Ohio Housing Finance Agency       57 East Main Street | Columbus, OH 43215
IRS Issues Notice Providing Temporary Relief
On July 1, 2020, the Internal Revenue Service issued IRS Notice 2020-53 providing temporary relief to owners and residents of Housing Credit and tax-exempt bond financed developments in response to the COVID-19 pandemic. The guidance is effective immediately. Specific provisions of the notice include, but are not limited to:
  • Suspending the owner requirement to perform tenant income recertifications for the period beginning April 1, 2020, and ending December 31, 2020;
  • Suspending the Housing Credit allocating agency requirement to conduct compliance monitoring inspections or reviews for the period beginning April 1, 2020, and ending December 31, 2020;
  • Allowing temporary closure of property amenities or common areas during the period from April 1, 2020, to December 31, 2020, in response to the COVID-19 pandemic without resulting in a reduction of the eligible basis of the building; and
  • Allowing medical personnel or other essential workers providing services during the COVID-19 pandemic to temporarily occupy Housing Credit units in accordance with the emergency housing provisions of IRS Revenue Procedures 2014-49 and 2014-50.
OHFA will be issuing its guidance regarding the newly published IRS guidance by the end of July.
 
IRS Issues Proposed Regulations for Housing Credit Compliance Monitoring
On July 7, the IRS also issued a proposed rule, IRS/Treasury REG-123027-19, regarding Housing Credit Compliance Monitoring Regulations. The proposed regulations relate to the sample size Housing Credit Agencies must monitor for program compliance, both physical inspections and low-income certification reviews and permits agencies to monitor the lesser of 20 percent of the units in a building or the number provided in the Minimum Unit Sample Size Reference Chart.  
 
Written or electronic comments can be submitted until September 8, 2020. Commenters are encouraged to submit their comments electronically via the Federal eRulemaking Portal at https://www.regulations.gov/ (search for Reg-123027-19). Follow the online instructions for submitting comments.
Other Compliance Updates
Student Certifications
 
The OHFA student certification form has been updated and is effective 9/1/2020. Thank you to one of our partners who spotted an error on our form for correction. The updated student certification form is now available on the OHFA website. 
 
OHFA Inspection & DevCo Systems 
  • Instructions on how to upload documents into the OHFA Inspection system are available on the OHFA website.
  • DevCo Tenant Events: Please remember to ensure that all tenant events are updated, at a minimum, on a monthly basis as required.
Extended Use Properties 
  • OHFA permanently ceased issuing Notifications of Transition to Extended Use letters in 2020. Please refer to your restrictive covenant and 8609's for extended use information. If you need further assistance, please email OHFA's Compliance Division at compliance@ohiohome.org.
HUD 811 Project Rental Assistance (PRA) Program
  • OHFA recently issued a "quick guide" for property managers working with the Ohio 811 Program. This document contains brief reminders regarding several aspects of program units, including handling referrals, the application process, the Tenant Selection Plan Addendum, and reporting leased and vacant units. Questions may be directed to the Ohio 811 Program mailbox at 811Program@ohiohome.org. 
HOME and NHTF Rent Increases and Rent Approvals
  • Rent increases on HOME and NHTF units are limited to $25.00 or less for existing residents, effective immediately. Rent increases may only occur at recertification and may only be increased once during any given calendar year. New move-ins are permitted to start at the maximum HOME or NHTF rent amount allowable.
  • HOME rent & Income limits were released with an effective date of 7/1/2020. The rent approval form must be submitted within 30 days of July 1st, 2020. The new rent and income limits can be found on OHFA's website. 
  • The updated form for HOME & NHTF rent approvals is now available on OHFA's website. 
  • Updated HDAP/HOME MATRIX
    Please note that effective on 9/1/2020, all HDAP-funded projects will require 2 months of salary history for employment verification. This change should help to simplify the verification process for HDAP-funded projects, as the verification process will now be the same for all funding types. You can find the new matrix on OHFA's website.
Income Verification During COVID-19
  • OHFA advises owners/managers to include any/all hourly employer payments for "hazard pay for COVID-19," until there is a verified end date. Please see the chart below regarding included and excluded income.
 

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