12/8/2016 11:59:18 PM
By Jo Ikelheimer, MA, RHM, Director of LIHTC Compliance
I am often struck by the different languages that different affordable housing programs speak. What one program calls something may be completely different from what another one does – even if they're talking about the same thing! For that reason, I see it as part of our jobs as affordable housing practitioners to become educated not only in each program's compliance and management characteristics, but in the disparate languages they use.
Take, for example, how different programs address verification requirements. HUD programs and the Low-Income Housing Tax Credit (LIHTC) program generally require written third-party verification of income while HOME requires verification through source documents. The irony is that they are basically the same thing. HOME guidance tells us that “source documents are written documentation, generated by a third party (such as an employer), that verifies the income sources that the applicant reports.” It then goes on to list acceptable source documents to include wage statements, interest statements and unemployment compensation statements, which are also acceptable forms of verification for both HUD and LIHTC. You say tomato, I say tomahto ...
Another example is how programs address the physical condition of units and properties. HUD and LIHTC are expected to conform to HUD’s Uniform Physical Condition Standards (UPS), except when state housing agencies use local code as the standard for LIHTC. By contrast, the HOME guidance makes reference to Minimum Property Standards and describes these in Exhibit 5-1 of the HOME Model Program Guide for Owners, which also references the older Section 8 Housing Quality Standards (HQS) as an acceptable option for HOME. Knowing the difference in not only the lingo but the standards’ requirements is key in ensuring our properties conform to the expected physical conditions to maintain compliance.
Finally, I must address one of the most confusing (and annoying, in my opinion) language-related issues for affordable housing programs – acronyms! One of my biggest pet peeves is when they are liberally sprinkled into industry discussions with nary a consideration of defining them. For that reason, I try to always be mindful of their abundance in our business and the fact that even we seasoned practitioners don’t know them all! In fact, here’s a small takeaway for you who have chosen to read this article. Follow this link to find NCHM’s acronym list from our Blended Occupancy Specialist (BOS) course. There will be a vocabulary test tomorrow!