New REAC Rules, NSPIRE Demonstration Program, and Creating Effective Self-Inspections

No matter how experienced you are, it’s tough to get your units in decent, safe, and sanitary conditions. Especially while overcoming daily challenges such as tenant damage, unreported damage, razor-thin budgets, and aging properties is tough. Combine those challenges with oversight from agencies like REAC, and it can become stressful and feel like a thankless task.

Developing a Compliance Driven Maintenance Policy

In affordable housing, there are rules and regulations which govern eligibility, how much rent a family pays, and many other aspects. Many companies have specialists who monitor compliance with these requirements or outsource compliance to experts like US Housing Consultants.

But when it comes to maintenance and inspections, the standards are less specific, and open to interpretation, and frequently – sub-standard results. With HUD’s NSPIRE initiative to include requirements for self-inspections with electronic reporting, now is the time for owners and managers to develop a compliance-driven maintenance policy.

The Importance of Leadership in Property Maintenance

The most effective maintenance policies include procedures for utilizing “a second set of eyes” who check the quality of maintenance performance in real-time, just like we do with LIHTC and HUD file approvals. How do you implement this sort of oversight while avoiding micro-management? How do make employees feel helped with the oversight and not hounded?

Without Low-Income Housing Tax Credit (LIHTC) experience, even the most seasoned property management professionals can find themselves overwhelmed when taking on the management of a LIHTC property. In this 2.5 Hour minute webinar, Amanda Lee Gross and Scott Precourt will outline the fundamentals for someone new to LIHTC Management.

In this 90-minute webinar, Amanda Lee Gross will provide valuable information relating to conducting tenant file reviews. This webinar is essential for any professional who conducts file reviews or oversees a file review department.

Topics Include:

• Recommended policies and procures for On-going File Reviews

• Recommended policies and procedures for Periodic File Reviews

• Writing effective findings and corrective actions

• Necessary Project Data to collect before beginning reviews at a new project

• Audit Techniques

• Red flags in tenant files

Streamlining HUD Recertifications

In May of 2020, HUD published a Final Rule finalizing the regulatory language to implement the FAST Act which allows for streamlined recertifications. This final rule discusses how these new rules affect:

• Asset Verification
• Utility Allowance Reimbursements
• Triennial Income Verifications

Reducing the Administrative Burden for Owners

This Final Rule reduces the burden of verifying household assets when determining a household’s income upon recertification and also reduces the burden of verifying fixed income sources when determining a household’s income upon recertification. The rule reduces this burden by permitting owners/agents to verify a household’s fixed income (such as social security)every three years as opposed to every single year. For households whose fixed income represents 90% or more of the household’s total gross income, the owner/agent is not required to verify non-fixed income sources in years 2 and 3 after a full third-party income certification has been conducted. Additionally, this new rule allows for utility reimbursements to be paid quarterly in certain circumstances.

Learn to Take Advantage of This New Benefit

This rule makes the process of recertifying households in HUD housing much easier and less time-consuming. So the question is: why haven’t more owners implemented this rule? Some owners and agents have avoided using this new option out of fear the process is too difficult to track. Others are afraid of doing it wrong and getting in trouble.

Simplifying Streamlining

In this 90-minute webinar, Amanda Lee Gross will provide valuable information relating to the streamlining provisions and provide guidance on how to implement these provisions at a HUD Multifamily Property. Topics Include:

• Verifying Assets every three years
• Determining which households are eligible
• Interim Recertifications during the triennial period
• The requirements regarding fixed-income triennial verification
• Utility reimbursements can be paid quarterly

Whether you are responsible for preparing tenant files or reviewing tenant files, chances are you have made a mistake in determining household eligibility. Mistakes will happen. The key is to learn from those mistakes. This 90 min webinar discusses best practices to prevent common errors.

The IRS requires that Tax Credit monitoring agencies use the UPCS Inspection Protocol to monitor the physical standards of LIHTC and HOME properties. Using HUD's inspection protocol for tax credit properties is more than just doing a REAC Inspection. There are subtle differences between doing a REAC Inspection and doing a UPCS Compliance inspection. In this one-day online course, we'll cover what Tax Credit professionals need to know to perform effective compliance inspections.

