Ohio Housing Finance Agency published the following updates for property owners who are interested in utilizing the Income Averaging (AI) set aside.
- Final IA Policy. Final IA election requirements are new set forth in the 2019 Technical Amendments to the Qualified Allocation Plan and cover topics like opt-in timing, resyndication implications, design requirements, and compliance monitoring.
- 2018 Final Apps. OHFA is eager to see a number of our 2018 HTC recipients will be using this new test; as a reminder, if you are planning to submit a final application with the IA option, you must contact OHFA for a customized final AHFA.
- Restrictive Covenant Alert. Developments that were awarded credits prior to the 2018 funding round may elect IA at 8609. If you intend to do so, do not record a restrictive covenant until consulting with OHFA staff. A new restrictive covenant template is now available incorporating this option. Developments that already recorded an older version of the covenant will still be permitted to make the IA election (if they have not received an 8609 form) but will not be able to change rent and income restrictions from what is contained in the recorded document.
- IA Form Posted. The IA Acknowledgement form is also now available online. This form is required for all developments that anticipate using the IA option but did not apply under a QAP that contained the necessary guidelines implementing it. For all 2018 developments (both 9% and 4% credits), this must be submitted with the final application. For earlier developments, this must be submitted with the 8609 request.
- Compliance Monitoring Fee. Finally, OHFA wishes to notify its partners that it does not anticipate increasing the compliance monitoring fee in 2019 for developments that make the IA election. We continue to assess the financial implications of this option and reserve the right to make future modifications to the fee structure as may be necessary.
