The State of Ohio received a Major Disaster Declaration in response to the COVID-19 pandemic on March 31, 2020 (DR-4507). While guidance related to Low-Income Housing Tax Credits and other sources of funding continues to be released by the federal government, the Internal Revenue Service (IRS) has indicated that Housing Credit agencies in states with a federal Major Disaster declaration can rely on relief measures provided in Revenue Procedure 2014-49 (Rev. Proc. 2014-49).

Under Sections six and seven of Rev. Proc. 2014-49, agencies may grant extensions to both the ten percent test requirement deadline (up to six months) and the placed in service deadline (up to 12 months) for projects whose owners cannot reasonably satisfy the deadlines of § 42(h)(1)(E) because of a major disaster.

The Ohio Housing Finance Agency (OHFA) will grant Carryover Allocation relief to eligible projects on a case-by-case basis. To be eligible, projects must have a demonstrated and documented need and must meet the requirements outlined in Rev. Proc. 2014-49 and described below:

  • Owner has a carryover allocation for a building located in a Major Disaster Area;
  • Owner cannot reasonably satisfy the deadlines of § 42(h)(1)(E) because of a Major Disaster;
  • For ten percent test relief, the project has a ten percent test deadline of January 20, 2020 or later as indicated in the carryover allocation agreement; and
  • For placed in service relief, the project has an Allocation Date of March 31, 2020 or earlier as indicated in the carryover allocation agreement.

To submit a carryover relief request:

  1. Download the Letter Template for Carryover Relief.
  2. Complete the template with information specific to the eligible project.
    1. Requests for more than one project may not be combined in one letter – a separate letter must be submitted for each eligible project.
    2. Sign the letter.
  3. Email a PDF of the signed letter to kbanyai@ohiohome.org.

OHFA staff will acknowledge receipt of your extension request and will be in contact with next steps once it has been reviewed and approved.