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OHFA Revises Two Mandatory Student Status Forms


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, bkrieger@ohiohome.org or Christine Bennett, Training and Operations Manager, cbennett@ohiohome.org



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