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Real Estate as an Asset

Posted on: July 18th, 2019 by Christa Landram No Comments

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Under Section 42, all assets must be accounted for, with the exception of assets that have been disposed of more than two years ago. Real estate is an asset that must be counted. Since there are a few types of real estate, it can be confusing how to calculate the value.

To determine the asset value of real estate that has been sold at market value, the cash value of the property and the imputed value (if it exceeds $5,000) must be calculated. Once that is completed, the higher value is used. The cash value is determined by taking the actual value of the property and deducting the outstanding mortgage, closing costs, and any other applicable fees.

A household using their own real estate as a rental property may apply to live in your property. When dealing with this scenario, two calculations must be done. The cash value must be determined as noted above. The second calculation is determining the monthly income that is received for rent on their real estate. The actual income received is not what is included. Management must take that amount and subtract the mortgage and any applicable maintenance fees.

If real estate has been foreclosed on, then it will not be considered in the asset calculations as the tenant will not be receiving income from the foreclosure. However, keep in mind that until the foreclosure is complete, the real estate is sold at an auction, or the title has been transferred to another party, the real estate is still technically considered the tenant’s.

The real estate may have gone through a short sale.  In this case, it is typically not considered an asset, as most often, the owner will not be receiving income from this. However, if there is a difference in the sale that is in favor of the resident, that difference is counted as an asset.  Also, it must be verified by a third party if it is a HOME project and if it exceeds $5,000 for LIHTC.

One final note is in regard to reverse mortgages. These are similar to a loan since the income from this must be paid back. Keep in mind that the real estate would still need to be treated as an asset and calculated accordingly. The calculation for the cash value is done by taking the market value less the principal balance due on the reverse mortgage.

There are many scenarios when dealing with real estate, so please ensure you are consulting with your HFA or State Agency if you come across one of these examples.

YTD Calculation

Posted on: July 18th, 2019 by Christa Landram No Comments

As of October 2018, the following guidance was provided for Year-to-date (YTD) calculation.

Procedurally, we do not require a property to use a year to date (YTD) calculation method and conversely, will not cite a property for using this method; however, if they do use it, we will also consider that calculation in our review(s).

Many properties choose to use this calculation due to concerns that the paystubs or employer’s verification provided, do not show a true reflection of hours, pay, etc. This can be for a number of reasons, which can include hours, OT, commission, and bonuses.

If a property does choose to use YTD, it should be used consistently and with all files where YTD is provided. When a property is not consistent with the use or non-use of this calculation, we will write it up as a general comment.

In the event we review a file that would have been over-income by use of YTD, and the owner chose not to include the calculation for this reason, we will cite it as noncompliance if the owner’s standard procedure is to use that method for all other files.

In summary, we will monitor this calculation in a manner consistent with the owner’s procedures.

Child Support

Posted on: July 18th, 2019 by Christa Landram No Comments

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A few people have expressed confusion regarding how Florida Housing monitors child support; so, I have written a succinct explanation in hopes that it will provide clarification.

If an owner has a court order and a printout from the enforcement agency, the owner is now allowed to use the average payment from the printout, if:

1. The printout is from the actual enforcer (this does not include myflorida.gov); AND

2. There is at least 3 months of history (this can include $0).

If one of the above criteria is not met, then the amount on the court order MUST be used.

As a reminder, the following steps should always be taken:

1. Every household should be asked if there is child support or if child support is due, even if children are not present in the household.

2. A child support affidavit is not required if the file is properly documented with these answered questions:

a. Do you receive child support?

b. Are you entitled to receive child support?

c. At what frequency are you entitled to receive child support?

3. The questions should cover ALL children.

4. The court order in its entirety is recommended; however, if the printout from the enforcement agency clearly shows the amount due to them, the frequency of pay, the contributor, and the children(s) names, then it will not be a discrepancy if the court order is not present. This is an exception and should not be the standard. Most everyone can retrieve their court order, as they are located and accessible in court archive

 

Unit Transfers

Posted on: August 8th, 2018 by Christa Landram 1 Comment

Anyone who participates in the affordable housing industry has dealt with or will deal with a transfer(s) at some point in the affordability period. It is crucial to understand the different rules pertaining to transfers. To help compartmentalize the various rules, we will break it down by funding source.

