February 9, 2023
Columbus, Ohio
Requesting Extensions
 
Compliance wants to ensure that all of our partners know that after you have been issued a Compliance Audit Report (CAR), you initially have 30 days to provide corrections to the findings. If you need additional time to complete the corrections, you must do two things: actively work on the corrections and request an extension. Your request for an extension to the auditor who completed the inspection must be in writing and state the reason(s) why you are requesting the extension and what you are working on in regard to the corrections. Your request must be submitted via the OHFA Inspection system in the communications tab. If an extension is not requested, the audit will be closed out as uncorrected and 8823’s issued as applicable.
Uploading Tenant Files in OHFA Inspection
 
  • Upload only what is asked for and only one file at a time.
  • Be sure to label each file you upload 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. Please ensure the project name and project number is notated in the subject line of the email.

Failure to follow these instructions may result in the upload being rejected by the auditor.
Compliance Next Steps Meetings
 
In an attempt to streamline the Compliance Next Steps (CNS) meetings process, effective March 1, 2023, the compliance team will offer only two dates to hold the CNS meetings rather than providing multiple dates. Dates will be offered at a minimum of two weeks out. A response will be required within three business days of the email sent date. We have learned over the last year that offering multiple dates and waiting for responses have caused the process to slow down significantly. Please do your best to make one of the appointments work if at all possible. If there is no way to make either appointment work, please reply to the email with two alternative dates. Information on the CNS process is found here
HOTMA is here! 
 
On January 31, 2023, the U.S. Department of Housing and Urban Development’s Office of Multifamily Housing Programs published a draft of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) final rule. The new final rule can be found here.

HOTMA will impact the LIHTC, HOME and National Housing Trust Fund (NHTF) programs that use HUD regulations, specifically Sections 102 and 104 of the Final Rule: 

  • Section 102: Addresses income reviews, including the frequency of income reviews, and revises the definitions of income and asset

  • Section 104: Sets asset limits for Section 8 and Public Housing programs — Asset limits do not apply to Section 202/8, Section 202/162 Project Assistance Contract (PAC), 202/811 Project Rental Assistance Contract (PRAC), Senior Rental Preservation Assistance Contract (SPRAC), or Section 811 Project Rental Assistance (PRA) programs.

The provisions that apply to LIHTC, HOME and NHTF will be effective starting January 1, 2024. 

More information can be found on HUD’s HOTMA webpage.
 
OHFA will issue additional guidance soon. Stay tuned!
It’s That Time Again. Be Prepared for Annual Owner Reporting.
 
2022 Annual Owner Reports (AORs) are due Wednesday, March 1, 2023. Owners are able to submit AORs now rather than waiting until March. Below are a few reminders to help prepare for AOR submissions:
 
  • All tenant events need to be updated in DevCo no later than the 10th of each month for the previous month. Please make sure you have updated all tenant events for the 2021 year in preparation for submitting your AOR next year. You also need to update all tenant events when you are notified of a file audit.

  • Utility Allowance (UA) information must be updated in DevCo annually. Here are instructions on how to update your project’s UAs.

  • Make sure the necessary staff members responsible for completing the AOR have access to DevCo. Here are instructions on how to get access to the DevCo database. If you need any assistance getting access, please contact the DevCo Help Desk.

OHFA will offer a free one-hour AOR webinar on February 14, 2023, at 1:00 p.m. The webinar will explain the Annual Owner Report process, including entering tenant events, dealing with errors, uploading XMLs, finalizing the reporting year, completing the Annual Owner Certification questionnaire, and submitting corrections to AOR findings.  
Annual Operating Survey
 
Part of the reporting process for LIHTC projects includes completing the Annual Operating Survey, which is available here. The survey must be completed for each project awarded tax credits between 2006–2019 (project numbers that begin with “06” and end through “19”) and has 10 or more units. Completed surveys must be submitted to 811Program@ohiohome.org no later than Wednesday, March 1, 2023. Questions regarding the Annual Operating Survey may be directed to Kevin Clark at kclark@ohiohome.org.
2023 Compliance Training Dates Are Here. Don’t Miss Out!

OHFA will continue to offer free compliance trainings this year. The trainings will be in the form of webinars and in-person trainings. You are able to register for any webinar at this time. In-person trainings registration will open soon. All webinar trainings are from 12:30–4:30 p.m. In-person trainings will be held at the Columbus Main Library with the times to be announced.

Compliance Policies and Regulations Training
The training session will fulfill OHFA's Qualified Allocation Plan (QAP) training requirement in order to obtain IRS Form 8609 and provide four hours of continuing education credit for Specialist in Housing Credit Management (SHCM), Housing Credit Certified Professional (HCCP),National Compliance Professional (NCP), and National Compliance Professional-Executive (NCP-E) designations.
Acquisition/Rehabilitation Compliance Training
The training session will provide three hours of continuing education credit for the Specialist in Housing Credit Management (SHCM).
LIHTC Essentials Compliance Training
The training session will fulfill OHFA's QAP training requirement in order to obtain IRS Form 8609 and provide four hours per training (total of eight hours for both webinars) of continuing education credit for SHCM and HCCP certifications.
Be sure to visit the Training and Technical Assistance webpage for all future training dates and resources.