IHCDA RED Compliance Monthly November 2018

RED Compliance

Helpful Reminders

  1. Please ensure tenant events are entered thru Authority DMS at ihcdaonline.com . According to the policy, tenant events are to be entered within 30 days of the event (RHTC Compliance Manual Section 7, Part B, page 92). Tenant events are reviewed during the audit season as well as at the beginning of each year with Owner Certification reports. Our Data and System Specialist, Meagan Simpson, is available to assist with access to the system, troubleshooting, and general questions regarding the system. Please contact at Meagan at msimpson1@ihcda.in.gov or (317)232-3561.  
  2. When preparing for a RHTC audit, please ensure all recertification documents include the following: TIC, Tenant Income Questionnaire (except at 100% properties), Student Status form, application, VAWA forms, Lease, and all addenda.
  3. When preparing for a HOME audit, please ensure all recertification documents include the following: TIC, Tenant Income Questionnaire, Student Status form, VAWA forms, Lease, and all addenda.
  4. All corrections on the TIC made after the recertification effective date should be initialed and marked “True and Effective as of” the date of the effective date.
  5. VAWA Addendum Form HUD 5380: Notice of Occupancy Rights Under VAWA is required to be given at the following times: initial admission, time of application denial, and when termination/eviction notices are sent.

Monitoring Stats

Total On-site Reviews: 74
Total On-site Completed : 56
Remaining: 18

Total Desktop Reviews: 243
Total Desktop Completed: 231
Remaining: 12
As of November 30, 2018

Complaint Chart

Top-Five Complaints

1. Eviction - 32%

2. Lack of Response to Work Orders - 24%

3. Mold - 20%

4. Discrimination - 12%

5. Miscellaneous - 12%


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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.