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Low Income Housing Tax Credit (LIHTC) Recertifications

 

The Ohio Housing Finance Agency (OHFA) Office of Program Compliance is revising its policy for timing of signatures for Low Income Housing Tax Credit (LIHTC) recertifications and/or verifying tenant student status. For LIHTC properties that are required to conduct full annual recertifications (i.e. properties that are not 100% allocated to the Housing Tax Credit program), OHFA's current policy is to allow owners and managers to gather signatures on Tenant Income Certification (TIC) up to 60 days before the anniversary date of move-in. The Internal Revenue Service through the 8823 Guide instructs state housing agencies to recertify tenants within 120 days from the anniversary date of move-in. In order to align OHFA policy with the IRS, OHFA is revising its policy to allow both the recertification TIC and Sworn Income and Asset Statement (SIAS; form PC-EO1) or Student Status Certification (form PC-E42) to be signed on or up to 120 days of the household's move-in or recertification date. This policy will be effective October 1, 2014. Keep in mind properties with multiple funding sources such as HOME or USDA RD must continue to follow the specific recertification program guidelines. Owners and managers of 100% low-income properties should continue to verify tenant student status by using either the SIAS or the Student Status Certification on or up to 120 days of the household's move-in or recertification date. There have been some inconsistencies in the use of OHFA's student status verification forms. OHFA instructs owners and managers to use one or the other student status verification forms but not to use both when verifying student status.

We believe this change will allow for more operational efficiencies for our partners. Please direct any questions regarding this policy change to Betsy Krieger, Acting Director of Program Compliance by email or by telephone at 614-387-1661.