LIHTC/HC
With LIHTC, the owners must know whether the building is part of a multiple building project or a single building project.
Note – building election can be found on Form 8609, Line 8b.

Each Building is a Project:
Transfer between buildings: If the owner chose each building to be a project, then each building is treated as a separate project. This means that Initial Certifications must precede transfers between buildings or “projects,” and the household requesting a transfer to a different building is treated as a new move-in. This means the household must meet the applicable income limit.

Transfers within the same building – 100% Low-income: households can transfer within the same building without having to test their income because, per IRS regulations, they do not have to conduct recertifications and at initial they were presumably under the applicable income limit.

Transfers within the same building – Mixed Income: transfers can take place within the same building, but income should be “tested” to see if the household exceeds 140%. If the household does exceed 140% of the applicable AMI, then the household can still transfer, but to maintain compliance, the Next Available Unit Rule (NAUR) will need to be invoked.

Multiple Building Project:
100% Low-income: households can transfer within buildings and between buildings without having to test their income because, by IRS regulations, they do not have to conduct recertifications and at initial they were presumably under the applicable income limit. Even though Florida Housing conducts one annual recertification for these projects, they still do not prohibit transfers between buildings, even when a household exceeds 140%.

Mixed-income – transfers within the same building: transfers can take place within the same building, but income should be “tested” to see if the household exceeds 140%. If the household does exceed 140% of the applicable AMI, then the household can still transfer, but to maintain compliance, the NAUR will need to be invoked.

Mixed-Income – transfers between buildings: income must be tested to see if the household exceeds 140% of the applicable AMI. If it does, then the household cannot transfer. If the household does not, then the household is permitted to transfer.

MMRB
NOTE: following is a Florida Housing rule. Please check with your bond issuer to see if they follow the same principles.

When a property is combined with MMRB/SAIL, the HC rule applies. The IRS states that when a property is 100% low-income, annual recertifications do not have to be conducted and transfers can take place without restriction.

When it is not combined with HC, but is still 100% low-income, the same rule applies (see LIHTC/HC rules above).

When a project is not 100% low-income, all transfers must be treated as new move-ins and the entire initial certification process must be completed.

SAIL
The SAIL definition of very low-income indicates that when a property is combined with HC/SAIL, the HC rule applies.

The IRS states that when a property is 100% low-income, annual recertifications do not have to be conducted and transfers can take place without restriction.

When it is not combined with HC, but still 100% low-income, the same rule applies (see LIHTC HC rules above).

When a project is not 100%, all transfers must be treated as new move-ins and the entire initial certification process must be completed.

HOME
Under HOME, the transfer rule is slightly ambiguous, and it is important to inquire how to do all transfers with the PJ (Participating Jurisdiction) or the Program Administrator. Many administrators require the household to be treated as a new move-in before conducting the transfer. Transfers are often done at lease renewal. To accommodate appropriate occupancy, an owner should complete the entire certification process to ensure the current household and associated income has been captured. At all times, the unit mix must be maintained.

 

First Housing Originates $31.6 Million in Construction Financing for Lenox at Bloomingdale

Posted on: August 1st, 2018 by Anne Gehlsen No Comments

First Housing originated $31,691,000 in permanent, fixed-rate debt through its HUD/FHA 221(d)(4) program for the construction of Lenox at Bloomingdale, a 240-unit apartment community in Riverview, FL. The loan features a 40-year term and 40-year amortization with a fixed interest rate of 3.80 percent. Lenox at Bloomingdale includes ten residential buildings of three stories and a clubhouse that  includes amenities such as a fitness center, game lounge, business center and an internet café with coffee bar. Additional amenities include a swimming pool, outdoor kitchen, bike storage, pet park and walking trails. Units have one to three bedrooms and average 996 square feet in size.

Lenox at Bloomingdale was developed by The Richman Group Development Corp. and constructed by First Florida.

Senior Vice President Scott Moreman originated the loan.

COMPLIANCE: ACQUISITION/REHAB vs. RE-SYNDICATION

Posted on: July 20th, 2018 by Christa Landram No Comments

Recently, the affordable housing industry has seen a surge in acquisition/rehab deals. It is important to know the difference between a straight acquisition/rehab property and a re-syndication.

