Lisa Goulet didn’t set out to become a housing manager. But her path led her to NCHM's Registered Housing Manager designation, and today she is a successful portfolio manager in San Diego. Click above to hear her story.
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By Jo Ikelheimer, MA, RHM, Director of LIHTC Compliance
Hi folks! I thought I would share a few recent questions pertaining to LIHTC that we received through the eHotline – our free technical assistance service for those with active NCHM certification.
Q: Our LIHTC property has two buildings and on question 8b under Part 2 of the 8609 [Are you treating this building as part of a multiple building project for purposes of section 42?], we answered No. I understand that households may need to income qualify again prior to transferring units, but what if the transfer is in the same building?
A: If the transfer occurs within the same building (or BIN), then you may treat it as a transfer without the tenant having to requalify. The LIHTC regulations don’t consider tenants to be over-income until their income exceeds 140% of the current applicable income limit, but even if that’s the case then they may still transfer within the same BIN. Under the circumstances that you’ve described, tenants would need to requalify to transfer or move between buildings since the answer to question 8b indicates that your buildings are not being treated as part of a multiple-building project.
By Paul Flogstad, RHM, NCHM instructor
Principal, Property Management Solutions
"I’ve been doing things this way for over 25 years and I am not about to change now."
"The government can’t tell me what to do."
"Tenants have too many rights as it is. What about landlord rights?"
I have been involved in fair housing education and consulting for over 10 years and I hear statements like this all the time. As the fair housing ombudsman for the state of South Dakota, I respond to fair housing complaints that come in on a toll-free line. It gives me a good sense of the issues people are contending with – and, by extension, where the gaps exist in fair housing knowledge.