Managing Blended AR S

Transcription

1 41 st Annual Seminar & Tradeshow May 20 22, 2018 LAX Mariott Managing Blended AR S The right benefits go to the right persons It is the responsibility of every owner, management companies and managers (including their staff) of a HUD assisted housing property to ensure that eligible families lease the correct units and pay the correct amount of rent. 1

2 Why do we have to do ALL This paperwork for Tax Credit?? Chapter 4 states that a determination of annual income of individuals must be done PRIOR to move in. Households must qualify for ALL programs. What is a Blended Property? Blended or Layered Property What is program layering? Affordable housing is made of up of different financial layering in order for the property to receive subsidies, funding, bonds, or tax credits. Each property has different layers of funding. The regulatory agreements for the property define what those funding programs are and what the regulatory or compliance requirements are. 2

3 Section 8 and Tax Credit Today we will focus on two major programs at one property Project Based Section 8 (HUD) Tax Credits (LIHTC) Annual Recertification Interview We are required to complete an annual recertification for each household. We have the advantage to review previous year annual certification. We should not assume that family circumstances or even family composition is the same as the last year. We should compare the new information provided by the family to the information in the file. We should look for changes in family composition, income sources and amounts as well as dates of birth and social security numbers for all family members. A discrepancy may suggest additional questions that should be asked. Process AR on a timely manner Why? HUD handbook 7 6 clearly indicates that it is the owner s responsibility to process all recertifications in a timely manner. If a new recertification is not submitted within 15 months of the previous year s recertification anniversary date, HUD will terminate assistance payments. LIHTC Requires the AR 3

4 Does this resemble your day to day? In order to be able to accomplish your everyday task and the AR on time, it depends on one major key element... ORGANIZATION! Preparing for Interviews Once your AR is with 5 months from the effective date, you should start preparing as follow: Print your AR First Reminder Notice Fill out First Reminder Notice Prepare Appointment Log &/or Calendar Prepare Recertification Log (Electronic) Make a copy of the First reminder notice and place in the folders Send letters at least 120 days before AR effective date How should I prepare? What documents should I have ready? Print out 3PV, make copies Print questionnaires (HUD and TICQ), make copies Print 9887 place addresses in the 3 boxes, make copies Print 9887A, make copies Child Support/Student Certification Prepare addresses labels for 3PV 4

5 What else? Get your stamps in Federal Government Information Requested. Please Return Within 5 Days See Attached Date Received Property Name Property Name and Address Get Postage EIV... EIV... EIV... Print out EIV Reports on day 120 (not before!) Income Report Summary Report Income Discrepancy Get EIV Labels Suggestion I Agree I Disagree Date Signature What are these logs you talk about??? You should develop: Appointment Log 3PV and Documentation Tracking Log Completion log Software tracking?? The logs helps you keep organize and provides you a current status as to where you are with your recertification 5

6 Conducting Interviews Go over your questionnaire with the tenant Review last year s AR's and all the IR's in between, then compare with the questionnaire Sign the 9887/9887A and LIHTC release and consent form Get the verifications needed and obtain signature Collect review of documents Log information on the AR log At the end of the day, mail out the verifications with self address envelopes. Verification Hierarchy Section 8 vs. Tax Credit Section 8 Types of third party verification in order of acceptability (4350.3, 5 13) a. Upfront income verification (UIV) b. Third party verification from source (written) c. Third party verification from source (oral). d. Family Certification. Tax Credit Verification a. Third party verification from source (written) b. Review of Documents EIV Section 8 vs. Tax Credit Section 8 Must use EIV (not available at movein) Tax Credit Can ever ever, ever, ever, ever use EIV. When can you use EIV for Tax Credit? NEVER 6

7 Verification Hierarchy Important for Tenant Provided Documents! (4350.3, 5 13) Is the document current? Is the documentation complete? Is the document an unaltered original? Photocopied documents generally cannot be assumed to be reliable. Wages Section 8 vs. Tax Credit Section 8 When using pay stubs to document employment income the applicant or tenant must provide the most recent four to six, consecutive pay stubs (actual paycheck not acceptable does not show gross). Tax Credit Must use most recent consecutive three months pay stubs Must complete all four calculations at Move-in and use highest calculation Social Security Verification Section 8 vs. Tax Credit Section 8 When verifying information over the telephone, it is important to be certain that the person on the telephone is the party he or she claims to be. Generally, it is best to telephone the verification source rather than to accept verification from a source calling the property management office. Oral verification must be documented in the file. Tax Credit Verbal verifications are not acceptable in Tax Credit. Verbal telephone clarification of existing documentation acceptable for minor issues relating to dates or blanks. If verbal clarification would reduce the income calculation, third party clarification must be obtained. 7

8 Calculate income Calculate all verifications and place in the tenant s folder. Make sure to place a calculation tape with verification. Once all the verifications have been received for the unit, mark off the recertification log. Send 2nd attempt after week one has passed from first attempt. Wait another week and send 3 rd attempt. After 3rd week, use review of documents and place clarification record with verifications attempt. After Income is Calculated Enter and update information in the software. Send notice to tenant to come and sign the HUD and and TIC along with the 30 day notice of Rent Change. This should be done at least 45 days before the effective date for HUD. By day 90, all HUD s should be signed and dated. All HUD s must be signed and dated by all parties before the voucher is sent. Update your Recertification logs to show completed. What if they fail to recertify? If tenant fails to meet appointment based on the first reminder notice, send them a second reminder If they fail to make appointment, send them third reminder which states that their assistance will be terminated and they will pay the HUD Market Rent If the household fails to recertify for TCAC; tenancy is terminated. 8

9 What's next? Once you obtain all your signatures: Organize the files according to your set up You should place the cover sheet and make sure its shows the correct effective date Put the files away for next year... Remember in order to successfully manage the AR process you must... Be Organized, keep track, and did we say BE ORGANIZED?! 9