FROM: Asset Management, Management & Development Division
SUBJECT: 2017 Income Limits
DATE: April 19, 2017
Note: New Hampshire Housing provides the following information as a courtesy to owners and management agents and bears no responsibility for the accuracy of the information provided.
Please be advised that HUD published the 2017 income limits on April 14, 2017 and the limits were effective on that date. The HUD Multifamily income limits (to be used for Section 8) are available here and on the New Hampshire Housing website.
Properties with Section 42 Low Income Housing Tax Credits (LIHTC) or Section 142 Tax Exempt Bonds must use the Multifamily Tax Subsidy Project (MTSP) Income Limits available here and on the New Hampshire Housing website. For these programs, income limits must be implemented on the effective date or 45 days from the published date, whichever is later, which means that the 2017 limits must be implemented no later than May 28, 2017. Please see the clarification below regarding income limit requirements for areas where limits have decreased.
NOTE: For Section 8 properties that also have Tax Credits/Tax Exempt Bonds and/or HOME, all limits apply and the strictest applicable income limits must be used.
For properties that do not have Tax Credits/Tax Exempt Bonds and/or HOME, the Section 8 income limits must be used.
For properties with HOME funds, the 2017 HOME income limits have not been published to date. Please continue to rely on the 2016 limits until further notice.
If you have any questions, please contact your Asset Manager.
The following clarification applies to the MTSP income limits only. If you have properties with Tax Credits and/or Tax Exempt Bonds, please read below. This clarification DOES NOT apply to HUD Multifamily (Section 8) or HOME income limits.
For Tax Credit and Tax Exempt Bond properties the IRS has a "Hold Harmless" policy regarding income limits. What this means (as summarized by the IRS) is: "For both qualified residential rental properties under IRC §142 [Tax Exempt Bonds] and low-income housing under IRC §42 [Tax Credits], an initial AMGI is determined with respect to a project and the AMGI for any given year going forward from the date of initial determination will never be less than the AMGI for the year before." Basically, income limits for Tax Credit and Tax Exempt Bond properties will never go down. If the income limit for a specific area goes down, properties that have already placed in service will continue to use the same income limits that they used for the previous year. New properties placing in service would have to use the limits published for that year.
Again, this only applies to the MTSP income limits used for Tax Credits and Tax Exempt Bonds. Please continue to follow the requirements for the HUD Multifamily (Section 8) income limits and the HOME income limits (which have not been published yet for 2017). Properties with a combination of any of these must comply with all applicable income limits.