The Tax Credit Assistance (TCAP) and Tax Credit Exchange (TCE) Programs have been critical to the continued development of affordable housing. In creating programs to assist with the continued development of housing and the stabilization of neighborhoods, Congress imposed specific compliance requirements. Projects funded with TCAP or TCE funds, even if there are no tax credits in the project, must remain in compliance and operate as “traditional” tax credit projects. In addition to meeting all tax credit rules and regulations, projects must comply with all restrictions outlined in IHFA TCAP/TCE Regulatory Agreements. IHFA is required to perform asset management for these projects. Additionally, please be aware that IHFA is also responsible for LIHTC compliance monitoring for these projects. These two functions are distinct and different and will not be performed by the same IHFA Compliance Staff.
The executed TCAP and/or TCE Regulatory Agreement outline the specific Asset Management Requirements required by IHFA. Specific attention is given to the following:
- Occupancy restrictions outlined
- Staff units
- Percentage of units to be rented to the various income limitations
- Preferences for wait list positioning
- Supportive services
- Quarterly financial and project reporting requirements
- Affirmative Fair Housing Marketing Plan requirements
- Yearly submission of proposed rental rates and budgets
- Creation of separate accounts to hold security deposits and replacement cost reserves
- Monthly deposit requirements into the replacement cost reserve account
- Requirements for making changes to the management agent of the property
- Submission of the annual financial statements
- Submission of monthly occupancy reports (if applicable)
- Move in, annual, and other inspection requirements
What’s New
Submission of proposed budgets and rents for the next fiscal year are due
According to your regulatory agreement, for all TCAP and Exchange sites, “…The Housing Sponsor shall submit a proposed schedule of rental rates and a proposed operating budget for the project to the Allocating Agency at least once a year and not less than sixty (60) days prior to the beginning of each fiscal year…”
If you have not already done so, Please submit these ASAP to:
IHFA
Attn: Katie Kilgrow
P.O. Box 7899
Boise ID, 83707
Email: katiek@ihfa.org
Asset Management Forms and Manuals
HUD Guidance
HUD’s TCAP webpage
TCAP Guidance on Fees and Asset Management
Quarterly Reporting
Annual Reporting
Memos
Owner/Agent Changes
Tax Credit Exchange Program
Another part of the American Recovery and Reinvestment Act of 2009 is the Tax Credit Exchange Program, which funds projects for construction or acquisition and rehabilitation of low-income housing to continue where developers are unable to proceed due to lack of investors. In this way, the near-term goal of creating and retaining jobs is achieved, as well as the long-term benefit of increasing the affordable housing supply.
For more details on the TCAP Plan or the Tax Credit Exchange Program, please click on the following links:
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