Advanced LIHTC Compliance - This course covers credit allocation, applicable fractions, minimum set-asides , acquisition /rehab and resyndication. 

As we all know, many USDA/RD properties have budgets that are tight and provide little flexibility. As such, proper financial management is paramount for these properties. USDA requires proper financial tracking, budgetary controls, and replacement reserves. During this three-hour webinar, Amanda Lee Gross will review the fundamentals of proper financial controls and management. This includes:

• • Project Accounting Systems
• • Required Financial Accounts
• • Allowable Project Expenses
• • Replacement Reserves
• • Budget Requirements
• • Reporting and Financial Examinations

The Importance of Income Certifications All of the major funding programs, including Multifamily HUD to USDA/RD, and LIHTC, use income certifications to determine initial and continued eligibility for the programs. HUD and RD also use the income to establish what rent the household can afford and how much subsidy the owner is eligible to receive. Accuracy on income certifications is paramount to remaining in compliance with each of these programs. This webinar breaks down best practices and requirements for all of the major funding programs. This will include what to include when verifying income from wages as well as fixed income sources like social security. In this two-hour session, Amanda Lee Gross will discuss: • Verification Requirements • Signature Requirements • LIHTC, HUD and RD COVID-19 Guidance to Date • Post-COVID-19 Tenant File Follow -Up • Confidentiality and Data Security • Practical Points to Cover in a COVID -19 Policy and Procedures for Conducting Income Certifications •Confidentiality and Data Security While Working from Home

In this webinar, Amanda Lee will discuss the components of determining adjusted income and determining tenant rent for HUD, HOME, and USDA/RD. She’ll also review the impending changes regarding adjusted income will also be discussed throughout this informative webinar.

Are Your House Rules and Occupancy Standards Fair?

Fair Housing regulations treat policies like House Rules and Tenant Selection Plans with great scrutiny. The Fair Housing Act prohibits policies from including discriminatory terms and conditions. However, the interpretation of what is discriminatory often requires a considerable amount of clarification, especially when it comes to rules regarding personal conduct.

Good Intentions or Fair Housing Discrimination?

Most housing providers create policies to create a better environment for all residents. This can include rules about what residents can do in common areas, and how they are to maintain their homes. Many times policies are created with the best of intentions but viewed under a different light, they can be considered discriminatory.

Rules of conduct are a vital part of property management. They can be used to ensure proper housekeeping standards and reduce excess noise, and keep the property a clean and safe place for all. However, it is even more important to ensure that these cannot be considered discriminatory against any protected classes under the Fair Housing Act.

Avoiding Discriminatory Policies and Terms & Conditions

In this 75-minute webinar, Amanda Lee Gross will begin with an overview of protected classes under the Fair Housing Act. Then, she will review prohibited actions in general, and how these prohibitions look when applied to policies and procedures.

This includes a detailed review of how the Fair Housing Act intersects with the everyday activity of property management.

• •. Criminal Screening Criteria
• •. Rules of Conduct
• •. Facility Rules (Fitness Center, Pools, and Laundry Rooms, etc.)
• •. Occupancy Standards

Learn to Conquer Compliance

Amanda Lee Gross will take you through a comprehensive and interactive webinar. Amanda will discuss the requirements of the Fair Housing Act from a property management professional’s perspective. First, she will take you through case examples and exercises to provide a real-world connection to the material. Next, Amanda will talk about common mistakes and issues with property policies and procedures and how to best identify these issues and correct them. Above all, she will discuss how to best protect the interests of the property while meeting Fair Housing guidelines.

Stumped by the Affordable Housing Student Rules? 

There are student eligibility requirements applicable to each of the four major housing programs, LIHTC, HUD, Rural Development, and the HOME Program. These requirements affect whether a household is eligible to occupy a unit or receive rental assistance, and also affects how the treatment of student income determining a household's annual income. While each program has student eligibility requirements, the requirements are not the same for each program, which can pose a compliance challenge for housing professionals dealing with layered properties. 

Student Eligibility in Affordable Housing 

In this 90 minute webinar, Amanda Lee review the student eligibility requirements and exceptions for the following housing programs 

• LIHTC 
• HUD
• HOME Funds 
• Rural Development 

Amanda will wrap up the session by reviewing the treatment of student income, including the student financial assistance . 

