Appendix 3.xlsx

Summary

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

Name / Title Date Name / Title Date

Additional Addresses

Number and Type of Bldg.

Have all findings from prior management/desk/tenant file reviews been resolved? YES

NO

N/A

Comments to Findings/Management Review Questions:

Questionnaire

Part A: Maintenance

b. Which type of inspection was completed?

1. General Physical Condition A C

Part B: Financial Management

b. Date of last rent adjustment:

d. Was the annual utility allowance analysis submitted?

2. Rent Schedule Compliance A C

Part C: Leasing and Occupancy

a. Date TSP executed by owner/agent:

Does the development have any unresolved TSP findings?

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?

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?

p. In accordance with the Fair Housing Act:

q. How many units are accessible:

3. Tenant Selection and Orientation A C

4. Vacancy, Turnover, and Market Conditions

a. Is the vacancy rate greater than 30% of total units?

b. Has the development had significant turnover?

Security problem Poor maintenance

Noncompetitive amenities Rents too high

Inadequate marketing Location

Development reputation Lack of demand

Bedroom mix/size ( bdrm hard to rent)

Tenant/management relations Other

e. 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?

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

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

h. Are the market conditions affecting occupancy?

i. Is there saturation of affordable housing?

4. Vacancy, Turnover, and Market Conditions A C

Part D: Training and Program Compliance

On-site (Frequency )

IREM NCHM HUD seminars Local colleges

Fair Housing training date

Energy conservation

Other (specify)

How are updates communicated?

5. Training A C

6. Program Compliance

a. Was the Consolidated Certificate of Compliance received?

When:

HOME ONLY

b. Was the Tenant Profile Compliance Report (form TST-2) received?

When:

6. Program Compliance A C

Part E: File Review

Summary of Tenant File Review HOME, NHTF, TAX CREDIT ONLY

Number of program units Number of files reviewed

Name Unit Name Unit Name Unit

7. Resident File Maintenance and Security

c. Is there a file organization system?

Is it followed consistently?

7. Resident File Maintenance A C

8. 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?

8. Household Information A C

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

9. Verification A C

10. 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?

10. Leases A C

11. Inspections

11. Inspections A C

12. Certification / Recertification Activities

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

c. Were income and assets calculated correctly?

d. Were the correct rent and income limits used?

12. Certification / Recertification Activities A C

13. Move-Out File Review

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

13. Move-Out File Review A C

14. Applicant Rejection Review

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

b. If appealed, were criteria met?

14. Applicant Rejection Review A C

Instructions

Development name & address: include addresses for all buildings. Use Development Description area of summary page 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.

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

Date of last annual inspection: insert the date of the most recent on-site management review. This does NOT include the physical inspections. These inspections are addressed in part A.

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

Maturity date: obtain from Benedict.

Tax Credit expiration date: insert the end date for the extended use period. Find in DMS: Award -> LIHTC tab -> Extended Use Expiration

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

Name / Title: type the name of the AM who completed the review; adjust title for Senior AMs

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.

Additional addresses: self explanatory

Work out & additional comments: refinance, loan modification, transfer of physical assets, Owner or Agent changes, market changes. Review current Loan Monitoring Agenda.

Have all findings from prior reviews been resolved: List any outstanding/unresolved findings from the prior review (limited to the prior year). If there are outstanding findings, include specific findings. Unresolved code violations, audits, TSP and AMP updates, budgets, or tenant file audits, will result in an automatic Below Average or Unsatisfactory based on the number of findings.

b. All properties are required to have a physical inspection based on the program type. If there has been no inspection in the past three years, contact your field inspector. The appropriate inspection type should be selected based on the applicable program:

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.

b. For NHTF and HOME see DMS. For Other Programs use effective date of Owner's rent schedule. If current data is not in DMS, e-mail CA for update.

PART C: 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. HOME, Mod Rehab, NHTF, and 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.

f./g. 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.

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

i. 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.

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. HOME requirement: Individual tenant income, rent, and inspection information must be kept for the most recent five year period through the affordability period and five years after it has concluded. (From HOME Guide for Owners, paragraph 3.7, p83)

Tax Credit requirement: 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. Is this complete on the TIC? No specific reporting form required.

e. Applicable for properties built prior to 1978 and elderly properties built prior to 1978 that house children under the age of six.

f. 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 TIC.

HOME projects must complete a full recertification with source documentation every six years of the affordability period. Self-certification may be acceptable for the certification years between.

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