Good afternoon Program Participants and other Interested Parties,

New and/or Updated Compliance Forms:

Multifamily Programs has made changes to our required compliance forms. These modified forms can be found at  https://thda.org/business-partners/housing-credit-compliance.

Household Income Certification (HIC HO-0420)

  • This is the former Tenant Income Certification (TIC)
  • A disclosure added to the Household Certification and Signatures section notifying residents of THDA’s obligation to submit household data to HUD annually.
  • Updated income restriction options in Part V determination of income eligibility and Part VI rent for the Average Income set-aside option beginning in 2019.
  • Update to instructions of Part II – Household Composition to align with HCMS and HUD reporting options.

Continuing Residency Certification (CRC HO-0489)

  • A disclosure added to the Household Certification and Signatures section notifying residents of THDA’s obligation to submit household data to HUD annually.
  • Updated income restriction options in Part V determination of income eligibility and Part VI rent for the Average Income set-aside option beginning in 2019.
  • Update to instructions of Part II – Household Composition to align with HCMS and HUD reporting options.

Exhibit B was expanded to Exhibits B-1 & B-2

Exhibit B-1: Transfer or Sale of Ownership Interest (HO-0419)

  • Exhibit B-1 is used for ownership changes
  • Exhibit B-1 has a version for multiple ownership entities
  • Ownership contact information has been expanded
  • Management company changes have been added
  • The THOMAS authorization request has been added

Exhibit B-2: Managing General Partner Change or Transfer of General Partner Interest ( HO-0419)

  • Exhibit B-2 is used to document and update managing/general partner changes
  • Exhibit B-2 was also expanded to include the managing partner contact information.
  • Management company changes have been added
  • The THOMAS authorization request has been added

Employment Verification Form and Process

THDA has been made aware that property management companies are not using the THDA Employment Verification form (HO-0422) as the primary method to determine employment and employment income when qualifying households. Ownership entities and property management companies are strongly encouraged to use this form as the primary method of verification. The THDA Employment Verification form has been modified and eliminates the collection of Year to Date Earnings. When properly used as a verification form, Year to Date Earnings should not be disclosed by the applicant’s employer. This allows ownership entities and property management companies to anticipate the applicant’s income over the next 12 months including disclosures of salary increases, bonuses, overtime wages, commissions, etc.

If the applicant’s employer will not complete the THDA Employment Verification form, ownership entities and property management companies should document the applicant’s file with a note explaining why the THDA Employment Verification form was not used. When ownership entities and property management companies use paystubs and third party work verification lines to confirm employment and wages; the situation changes. Information contained on paystubs and third party work verification forms cannot be ignored. If the Year to Date Earnings are disclosed, that information must be investigated should it indicate the earnings would be higher than the income limits. Also, ownership entities and property management companies should question applicants as to future salary increases, bonuses, overtime wages, commissions, etc.

Guidance on the THDA Employment Verification form can be found on the THDA website at https://thda.org/business-partners/housing-credit-compliance.

Customer Complaint Posters

THDA’s Program Compliance required the use and posting of Customer Complaint Posters at Low Income Housing Credit properties. The information was memorialized in Qualified Allocation Plans however, there was no enforcement ability in IRC Section 42. In late 2016, that practice was discontinued. In late 2018, THDA’s Call Center was also discontinued. Please remove the Customer Complaint Posters from your properties. Should a resident have a complaint, they should discuss the situation with the property management company and the ownership entity.

From the entire team at THDA, we wish all of you, and your families, a very Happy Thanksgiving!

Thank you,

Chuck O’Donnell
Compliance Manager – Multifamily Programs
Tennessee Housing Development Agency
502 Deaderick Street, Third Floor
Nashville, Tennessee 37243
(615) 815-2215
www.thda.org