Selecting the correct Income and Rent Limits for LIHTC projects is never easy. Learn about Income Limit and Rent Limit requirements for the LIHTC program and how to stay in compliance with the limit requirements for layered programs.

With continued advances in technology, we are now living in the “Age of the App” which has created peer-to-peer payment apps, such as Venmo, Cash, Paypal, etc. The determination of annual income includes considering proceeds from household assets, and one of many challenges for housing professionals in determining when an asset is treated as an asset, and when an asset is actually treated as an income source. 

Learn to Conquer Asset Calculations 

In this webinar, Amanda Lee Gross will review common assets encountered by housing professionals and she will even touch upon some less common assets as well. Amanda will also clarify when an asset source is actually treated as an income source. Amanda will also speak to: 

• Are these peer-to-peer treated as household assets?
• Are deposits made into the app treated as income? 
• Potential changes related to assets under HUD’s proposed rule implementing HOTMA. 
• Handling income and assets utilizing of peer-to-peer apps

As part of the NSPIRE changes, HUD wants annual inspections that are exhaustive, comprehensive and create units that are in good condition, every day. This session will talk about policies, procedures, and best practices that will make your unit inspections truly matter and keep your units in good condition and ready for REAC inspections at all times. 

In this webinar, we will review how to properly inspect a unit, set standards that are higher than the minimum, and create a dedication to safety. We discuss best practices, including technology uses for inspections, and how to establish proactive internal procedures that use annual inspections as an effective tool to maintaining safe and quality living environments.

When do start Preparing for your next HUD MOR? You know it is going to happen. It looms over your head like a swollen rain cloud building itself into a storm. You can't avoid it. You can't hide from it, your HUD Management and Occupancy Review will happen! 

Actually, an MOR is only something to dread IF you and your property is not prepared. In this 90-Minute webinar, Andrea Champine will focus on the Leasing and Occupancy areas that are reviewed during an MOR. 

Many of the most common findings on a Management Review include issues with Leading and Occupancy, from income and asset calculation issues, EIV Issues, and issues with proper documentation.

Andrea will cover the following topics: 

• MOR Steps and Categories with a focus on Category E on the HUD 9834 Form "Occupancy and Leasing"
• A Review of Resident File Checklist used by Contract Administrators (CA) when reviewing tenant files 
• Available documents that must be on hand during an MOR
• Understanding MOR Ratings
• Tips to prepare for an MOR
• Common Findings noted in MORs
• Responding to MORs

Preparing for a HUD Management Review requires constant vigilance and a focus on understanding those items which are included in the HUD 9834 Form, and how you can prepare for your next MOR with an Above Average as your goal.

October is National Domestic Violence Awareness month. In recognition of this, US Housing Consultants presented a free webinar by Amanda Lee Gross, where she discussed the rules and requirements of the Violence Against Women Act. US Housing Consultants also donated $5 per person to the National Domestic Violence Hotline for every attendee during the October 2019 webinar, which registered more than 2,300 people for the webinar.

Residents of affordable housing programs are often among the most vulnerable populations, and protections for victims of domestic violence is one of the most important advancements in HUD requirements. The rules in VAWA create real world protections for residents, and affirms the affordable housing industry’s responsibility to provide leadership and direction on making sure domestic violence victims have proper resources, support, and a safe place to call home.

In this 90 minute webinar, Amanda Lee Gross will discuss the requirements that apply to affordable housing properties under VAWA. 

Topics covered include:

• Overview of Legislative History
• Covered Housing Programs
• Key Terminology

VAWA Protection Provisions, including:

• Denial of tenancy or assistance
• Termination of assistance or tenancy
• Lease Bifurcation
• Emergency Transfers
• Notification and documentation requirements
• Review of HUD’s VAWA Final Rule and HUD’s notice H-2017-05 published Jun 30, 2017 “Violence Against Women Act (VAWA) Reauthorization Act of 2013 – Additional Guidance for Multifamily Owners and Management Agents”
• Review of Rural Developments Guidance
• Discussion of VAWA implementation for the LIHTC Program and the HOME Program

In 2018 the Low-income Housing Tax Credit program introduced a significant change - the new “Income Averaging” Minimum Set-Aside election.

