August 20, 2025

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

Tenant Recertifications — What Documents are Required?

OHFA has received several inquiries as to what is required in tenant files for recertifications. Due to the Housing and Economic Recovery Act (HERA) of 2008, owners/management agents of 100% LIHTC projects are no longer required to conduct annual income recertifications. However, for mixed-income projects (i.e., market rate), tenants’ incomes must be verified annually. 

Following is what OHFA requires in tenant files for LIHTC projects: 

Note: Owners/management agents of projects in the extended use period are not required to complete OHFA’s Student Status Certification form. However, OHFA highly recommends it be completed, especially if owners may want to resyndicate the project in the future.  

For LIHTC projects with HOME-, RD-, or HUD-assisted units, owners/management agents must follow the recertification rules as outlined in those program regulations. 

OHFA’s Zero Income Verification Form

Effective September 1, 2025, for initial certifications or recertifications (only for mixed-income projects) owners/management agents must use OHFA’s Zero Income Verification form for applicants/tenants claiming zero income. While there is information on OHFA’s Applicant/Tenant Sworn Income and Asset Statement, which asks if applicants/tenants receive recurring — even if sporadic — non-monetary in-kind donations from outside their households, or if they receive recurring payments from persons not living in the same units, the zero income form outlines more detailed information for how items are paid. Often times, applicants/tenants do not realize certain things are considered recurring funds being provided to them, but when asked specifically, they disclose the income. Use of the zero income form will help to ensure applicants/tenants are truly without anything considered income. 

Note: While the zero income form is not new, OHFA has found some management agents use the form while others are not. Owners/management agents who fail to use the form for zero income households will be cited for noncompliance.  

New HOTMA Adjustment Factors — Heads Up!

The HOTMA rule requires certain amounts used to make income, asset, and eligibility determinations be annually adjusted by an inflationary factor. On August 1, 2025, HUD issued new adjustment factors that will become effective January 1, 2026. The new adjustment factors will apply to all OHFA-funded projects. The adjustment factors can be found here.

OHFA Implementation of the 2025 HOME Final Rule — Coming Soon!

The 2025 HOME Final Rule was published on January 6, 2025, and is found here. After certain delays and revisions by HUD, the regulatory changes implemented through the 2025 HOME Final Rule went into effect on April 20, 2025.

Note: HUD allows a one-year compliance period for participating jurisdictions (PJs)/HFAs to implement the new Rule no later than April 20, 2026. HUD also allows flexibility to apply most provisions of the Rule for all HOME projects as long as it is addressed in the PJs’ written policies or compliance manual. With this said, OHFA will retroactively implement all provisions of the Rule (with the exception of the new tenant protections, which HUD delayed until October 30, 2025) to all HOME-funded projects on October 1, 2025. The use of the new HOME Rule is mandatory for initial certifications and recertifications that become effective February 1, 2026. The new Rule will also apply to HOME-ARP and Ohio Housing Trust Fund (OHTF) projects. 

OHFA will issue additional guidance next month. Until OHFA implements the new Rule, owners/ management agents should continue following all provisions as outlined in the 2013 HOME Final Rule. 

Upcoming Events — Don’t Miss Out!

MAHMA Hot Topics Conference: Save the Date!

Want to know what the latest changes in the industry mean for you? Come join OHFA staff and your industry colleagues at the Midwest Affordable Housing Management Association (MAHMA) conference in Cleveland, Ohio, on September 11, 2025. Further information and registration can be found here.

LIHTC Training 

OHFA is proud to sponsor a Conquering LIHTC Compliance (with Optional A.C.E. Exam) training. US Housing Consultant's Housing Compliance Trainer Randy McCall will delve deep into the LIHTC laws and regulations, including the HOTMA Rule, while also providing real-world examples with practical applications. The two-day in-person training will occur in Westerville (a suburb of Columbus), Ohio, on September 23–24, 2025. 

Stay Informed! 

Subscribe to OHFA’s email distribution list, which allows you to receive important notifications concerning regulatory and policy changes, development updates, and much more. Please forward the subscription link to any of your staff who may benefit from this type of information.

Reminder to all 811 project owners/management agents: Stay in the know! You can now sign up to receive 811 updates through OHFA’s email distribution list. Be sure to select Ohio 811 PRA under Email Lists on the sign-up form.