THDAs Top 10 Compliance Issues PRESENTED BY MULTIFAMILY PROGRAMS - - PowerPoint PPT Presentation

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THDAs Top 10 Compliance Issues PRESENTED BY MULTIFAMILY PROGRAMS - - PowerPoint PPT Presentation

THDAs Top 10 Compliance Issues PRESENTED BY MULTIFAMILY PROGRAMS DIVISION STAFF 2018 TAAH Conference Top 10 Lack of Knowledge of Development Requirements Compliance Confusing the Housing Credit Program with Rules with other Program Rules


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SLIDE 1

THDA’s Top 10 Compliance Issues

PRESENTED BY MULTIFAMILY PROGRAMS DIVISION STAFF

2018 TAAH Conference

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SLIDE 2

Lack of Knowledge of Development Requirements Confusing the Housing Credit Program with Rules with other Program Rules Incorrect Income and Rent Limits File Organization Poor Documentation Weak or Missing Policy and Procedures Lack of Training Lack of Quality Assurance Online Reporting Physical Deficiencies

Top 10 Compliance Issues

2018 TAAH Conference

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SLIDE 3

Property Profile

Applicable QAP Point Items from Initial Application Extended Use Place in Service Dates Minimum Set Aside First Year Credits Claimed Gross Rent Floor Applicable Income Limits

2018 TAAH Conference

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SLIDE 4

MTSP Income Limits

  • Only Applicable to LIHTC Properties
  • 45 Days Implementation
  • HERA Special
  • National Nonmetro Income Limit

* Not applicable to bond deals

Information Needed to Determine Income/Rent Limits

  • Gross Rent Floor Election
  • Federal and State Set-Asides
  • Placed in Service Date(s)
  • Multiple Building Project

2018 TAAH Conference

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SLIDE 5

File Organization

Systematic Filing, including move-out files Application, Verification, and Certification in each file Consistent structure throughout each file Implementation of THDA’s Best Practice Forms

2018 TAAH Conference

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SLIDE 6

2018 TAAH Conference

Exercising prudence and establishing strong internal controls

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SLIDE 7

Resident Data

OAC

2018 TAAH Conference

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SLIDE 8

Physical Inspections

Units Not Rent Ready Exigent Health & Safety Issues Deferred Maintenance Unreported Casualty Losses

2018 TAAH Conference

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SLIDE 9

Division Updates Portfolio Assignments Revised Forms (2018) New Online Reporting System Income Averaging

2018 TAAH Conference

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SLIDE 10

2018 TAAH Conference 60% Average

2 units @ 80% 1 unit @ 20%

60% Average

4 units @ 70% 1 unit @ 20%

60% Average

3 units @ 80% 2 units @ 30%

60% Average

6 units @ 70% 2 units @ 30%

Income Averaging

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SLIDE 11

2018 TAAH Conference

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SLIDE 12

Allocation

Ed Yandel Felita Hamilton Joe Bethel Rebecca Scott Terry Montgomery

Asset Management and Construction

Terry Malone Stan Pack Chris Marlin

Compliance

Andrew Bryant Chuck O’Donnell Jawon Lauderdale Leontyne Washington Marquel Mitchell

Support Team

Mark Cantu Robert Lucas Shannen Cross

Multifamily Programs Division Donna Duarte, Director

2018 TAAH Conference

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