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Importantly, verification rules for HOME or NHTF units with either Project-based Rental Assistance (PBRA) or Tenant-based Rental Assistance (TBRA) have significantly changed. For the initial and subsequent recertification years of the affordability period:
- HOME and NHTF units with PBRA must use income determinations by a state or federal rental assistance program.
- HOME units with TBRA may use income determinations by a state or federal rental assistance program (e.g., housing choice voucher). HUD allows a participating jurisdiction (PJ), such as OHFA, flexibility as to whether to accept this form of income determination. OHFA will accept this form of verification
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- NHTF units with TBRA must use income determinations by a state or federal rental assistance program.
OHFA’s Student Certification form must be used for all years of the affordability period regardless if a project has subsidies or not.
NOTE: If a PJ, such as OHFA, is required (or in the case of TBRA) chooses to use income determinations for a rental assistance program, then the sixth-year requirement of full recertification does not apply {24 CFR 92.203 (b)(iii)} (2024). This is applicable to both HOME and NTHF projects.
Units funded by HDAP Ohio Trust (OHTF) will follow HOME verification rules.
Asset Certification
Per 24 CFR § 93.151(e) (1), households may use the self-certification in 24 CFR §5.618 to certify that their net family assets are below the threshold for purposes of imputing asset income. For asset self-certification, owners/management agents must use OHFA’s $50,000 in Assets Self-certification form, which will be amended yearly to reflect HUD’s inflationary adjustments.
Additional HOTMA guidance can be found in our October industry message: OHFA HOTMA Implementation Guidance & OHFA Forms Additional Guidance.
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