Appendix 2.xlsx

Summary

Development Name & Address Owner Entity Since: (Mo/Yr)

Property / Site Manager's Name Since: (Mo/Yr)

Management Agent Organization Since: (Mo/Yr) No. of Units: Occupancy ERROR:#DIV/0!

Type of Program IHDA No. Loan Position(s) Total

Program

Name / Title Date Title Date

Development's Description

Non-IHDA HUD Subsidies

Unit Composition

Additional Addresses

Number and Type of Bldg.

Comments to Findings/Review Questions:

Questionnaire

Part A: Maintenance & Security

1. General Physical Condition A C

I. Maintenance & Security Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part B: Leasing & Occupancy

b. Does the property have a written VAWA Emergency Transfer Plan?

d. Is rental staff familiar with AFHMP?

e. Does site signage include the EHO logo?

f. Is the EHO poster displayed in offices and model units?

h. Were the outreach efforts, as described in the AFHMP, performed annually?

Last outreach date:

White %

Black/African American %

American Indian/Alaska Native %

Asian %

Native Hawaiian/Pacific Islander %

Other %

Not Hispanic or Latino %

n. What staff positions are/will be responsible for affirmative marketing?

q. How many units are accessible?

2. Tenant Selection & Orientation A C

3. Vacancy, Turnover & Market Conditions

a. Does the development maintain a wait list of prospective tenants?

Was annual update letter sent to applicants as required?

Date update letter was sent to applicant

Was wait list purged? When?

How many are currently on wait list?

Is the wait list currently open closed

Does the wait list include all required elements?

Were the applicants selected in proper order from the waiting list?

b. Is surrounding neighborhood market prosperous, average, or depressed?

c. Are surrounding neighborhood conditions improving, stable, or declining?

d. Are the market conditions affecting occupancy?

e. Is there saturation of affordable housing?

3. Vacancy, Turnover & Market Conditions A C

II. Leasing & Occupancy Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part C: Training & Program Compliance

On-site (Frequency )

IREM NCHM HUD seminars Local colleges

Fair Housing training date

Energy conservation

Other (specify)

How are updates communicated?

4. Training A C

5. Program Compliance

a. Was the Consolidated Certificate of Compliance received?

When:

5. Program Compliance A C

III. Training & Program Compliance Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part D: File Review

Summary of Tenant File Review

Number of program units Number of files reviewed

Name Unit Name Unit Name Unit

c. Is there a file organization system?

Is it followed consistently?

6. Resident File Maintenance and Security A C

7. Household Information

b. Does the application contain sufficient information to determine eligibility?

c. Was all move-in screening completed per the Tenant Selection Plan?

If a household was ineligible at move in, were exceptions granted?

7. Household Information A C

8. Verification

a. Have all eligibility criteria been verified and properly documented?

8. Verification A C

9. Leases

a. Were the correct program leases used?

b. Were the leases signed and dated by all parties?

c. Were all applicable addendums/attachments added to the lease?

d. Were security deposits collected in the correct amount for the program type?

e. Were pet deposits charged according to the pet policy?

9. Leases A C

10. Inspections

10. Inspections A C

11. Certification/Recertification Activities

b. Was the Tenant Income Certification form (TIC) in the tenant file?

c. Were income and assets calculated correctly?

11. Certification/Recertification Activities A C

12. Move-Out File Review

a. Did the move-out files include the required documentation?

12. Move-Out File Review A C

13. Applicant Rejection Review

a. Did the applicant rejection letter include the required criteria?

b. If appealed, were criteria met?

13. Applicant Rejection Review A C

IV. File Review Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Instructions

Development name & address: include addresses for all buildings. Use summary page under Development Description if necessary for additional addresses.

If this is a scattered site, for example, use one address on the first page and list the remaining addresses in Development Description.

Owner entity: review management agreement, regulatory agreement, or audit. Use legal entity name.

Type of program: list all program types in senior loan position - i.e. HOME, Section 8 and/or Tax Credits. IHDA programs only - do not use abbreviations. Do not include LTOS, SRN or 811 here, as Rental Compliance does not monitor these programs. They are captured under Additional IHDA Program Units in the Development Description.

IHDA number: list all loan numbers by lien position (i.e. 17-2037-01), and IHDA TC number (federal & state). Use the Benedict numbering system, not the portfolio system.

