May 14, 2025

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

OHFA’s LIHTC Compliance Manual —

Revisions and a Technical Update

On April 15, 2025, OHFA published a new LIHTC Compliance Manual. A few revisions made to the manual are as follows:

Section 13 (Unearned Income)

• Student Financial Assistance (page 113) – Added a student financial assistance chart to provide a better visual of how to handle this type of assistance

Section 14 (Assets and Exclusions)

• Assets Disposed of for Less Than Fair Market Value (page 117) – Technical Update – The manual published last month instructed if an asset is disposed of for $1,000 less than fair market value (FMV) within the last two years it must be included as an asset. This guidance is not compliant with HOTMA. Prior to HOTMA, assets disposed of for $1,000 less than FMV were to be included for two years. But with HUD Notice 2023-10, #F.4.a, page. 59, HUD eliminated the $1,000 threshold. 

• Tax Refunds (page 125) – Added text to provide additional explanation and two example charts 

Section 16 (Unit Transfers, Next Available Unit Rule, and Vacancy Rule)

• Unit Vacancy Rule (page 152) – Added text to provide further explanation

The revised manual (with these changes) was posted to our website on April 23, 2025. Owners/management agents should use this revised version.

Revised Sworn Income and Asset Statement (SIAS) and $51,600 in Assets Self-certification Forms

Because HOTMA eliminated the $1,000 threshold regarding assets disposed of for less than FMV, OHFA’s SIAS and $51,600 in Assets Self-certification forms were revised on March 27, 2025, to accurately reflect HOTMA. 

Older forms contained the following wording, “Have you disposed of any business or family assets for $1,000 less than FMV to someone outside the household within the last two years?” 

Because the $1,000 threshold was eliminated by HOTMA, the language regarding asset disposal has been revised to: 

“Have you disposed of any business or family assets for less than FMV, including a disposition of a trust to someone outside the household within the last two years? Do not include assets disposed through foreclosure, bankruptcy, separation, or divorce if you received consideration not measurable in dollar terms or monetary value. An example of this would be if you agree to sell your camper for less than fair market value in a divorce settlement to your ex-husband/wife in exchange for his/her promise not to resell the camper.”

The camper example was added to clarify what “received consideration not measurable in dollar terms or monetary value” means. 

Note: Owners/management agents who used a prior version of the SIAS and/or $51,600 in Assets Self-certification forms for income qualification before March 27, 2025, are not required to have tenants complete revised forms.  

OHFA HOTMA Forms — Your Questions Are Answered!

A couple of months ago, OHFA requested industry partners submit questions regarding HOTMA forms, specifically the SIAS and $51,600 in Assets Self-Certification. OHFA appreciates the feedback received.

Our initial intent was to hold a recorded training based upon submitted questions and comments on the forms. However, we decided it is just as productive to publish a Q&A factsheet. As such, we developed three Q&A documents: 

• General HOTMA Form Questions
• SIAS HOTMA Form Questions
• $51,600 in Assets Self-Certification HOTMA Form Questions

These documents can also be found on our website.

HUD Issues 2025 HUD HOME/NHTF Income Limits

On May 5, 2025, HUD released the HOME and NHTF 2025 income limits. These new limits become effective June 1, 2025.

Note: Last month, OHFA issued the 2025 Multifamily Tax Subsidy Income Limits. These limits were effective April 1, 2025, and must be implemented by May 16, 2025. 

Be Prepared: OHFA’s Annual HOME-NHTF Rent and Occupancy Report Is Due July 1, 2025!

HUD's 2025 HOME and NHTF income limits have been published and become effective June 1, 2025, as outlined above. Owners/Management agents of projects with HOME- and/or NHTF-assisted units are required to submit OHFA’s HOME/NHTF Rent and Occupancy Report 30 days after the effective date of the new HOME/NHTF income limits or by July 1, 2025. Additionally, NHTF and HOME regulations 24 CFR § 93.204(b)(4) and §92.214(b)(3) require that OHFA approve fees charged by the owners/management agents. As a reminder, any fees charged to tenants should not create an undue burden on tenants and be reasonable and customary for the geographic area. OHFA considers the following charges as customary:

• Application fees
• Late fees
• Fees for insufficient funds
• Lost key/lockout fees
• Pet fees (limited to $30/month total, not per pet)
• Parking in neighborhoods where such fees are customary (e.g., garage fees)
• Credit card processing fees
• Costs of non-mandatory services, such as meal or bus services, so long as such services are voluntary

Customary charges are limited to “actual costs.”

Please ensure you read all instructions on the HOME-NHTF Rent and Occupancy Report before completing it. 

Note: Owners/management agents only needs to be submit a new lease if there were changes made from the previous year's lease. Submit the HOME-NHTF Rent and Occupancy Report and any other required information by emailing it to HOMERA@ohiohome.org. 

Revised HUD VAWA Forms

In last month’s industry message, OHFA provided information on HUD’s revised VAWA forms to ensure you, our partners, were aware the revised forms had been published by HUD. As of the date of this industry message, HUD has not issued implementation guidance on the forms. In the absence of such guidance, owners/management agents should continue using the older VAWA forms. 

Stay Informed! 

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