In this webinar, Amanda Lee Gross breaks down the changes to Section 42 of the Internal Revenue Code relating to this new election and does so in an easy to understand format. Amanda Lee also highlights the benefits as well as the potential challenges owners may face with making this all-important election.

Topics include:

• Overview of the LIHTC program’s Minimum Set Aside (MSA) Requirements
• Understanding the available options
• Effect of the owner's multiple building election on the MSA
• Method of Achieving the Average Income Set-Aside
• Calculating income and rent limits based of the new set-asides
• Complying with the Next Available Unit Rule at an Average Income project
• Potential affects of Noncompliance at an Average Income Project

In this content packed webinar, Amanda Lee reviews the recertification requirements that apply to the Low-Income Housing Tax Credit (LIHTC) program and how a recertification can trigger the applicability of the Next Available Unit Rule. This session also includes valuable tips and red flags to be aware of when processing recertifications . 

In this session, Amanda Lee will address the following questions: 

- Which LIHTC projects must conduct annual recertification? 

- How can noncompliance from a Late recertification be corrected? 

- When is the HFA permitted to file an 8823 regarding late/incomplete recertifications, and when are they not permitted? 

- Does the Next Available Unit Rule apply to 100% LIHTC Project? 

- How is the Next Available Unit Rule apply to project that elected the Average Income Minimum Set Aside ? 

Get the answers to these questions and more by attending this webinar!

REAC Challenges for Owners and Agents include many levels of non-compliance risks. Understanding the rules behind REAC inspections is vital to understand how to best manage the REAC Process before and after the inspection. This webinar will provide a high-level review of the rules, requirements, and regulations which are a vital part of the REAC process. Including: 

• How to delay REAC inspections due to substantial rehab
• Changes to Appeals Process - Increased Scrutiny on Supporting Documents
• REAC Appeals for Modernization, Construction, and Pre-Database Adjustments
• Consequences of Poor Performances & Failing REACs

The special claims process is designed to reimburse owners of eligible HUD projects for the owner’s financial loss resulting from vacancy loss, unpaid rent, and tenant damages. However, in order to get this reimbursement, the owner/agent must file for the reimbursement. While owner/agents are not required by HUD to file for special claims, management agents who do not file special claims are essentially choosing not to collect funds that the project’s owner is entitled to. 

In this 90 minute webinar, Amanda Lee Gross - VP of Training and Compliance Policy for US Housing Consultants - will provide the information needed in order to process special claims for: 

• Vacancies after rent-up

• Unpaid rent/damages

All attendees will receive a comprehensive course manual that can be used as a reference manual long after the webinar has concluded.

Tax Credit/LIHTC Housing Projects are aging and many are in need of rehab and recapitalization. The challenges that come with this are many, and the rules can be complex.

During this informative and engaging webinar, Amanda Lee will provide attendees the information needed to maintain compliance when conducting Acquisition Rehab at a LIHTC project. 

Topics Include: 

• Certification of existing tenants
• Unit transfers
• Key deadlines
• Maximizing Credit Delivery
• Overview of Resyndication. 
• Overview of the Uniform Relocation Act. 

All attendees will receive a comprehensive course manual that can be used as a reference manual long after the webinar has concluded.

It Aint Over till It’s Over – The Treatment of Over-Income and Ineligible Households in Affordable Housing Programs – 90 Minute Webinar (Recorded Live July 11, 2019)

We all know that a household must be income qualified to move into an affordable housing unit, but sometimes even the most diligent compliance professional misses a detail or there is misreporting by the resident and a household is admitted who is not income qualified. What to do in these situations leads to many questions, such as:

• What happens if a household becomes ineligible after moving in? 
• What happens to an existing tenant who does not meet program requirements during Acquisition/Rehab? 

In this 90 minute webinar, Amanda Lee Gross will answer these questions by discussing the requirements regarding the treatment of these types of households for the following programs: 

• LIHTC
• HUD
• RD
• HOME

Amanda Lee Gross will also guide attendees on how to maintain compliance related to over-income or ineligible households when a project has more than one of the above funding sources. All attendees will receive a comprehensive course manual that can be used as a reference manual long after the webinar has concluded.