Number of Program units: list for the highest IHDA position only

Transferred to AM: omit MLs. Obtain from DMS, Project Dates.

Year of construction: insert year built. Refer to project summary. If construction year is not indicated, ask owner/agent.

TC Expiration Date: when the Extended Use Period ends. See DMS>Award>LIHTC.

Name / Title: type the name of the AM who completed the review

Review Approved By: the approving Rental Compliance Supervisor will insert their digital signature into the PDF version of the final report.

Name / Title: type the name of the Rental Compliance Supervisor.

2. Create a “general finding” definition for each common finding throughout your file audit. List them all general findings first. The definitions are to be separate and used for a reference for the O/A on your MOR report. Example: General Finding A: 5 out of 10 files were missing income verifications; General Finding B: most files were using incorrect rent/income limits.

Finding a: The file does not contain the credit check, criminal background check, or sex offender screening for adult household member Dante, as required by the Tenant Selection Plan. Management must either complete all screening as indicated in the TSP, or revise the TSP to reflect actual practices in place. In response, certify that a credit check, criminal background, and sex offender screening will be obtain for all future adult applicants and retained in the tenant file.

Check for pass/fail for the most recent physical inspection. Inspection date, type, and results can be reviewed in DMS under Monitoring > Project Monitoring > Program Inspection. Copies of the inspections, if needed, can be found in T:\Asset\Portfolio\Applicable Year\Inspection. If there has not been an inspection for the current year, review prior years and enter the most recent inspection date. If development failed their inspection verify current status with field inspector.

PART B: LEASING & OCCUPANCY

If the property is using the IHDA TSP, the initial plan must be signed by IHDA, the owner, and agent. Subsequent plans must be signed by the owner and agent.

If the property is using a TSP reviewed by HUD, the HUD approval memo/letter must be attached. The TSP must be signed by the owner and agent.

If the property is not using the IDHA TSP, the IHDA approval memo must be attached. The TSP must be signed by the owner and agent. You may see this with new deals that are Housing Authorities, RAD deals, 811 deals, etc.

Review the plan utilizing the tab TSP Checklist-Other.

For 9% credits, this is noted on the reservation letter, which should be saved in the Initial Tax Credit Documents portfolio folder. In this example, this property's allocation falls under the 2018-2019 QAP:

For 4% credits, use the the date of the 42(m) letter. The 42(m) letter should be saved in the Initial Tax Credit Documents portfolio folder. In this example, this property's allocations falls under the 2020-2021 QAP:

2. Allows a tenant to transfer to a new unit when a safe unit is immediately available and the tenant would not have to apply in order to occupy the new unit

3. Describes policies for assisting tenants to make emergency transfers when a safe unit is not immediately available, both for situations where a tenant would and would not have to apply in order to occupy the new unit.

4. Describes policies for assisting tenants who have tenant-based rental assistance to make emergency moves with that assistance.

5. May require documentation, as long as tenants can establish eligibility for an emergency transfer by submitting a written certification to their housing provider, and no other documentation is required for tenants who have established that they are victims of domestic violence, dating violence, sexual assault, or stalking to verify eligibility for a transfer.

d. Answer question.

e. Only the fair housing logo is required.

If the waiting list is managed by another agency, such as a housing authority, and 100% of applicants must come from that waiting list, mark N/A and make a comment in the remarks column indicating why outreach was not completed.

If less than 100% of units must be referred from another agency (such as SRN units), the agent must maintain a list & perform outreach for those units that do not require referral.

i. A development that provides affordable housing should keep track of race and ethnicity in their development. Tax Credit deals have to do the tracking to comply with HUD. Racial mix must equal 100%. Ethnic mix must equal 100%.

j. Detail the least likely to apply groups from the current approved AMP in the remarks section.

k. Add in remarks the successful outreach efforts such as local exhibits or other additional outreach efforts.

p2. Review IHDA TSP Exhibit B. A transfer addendum is required for developments with accessible units. The addendum must be signed only by tenants who move in to accessible units but do not require the features. This requirement does not apply to developments with no accessible units or when all units are accessible.

q. Review Management Plan, or TSP. An Accessible Dwelling Unit is a unit that is approached, entered, and used by physically-challenged people.