Straight Acquisition/Rehab

A property that was not a previous LIHTC property but received tax credits or both tax credits and bonds. Each renter is treated like a new move-in since they were not previously qualified.

Re-syndication

Re-syndication is when a project has been through its first 15-year compliance period, and the owner (original or new) elects to apply for a new set of credits. This election will restart their 10-year credit and 15-year compliance period. The property has already been a tax credit property and the owner is placing new credits into service with existing LIHTC residents in place, some of them having lived there for years.

One of the most common questions we receive is, “Can a household be ‘grandfathered’ into the program without having to undergo a new income certification (IC)?”

Under re-syndication with just LIHTCs, it is a possibility. If an owner can demonstrate with a good Tenant Income Certification (TIC), including strong documentation, that they were qualified for the LIHTC program, they are considered qualified at re-syndication. This is up to the owner and the limited partner (investor), as some investors will only participate if all households are initially qualified. An owner has 120 days to initially certify all households, or show all households are certified as of the last certification. Once the 120 days are up, households can continue to be qualified, but they must be treated like a new move-in.

When layered with bonds, all households MUST be initially qualified, and an owner has a year, as of the close of the bonds, to show that these residents are qualified under the bond program. After the one-year deadline, any households that do not qualify will be considered in noncompliance if the property is 100% bond. If it is not 100% bond, the unit must be listed and considered Market Rate. It is a federal rule that the owner of these projects ensures they have bond-eligible households in place within one year of closing.

If a resident was initially certified just before the acquisition and the income verifications are still within 120 days, then the owner can use the same verification, but a new TIC must be completed and signed by the owner and adult household members.

Note: if there is a change of ownership, being “grandfathered” in is only an option for those acquisition/rehab projects under re-syndication. If it is a straight acquisition/rehab (prior to the completion of the 15-year compliance period) and there is a change of ownership, then all households must be initially qualified.

TYPE OF ACQ/REHAB                INITIALLY CERTIFY              COULD BE “GRANDFATHERED IN”
___________________________________________________________________________________
Straight Acq/Rehab without
BONDs (not a previous LIHTC                    X
property)
___________________________________________________________________________________
Re-syndication (post 15-year
compliance period) without                                                                                 X
BONDs
___________________________________________________________________________________
Still within the initial Compliance
Period                                                     X
___________________________________________________________________________________
Has BONDs                                            X
___________________________________________________________________________________

Another common question we receive is, “How do verifications work when qualifying households under acquisition/rehab with the effective date being the acquisition (purchase) date?”  Verifications are good for 120 days from the date of owner’s receipt.  If a verification is obtained prior to 120 days before an effective day on the TIC, it wouldn’t be valid as of the effective date even if the resident signed the TIC early.  Looking at an example:

•    Assume a verification document is obtained in March
•    You have the tenant sign the TIC in June (within 120 days)
•    But the effective date will be in December (200+ days after the verification)
•    You have an expired verification document that will not be sufficient or valid for a December effective date

Verifications need to be within 120 days of purchase date. The whole process (verifications and TICs completed/signed) would all need to be complete within 120 after purchase/acquisition (effective date) to be able to use the purchase date as the effective date. Otherwise, the completion of paperwork/process isn’t done in time and the effective date doesn’t revert to purchase date but becomes the date the TIC is completed/signed.

Many also wonder if the move-in date is when the household moved in or the date the unit became LIHTC certified?

As of now, there is no clear guidance on this for acquisition/rehab deals. Most state agencies will not make an issue over whether an owner chooses to use the original move-in date or the effective date of the certification as the move-in date. This is one of those areas that is grey from a federal standpoint. It is still very important to check with your state agency to see if they have a preference

The income limits that should be used may be initially confusing to these deals. If it is an LIHTC only acquisition/rehab, the income limits may vary. When using old certifications, there may be several. The limits that will be used for old certifications will be the ones in effect at time of their certification. All other households will use the current income limits in effect at time of acquisition. These limits can be used for 120 days after date of acquisition, even if the new limits come out. Once the 120 days has expired, the current income limits will be used.

