During the recent NCSHA 2024 Housing Credit Connect Conference, the HUD Office of Policy Development and Research (PD&R) highlighted several critical issues related to the annual LIHTC regulatory requirements. Specifically, they emphasized the Allocating Agency’s responsibility to submit accurate and complete data. Based on the 2022 reporting, HUD identified several key data elements that were frequently missing in the regulatory requirement submissions:
- Allocation Sub-Type
- Placed in Service Date
- HUD Credit Type
- Minimum Set-Aside
HDS Findings
HDS has reviewed these requirements in detail and discovered that some of this critical data has not been entered into the HDS system, resulting in incomplete data submission files.
Regulatory Requirements: Importance of Accurate Data
As we prepare for the 2023 Tax Credit Tenant Data Submission to HUD, it is crucial to address these issues to ensure compliance. Accurate and complete data in the HDS Multifamily Compliance Management System is essential for maintaining your compliance status and fulfilling HUD PD&R reporting regulatory requirements. Missing data elements could potentially impact your compliance status.
Regulatory Requirements: How to Ensure Data Completeness
To ensure seamless compliance with HUD Policy Reporting and LIHTC Regulatory Requirements, we recommend the following steps:
- Review Your Data: Ensure that your data in the HDS Multifamily Compliance Management System contains all the required data fields.
- Use HDS Compliance Testing: Access your portfolio ‘Set-up’ and select the HDS Compliance Testing feature “Check HDS setup Issue Only” option. This will help you accurately identify any buildings with missing key data.
- Address Missing Data: Promptly address any missing data by navigating to the Programs, LIHTC Tab (Property Group > Buildings > Programs) in the HDS Multifamily Management System.
Important Reporting Deadlines
Submission Deadline: The deadline for your 2023 data submission is September 30, 2024.
Collaboration with HUD
HDS is actively working with HUD PD&R to identify data requirements for future submissions. In the immediate term, HDS will be implementing a release for the 2023 data submission in the coming month. This release will include submission requirement changes for the 2023 year only. Later in the year, the Industry Standard NAHAMA file requirements will be finalized, and the forthcoming release will be available.
Contact Us
Stay tuned for details on requirement guidance and how these changes will improve future reporting and program management. If you have any questions, please reach out to us. Thank you for your attention to this matter.