Welcome to the inaugural issue of the IHCDA monthly compliance newsletter. Through this monthly publication we intend to share trends, helpful reminders, compliance FAQs, and more. Please contact a member of the Compliance Team with any questions or comments.
 From left to right are Real Estate Department Compliance team members: Ryan Splichal-NE Indiana Region, Stacey Norman-Northwest Indiana Region, Anita Smith-Closeouts, Meagan Simpson-Data Systems Specialist, Ganee Natschke-Southwest Indiana Region, Cindy Cox-Southeast Indiana Region, Devyn Smith-Director Real Estate Compliance.
Click here to access the Real Estate Compliance map.
Desktop and Onsite Audits
2018 Audit Season is almost over! Thank you to all partners for submitting the requested information on time. Below is a list of the top-3 Tax Credit audit issues:
Issue # 1: The tenant selection criteria failed to meet the minimum standard as outlined in the manual.
RHTC Rule: The tenant selection criteria must at minimum contain the following information (Section 5.3, Part E, page 54):
- Occupancy Standards (Number of people allowed per unit by bedroom size).
- Program Eligibility Factors (income limits, student status, etc.)
- Citizenship requirements imposed by management (if applicable)
- Minimum income requirements imposed by management (if applicable)
- Credit, criminal, and previous landlord background check factors
- Application and waiting list process
- Transfer policy or state transfers are not allowed
- Any special preferences (e.g. elderly or special needs)
- Explanation of application denials including an appeal process
Issue # 2: The effective date on recertification documentation is not on the anniversary of move-in.
RHTC Rule: The RHTC recertification date for a household must be on the anniversary of the move-in date. The certification date may not change to align with other programs even if it means a household must be certified multiple times annually for multiple programs. (Section 6.6, pg. 81)
Issue # 3: There is a lack of evidence that tenants received the required VAWA forms.
RHTC Rule: The 2013 reauthorization of the Violence Against Women Act (VAWA) expanded the act’s coverage to include RHTC projects. There are required notices for tenants as well as an emergency transfer plan at each property. The required forms can be located on our partner page under Appendix M: VAWA Forms. (Section 5.3, Part G, page 56).
Utility Allowance Request Reminders
New cover letters can be found on our partner page under Appendix G. Please include the most updated utility allowance cover letter along with supporting documentation for all utility allowance requests. Requests can be submitted vial mail at 30 S Meridian Street Suite 900 Indianapolis, IN 46204 ATTN: Utility Allowance or email at ua@ihcda.in.gov. Please see Section 4.4, Pages 32-37, of the 2017 RHTC Compliance Manual for further guidance regarding utility allowances. |