Accessible features include: Wide doors, sufficient floor space for wheelchairs, lower countertops, lever and loop type handles hardware, seats at bathing fixtures, grab bars in bathroom, knee spaces under sinks and counters, etc. Most accessible features are permanently fixed in place.

An adaptable dwelling unit is one constructed and equipped so it can be converted with minimal structural change for the use by persons with different types and degrees of environmental limitation.

Adaptable features include: An Adaptable unit has features that are either adjustable or capable of being easily and immediately added or removed to "adapt" the unit to individual needs or preferences.

b./c. Determination of neighborhood market conditions should be made through both a visual assessment of the area by the asset manager, and a conversation with site staff. If conditions are other than stable/improving, explain how.

d. Market conditions that negatively affect the property should be indicated, i.e. job loss, college town, economic depression, location, etc.

e. If there is a saturation of affordable housing, explain how, i.e. two new senior developments are being constructed in the immediate area with more amenities, etc.

For Fair Housing, all properties must attend Fair Housing training. This should include office and maintenance staff. Recommendation is every 2-3 years.

Based on observations and conversation with staff during the review, make a finding or comment as necessary if extra training is needed for HOME, tax credits, etc.

b. Indicate in remarks column how management stays up-to-date with changes in HUD & IHDA policy.

Sample size: refer to the Federal Register Unit Table.

Random Selection

• Less than 100% LIHTC: selection is based on LIHTC units only

If the random selection does not include a move-in, request a file replacement from the rent roll. The selection should also include a move-out and rejection file.

b. Federal LIHTC regulations require that Owners retain records for each building in the project for at least 6 years after the due date (with extensions) for filing the federal income tax return for that year. The records for the first year of the credit period, however, must be retained for at least 6 years beyond the due date (with extensions) for filing the federal income tax return for the last year of the compliance period of the building. (From 8823 Guide, 2011 revision)

Ask how the owner is disposing of records. Are they being shredded, burned, etc.?

b. Applications must be date and time stamped upon receipt. Application should ask for household composition, age, student status, sources of income and assets, assets disposed of for less than fair market value.

c. Refer to the TSP (section V) to determine which screening management has indicated. Make a finding if the file does not contain documentation of the indicated screening.

d. Answer question.

e. Refer to the occupancy standards in the TSP.

d. The security deposit requirements, if any, vary. Discuss with the property to determine their deposit policy. Review the policy & compare to actual practice in place.

If a third party has paid the deposit on behalf of the tenant, the deposit amount must still be listed on the lease.

Include in Remarks section if rents exceed maximum rent level, missing or incorrect information on 50058 or TST-3 (TIC) forms.

100% LIHTC projects are not required to complete an annual recertification, unless combined with another program that has recertification requirements (i.e. Section 8). The recertification is for the applicable program, not for LIHTC. Student screening must still be completed every year.

Less than 100% LIHTC projects must complete a recertification annually, effective on the anniversary date of move-in.

b. The move-in certification and current three years must be retained in the active tenant file. Older years may be stored in an archived file, but must be made available at the auditor's request.

TSP Checklist - Other

https://www.hud.gov/sites/documents/15-01HSGN.PDFhttps://www.cookcountyil.gov/content/just-housing-amendment-human-rights-ordinancehttps://www.cookcountyil.gov/content/just-housing-amendment-human-rights-ordinancehttps://www.hud.gov/sites/documents/HUD_OGCGUIDAPPFHASTANDCR.PDFhttps://www.justice.gov/crt/executive-order-13166https://www.hud.gov/program_offices/fair_housing_equal_opp/disabilities/sect504faqhttps://www.hudexchange.info/programs/home/home-final-rule/section-by-section-summary/subpart-a/https://www.hud.gov/sites/documents/HUD_OGCGUIDAPPFHASTANDCR.PDFhttps://www.hud.gov/sites/documents/HUD_OGCGUIDAPPFHASTANDCR.PDFhttps://df7qosnywqs6g.cloudfront.net/wp-content/uploads/2019/10/2020-2021-QAP-Final.pdfhttps://www.hud.gov/sites/documents/USEOFMARIJINMFASSISTPROPTY.PDFhttps://www.chicago.gov/content/dam/city/depts/cchr/AdjSupportingInfo/AdjFORMS/2016%20Adjudication%20Forms/2016MilitaryStatusDiscriminationFactSheet.pdf image1.emf image2.png image3.png image4.png