In my most recent blog post some two weeks ago, I asked you what compliance rules you would like to see changed if you had a chance to sit down with the next administration.� Well, it seems folks are a bit shy so in an effort to get the ball rolling, I'm going to share with you a bit of my "wish list" on this topic.
1. Since the Section 42 Low Income Housing Tax Credits program continues to thrive, the Internal Revenue Service and HUD should put their heads together and come up with one Compliance Monitoring Handbook.� The state agency groups have made efforts to address this and are deserving of recognition.� The time has come to get it done.� When an owner with Tax Credit properties in four different states has to have four sets of compliance rules, this results in confusion at best and a catastrophic non-compliance situation at worst.
2. Section 202/8: Get rid of the ridiculous rule in HUD Handbook 4350.3, Rev. 1 (Paragraph 7-4D) that implies adult children admitted after move in have their income counted even though their presence is necessary for the care of their parent(s).� And if you're going to prevent Section 202's from collecting NSF fees, allow those fees as "special claims."� The overwhelming majority of Section 202's are non-profits and their banks are charging them NSF fees.
3. Start approving Affirmative Fair Housing Marketing Plans (AFHMP's) that have been floating around your respective offices for months.�
More next time.
beautiful dreamer, eliminating soft money, eliminating sodium, eliminating smoke smell from our home, eliminating smoke smell.
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