Spectrum Compliance Continuum 2022: Key Questions Answered
Navigate through the complexities of compliance in the Spectrum Continuum with answers to key questions on extended use agreements, grandfathering, income limits, recertifications, and relocations for property management and tax credit qualification. Get insights on ensuring compliance and maximizing benefits for your housing projects.
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Presentation Transcript
Resyndication/New Credits Spectrum Compliance Continuum 2022 By: Tina Clary
Most commonly asked question Number 1 Extended Use Agreement (EUA) Old vs. New Old Extended Use term still in effect and new term will run concurrently until both terms are met
Most commonly asked question Number 2 Grandfathering This concept is for tenants in place at the time of the 1st round of credits. It is critical that the initial move in file is intact and well documented including the application If the household was previously income qualified they will qualify at the 2ndround of credits Qualifying households are protected however, there is no such protection offered to fulltime student households or units that exceed the applicable gross rent
Most commonly asked question Number 3 Income Limits Use the income limits in effect on the date of acquisition The acquisition of the building might fall within the 45 day grace period after new income limits are published. If this occurs you re free to choose the higher of the 2 available income limits
Most commonly asked question Number 4 Recertifications The most important thing is to ensure that all existing residents complete the tax credit qualification paperwork within 120 days on either side of the acquisition date. The effective date on the Tenant Income Certification (TIC) will be the acquisition date. Your income/asset verifications, affidavit forms, and TIC signatures may or many not precede the TIC effective date Once a subsequent allocation of credit is received the property may no longer receive the Hold Harmless protection and must use the income limits that correspond to the new placed in service date. Rents being charged may need to be lowered If you can t get all tenants certified within the 120 days this means they are no longer allowed the protection of the grandfathering Any new applications received will reflect the actual move in date as the effective date
Most commonly asked question Number 5 Relocation If your property receives FedHome money Housing Trust Fund (HTF), Section 8, Rural Development (RD) or any Federal subsidy, you must follow HUD relocation plan. Submit for review and approval to MaineHousing. LIHTC alone does not qualify as federal funds If a HUD relocation plan is not required MaineHousing still requires a plan to be submitted for review and approval and can be found on page 30-31 in the 2017 RLP Guide. https://www.mainehousing.org/docs/default- source/program-guides/rental-loan-program-guide- (october-2017).pdf?sfvrsn=7a0fa115_2
