April 15, 2025

Note: Direct any questions on the content of this message to OHFA’s Compliance and DevCo Helpdesk.

2025 Multifamily Tax Subsidy Projects Income Limits Have Been Released!

HUD has released the 2025 income limits for tax credit/bond programs. The 2025 MTSP limits went into effect on April 1, 2025. The new limits must be implemented within 45 days for LIHTC properties or by May 16, 2025. Projects that are receiving an allocation of credits or will be placed in service within the 45-day period will be able to select the most favorable 2024 or 2025 limits with which to start. For allocations during the timeframe, the limits selected will affect the gross rent floor. For projects that will be placed in service in the 45-day period, it will affect the income and rent limits that the project will lease up with and “hold harmless” to in 2025, if necessary.  

For information on selecting the correct income limits for LIHTC projects, visit Costello Compliance’s blog post.

Importantly, HOME, CDBG, NSP, and NHTF programs are NOT covered by these limits. These limits should be published by HUD Community Planning and Development (CPD) in the next couple of months. 

HOTMA Guidance

In a prior industry message issued in December 2024, the HOTMA and NSPIRE Updates section instructed that HOTMA file errors found during an audit would be enforced (i.e., issuance of Form 8823) beginning July 1, 2025.  

However, on December 31, 2024, HUD extended the compliance implementation date for HUD-CPD programs, such as HOME, NHTF, HOPWA, CDBG, ESG, and CoC, to the earlier compliance date between January 1, 2024, and January 1, 2026.

Because HUD delayed implementation to January 1, 2026, OHFA has decided to delay enforcement actions (i.e., 8823) for HOTMA file errors until January 1, 2026. 

Prior to January 1, 2026, OHFA auditors will note HOTMA findings in the Compliance Audit Report (CAR). Although the message issued in December 2024 instructed that owners/management agents would not be expected to correct HOTMA file findings, OHFA has reversed this guidance. Owners/management agents must correct all HOTMA errors noted in the CAR. 

OHFA Audits

OHFA has seen an increase in owners/management agents failing to timely submit required audit documentation and/or correcting noncompliance for extended use projects. Owners/management agents for all OHFA-funded projects — even those in the extended use period — must comply with audit requirements. After an OHFA CAR has been issued, owners/management agents have 30 days to provide corrections to the findings. If additional time is needed to complete the corrections, OHFA requires owners/management agents to be actively working on the corrections and request an extension. An extension request must in writing and outline the reason(s) that warrant an extension. Requests must be submitted via the OHFA Inspection system in the communications tab.

Failure to comply with an OHFA audit may result in the issuance of Form 8823, placement on OHFA’s Not in Good Partnership list, and/or referral to our Chief Counsel’s office to enforce the requirements as outlined in the restrictive covenant, federal and state regulations, and OHFA policies. 

Uploading Tenant Files in OHFA Inspection - Reminder

• Upload only what is asked for and only one file at a time.
• Be sure to label each uploaded file with the BIN # and Unit #.
• Once the required files are uploaded, send an email to the OHFA auditor assigned to the project letting him/her know that the files have all been uploaded. The project name and number must be noted in the subject line of the email.

Failure to follow these instructions may result in the upload being rejected by the auditor.

HUD Updates VAWA Forms

HUD has updated the Violence Against Women Act (VAWA) forms. These forms are designed to handle transfers, certification of domestic violence, dating violence, sexual assault, and/or stalking. Additionally, the forms provide notice of rights and responsibilities to residents and housing providers. For more information, click here.

Stay Informed! 

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