For LIHTC/Bond or just Bond, the income limits will be based on the limits in effect at time of acquisition. These limits will be used until the next set of income limits has been received (or posted). LIHTC and Bond properties are held harmless from income limit (and therefore rent) reductions. These properties will use the highest income limits used for resident qualification purposes since the project has been in service. Once the new set of limits are known, an owner compares these newly posted limits to the previous year’s limits, to determine which one is higher and which one they will use.

Finally, why are there times when the year of the rent limits do not coincide with the income limits? The IRS allows owners of LIHTC developments to select a gross rent floor (GRF) election for every building in a project, based on when credits were first allocated to that building or the date the building was first placed-in-service. The GRF election is a rent revenue security blanket for the owners so that they do not have to reduce rent limits any lower than the rent limits in place at the time credits were allocated or at the placed-in-service date.

If the Owner elects their GRF to be at allocation, the rents will be based on when a state agency representative executes the Carryover Allocation. If a property does not have a Carryover Allocation, it is the date the Preliminary Determination page is signed by a state allocating representative.

Looking at an example:
•    Property allocated credits in 2015 with median income limit of $50,000
•    Property placed in service in 2016 with median income limit of $45,000
•    GRF is based on the median limit of $50,000
•    2017 the median income limit is $42,000
•    2018 the median income limit is $43,000

In 2018, the income limits will be based on the Placed in Service (PIS) median limit of $45,000 and the rent limits will be based on the GRF election (2015) when the median income limit was $50,000.

As always, it is important to verify all procedures with your state allocating agency prior to implementing any new rules or regulations.

NAHB HCCP Credential

Posted on: December 11th, 2017 by Christa Landram No Comments

Christa Landram Is featured in the #NAHB #HCCP Credential! ”
“I do not take my position lightly and spend hours every week researching and reading new things about the LIHTC industry so that I can help others understand.” Read more below:
https://www.nahb.org/en/learn/designations/housing-credit-certified-professional/the-credential/december-2017.aspx

HURRICANE IRMA

Posted on: September 9th, 2017 by Anne Gehlsen No Comments

As of about noon Saturday, Hurricane Irma was near the north coast of Cuba and 175 miles southeast of Key West with winds of 125 mph. It was moving west at 9 mph and is expected to turn north and head up the western coast of Florida, making landfall from early Sunday to early Monday as far north as Tampa.

In response to this threat and in order to ensure the safety of First Housing’s employees and their families, our offices will be closed through Tuesday, September 12th.  We anticipate returning to normal business operations on Wednesday, September 13th, barring any significant damages or transportation problems.

We send out prayers and well wishes to all Floridians preparing for this dangerous storm.

Florida Affordable Housing Success Story- Pasco County Community Development

Posted on: July 10th, 2017 by Anne Gehlsen No Comments

The Florida Housing Coalition recognizes the Pasco County Community Development, the Pasco County Housing Finance Authority, and Gorman & Company as a Model for Leveraging SHIP in support of developing Affordable Housing for Florida’s most vulnerable residents.  Watch on Vimeo here.

HUD to Require Energy & Water Benchmarking

Posted on: February 1st, 2017 by Angi Darling No Comments

As of April 15, 2017, HUD is seeking to require owners of HUD projects to provide the following utility consumption metrics for each property: Site and Source Energy Use Intensities (EUI), Site Water Use Intensity (WUI), and the ENERGY STAR Score for Energy, and – when available from EPA – the Energy Star Score for Water.

Covered property types include:
•    Section 202 Project Rental Assistance Contracts (PRAC)
•    Section 811 PRAC and Project Rental Assistance (PRA) contracts
•    Section 202/162 Project Assistance Contracts (PAC)
•    Section 202 Senior Preservation Rental Assistance Contracts (SPRAC)
•    Section 8 Housing Assistance Payment (HAP) contracts
•    Multifamily Housing properties insured under Sections 223(a), 223(f), 221(d), 220, 231, 236, and 241(a)

The Portfolio Manager software – which must be used to meet HUD benchmarking requirements – calculates and reports these metrics in a standardized report format. This report may also include property identifiers (such as address and HUD contract number), building characteristics and other summary-level data underlying the benchmarking score calculations.

The ENERGY STAR Score for Water is currently pending release by EPA, so it will not be required until it is available. HUD will provide at least 90 days advance notice before a requirement to submit water efficiency data goes into effect.

Source: Florida Green Building
Full Source Document

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