept. 15 at 2 p.m. ET. Register today. Again, the webinars are available free of charge to all active members of the HCCP community and are a perfect way to meet your continuing education requirements.

Many thanks to those doing their part in helping keep the wheels turning under these uniquely difficult circumstances. Staying connected with each other during these extraordinary times is particularly important as we all come to terms with new shared realities. In times where many are emotionally fatigued from fear and uncertainty, even a small gesture of support or a simple word of compassion can go a long way in promoting a sense of global camaraderie — that we are all commiserating over the impact from the pandemic and reminding one another that we are not alone. Hang in there.

With Warmest Regards,
Kristin Han, HCCP
WNC & Associates
Chair, HCCP Board of Governors

Stories in This Edition:

Update on COVID-19 Guidance for LIHTC Properties
Back to Basics: Casualty Loss
Utility Allowance Series, Part 5
Wrapping Up 2020: Year-End Reporting
HCCP Designee Spotlight
HCCP Board of Governors Spotlight
HCCP Distributor Spotlight