Once upon a time, there lived a new property manager at a nearby village developed quite some time ago as a Housing Credit property. Over the years many personnel changes occurred at this village as well as some uncontrollable incidences such as theft and fire. Then, one day the state showed up requesting to review 20% of the village’s tenant files. “No problem,” says the new property manager, “I got this!” All seemed well until the State suddenly requested first year records for a 15 year old file! The new property manager searched and searched but to no avail; she came up empty.
The new property manager had no idea that first year records must be kept for six years beyond the due date for filling the Federal Income Tax Return for the last year of the compliance period. Since the compliance period is 15 years, first year records must be kept and maintained for a total of 21 years. Yikes, that’s a long time!
Additionally, all other records must be kept at least 6 years beyond the due date for filing Federal Income Taxes for that year.
All resident files and records should be maintained in a secure and safe manner. It is recommended that in addition to hard copies being maintained onsite, electronic copies also should be maintained off-site. This will avoid the loss of records due to uncontrollable events at the property.
Not having first year records for Housing Credit files could cause tax credits to be recaptured!
It is important to refer to the state agency’s guidelines for record retention procedures for other types of programs such as HOME, MMRB, or SAIL.
Any developments utilizing more than one program type shall follow the record retention procedures pertaining to each program. For example, if a property has both Housing Credits and HOME, be sure to know the record retention policy for both programs and follow the procedures accordingly to ensure that the requirements of both programs are being met.
As the day continued on, the new property manager at the old village received excellent news from the corporate office. A copy of the 15 year old first year record was eventually found, since they already knew the importance of keeping an electronic record of files offsite, and everyone lived happily ever after.