Two OHFA Program Compliance forms have been revised in
order to address changes to compliance regulations with both
income calculation and the need to prove student status for
compliance with the HUD/HOME Student Rule. These changes are
necessary in order to be compliant with the final 2013 HOME Rule and
the changes made to the HUD 4350.3.
Due to monitoring over 1,400 properties for the
Housing Tax Credit program (HTC) with many also having HOME funds, it
is necessary to change both the Student Status Certification form
(previously optional, now mandatory) and the Sworn Income and Asset
Statement form (currently mandatory). The revised Student
Status Certification form contains questions that
inquire about student status, both full or part-time and issues
surrounding the two sets of student rule exceptions. In addition, the
revised Certification form contains questions regarding income
considerations for students in households that receive rental
assistance from the Section 8 program and receive financial aid above
the cost of tuition.
In light of the expanded student questions, the Sworn
Income and Asset Statement (SIAS) has been revised to
remove the HTC-specific student rule questions that currently appear
on page one. The SIAS also needed to be changed in order to inquire
about the use of Direct Express® cards (and any such card to which
wages or benefits are electronically deposited). The revised
forms are now posted on our website.
We recognize implementation of the HOME/HUD student
rule and the subsequent changes to the related OHFA forms may
initially be challenging for some of our partners. In drafting the
form changes, several industry partners and national trainers were
consulted along with OHFA's Program Compliance Advisory Committee to
ensure they contain concise questions to help maintain compliance
with the new regulations. OHFA Program Compliance will provide
supplemental guidance as needed. The revised Student Status
Certification and SIAS are now MANDATORY and must be
completed by all household members age 18 and older. The
implementation start date for use of these forms is January 1, 2016.
Certifications processed and executed before January 1, 2016 using
the older forms will not need to be altered. Questions regarding this
message may be directed to Betsy Krieger, Director of Program
Compliance, email@example.com or Christine Bennett,
Training and Operations Manager, firstname.lastname@example.org.