As a LIHTC site owner or manager, it’s important to be aware of Housing Opportunity Through Modernization Act (HOTMA) provisions since the legislation deals with reforms to the Section 8 Housing Choice Voucher program. And although the HOTMA legislative text or HUD regulations concerning HOTMA don’t mention LIHTC, the rules still affect LIHTC properties.

In dealing with the constraints imposed by the pandemic, many state housing agencies have successfully transitioned to virtual household file reviews. The IRS’ recent notice reflects this reality in splitting compliance-monitoring requirements for household file reviews from the requirements for physical inspection. Household file reviews must still be completed this year. But the required 15-day notice in advance of household file audits have been loosened to 30 days until the end of this calendar year.

An applicant or household isn’t qualified for a low-income unit at your site unless you have the verifications to prove it. Owners and managers must make sure that every source of income that a household reports is verified. If you accept a household without verifying all its income, the owner won’t be able to claim tax credits for the household’s unit. And if the owner needs to count the unit to meet the minimum set-aside, the owner won’t be able to claim credits.