December 24, 2024

Note: Any questions on the content of this message must be directed to OHFA’s Compliance and DevCo Helpdesk.

It’s That Time Again:

Be Prepared for Annual Owner Certification Reporting!

The 2024 reporting year Annual Owner Certifications (AOCs) are due March 1, 2025. However, owners/management agents may submit AOCs now rather than wait. Below are a few reminders to prepare for AOCs submissions:

• All tenant events must be updated in DevCo by no later than the 10th of each month in preparation for submitting AOCs. Management agents also need to update all tenant events when notified of an upcoming file audit.

• Utility allowance (UA) information must be updated in DevCo annually. Here are instructions (Section V) on how to update your project’s UAs.

• Additional information on the submission process may be found in the Multifamily Annual Owner Certification Requirements.

• Information on .XML uploads may be found in the XML Uploads Features Summary. 

• Make sure necessary staff members responsible for completing AOCs have access to DevCo. Here are instructions on how to get access to the DevCo database. If any assistance is needed, contact OHFA’s Helpdesk.

Code Violations

Owners/Management agents are reminded of their responsibilities under Treas. Reg. §1.42-5(c)(1) (Regulation). Pursuant to this regulation, AOCs are due annually to OHFA and such certifications are made under penalties of perjury. Code violations must be reported in AOCs. Further information may be found here.

Annual Operating Survey

Part of the annual reporting process for LIHTC projects includes completing the 2024 Annual Operating Survey, which is available here. The survey must be completed for each project awarded tax credits from 2007–2021 (i.e., project numbers that begin with “07” through “21”). Completed surveys must be submitted to PortfolioMailbox@ohiohome.org no later than Monday, March 3, 2025. Questions regarding the Annual Operating Survey may be directed to Kevin Clark at kclark@ohiohome.org.

HOTMA Update

OHFA’s IT Office is working on necessary changes to the Tenant Income Certification (TIC), including HOTMA’s HUD adjustment factor amounts and the NAHMA 8.0 standards. More information on the NAHMA standard is found here. OHFA anticipates the updated TIC will be published in the coming weeks. As OHFA establishes a firmer completion date on these updates, additional communications will be issued. While OHFA will implement HOTMA on January 1, 2025, mandatory use of HOTMA rules will only be applicable for initial tenant certifications and recertifications effective on and after May 1, 2025. Because all verifications must be dated within 120 days of the effective dates of household certifications, verifications effective between January 1 and April 30, 2025, may use “pre-HOTMA” rules.

For example, if a certification is due in April 2025, the paperwork should be started in December 2024 and can use pre-HOTMA rules. For a certification effective May 1, 2025, the paperwork should be started January 1, 2025.

Because the OHFA TIC will not be HOTMA compliant for the next couple of weeks, management agents beginning to qualify applicants on 1-1-2025, should continue to use the OHFA TIC in DevCo and place a clarification record in the file outlining the asset/income calculations. 

OHFA will not take enforcement actions (i.e., issuance of 8823’s) for any HOTMA file deficiencies prior to July 1, 2025, which includes initial tenant certifications and recertifications effective between January 1 and June 30, 2025. Any HOTMA file deficiencies found prior to July 1, 2025, will be noted as general comments on the first page of OHFA’s Compliance Audit Report (CAR). OHFA will not require owners/management agents to correct deficiencies found prior to July 1, 2025. 

NSPIRE Update

HUD has delayed its official NSPIRE implementation deadline for assessing physical conditions until October 1, 2025. OHFA continues to review different NSPIRE-compliant inspection software options with newer options to be tested. OHFA’s top priority with this transition is to identify and implement processes that are as similar to current methods as possible so that owners/management agents may be inconvenienced as little as possible. In pursuing this goal, OHFA will postpone adoption of NSPIRE until or unless further notice is issued. In the meantime, OHFA auditors will continue using UPCS protocols for on-site physical inspections. OHFA values and appreciates your efforts and patience as it continues navigating through the NSPIRE inspection protocols. 

Upcoming Trainings

OHFA along with the Ohio Capital Corporation for Housing (OCCH) are proud to sponsor an NSPIRE training with an optional NSPIRE-ACE Certification exam. The training will be a one-day in-person training conducted by US Housing Consultants in Westerville, Ohio, on March 18, 2025. For further information and registration details, click here. 

Industry partners may also want to check the following websites for upcoming 2025 trainings: 

• Costello Compliance
• US Housing Consultants
• OCCH Home | Affordable Housing Training Institute
• Midwest Affordable Housing Management Association

Stay Informed! 

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