Happy Holidays and welcome to the end of 2014! Looking back on the year, not much new occurred in the world of LIHTC, though debate continued to rage over events from the prior year such as the reauthorization of the Violence Against Women Act (VAWA), the publication of the HOME Final Rule, and the issuance of Change 4 to HUD Handbook 4350.3 REV-1. The only big surprise to come our way this year happened recently, when HUD announced a delay in the publication of its programmatic income limits until Feb. 2015.
Why is this surprising? Since 2011, HUD has regularly published its annual programmatic income limits in December. Prior to that, publication of income limits happened anywhere from the beginning of the calendar year until late May. Since we tend to like consistency when it comes to all things regulatory, many found comfort in HUD’s newfound December publication habit.
But this year, citing “statutory changes made to the publication of certain Section 8 income limits,” HUD broke its new habit. I’ll give them credit, however, for giving advanced notice of this change since in years past it was a guessing game as to when we would get the new limits.
So, what does this mean? For HUD programs it means that they will have to wait on their 2015 income limits until the February publication. For LIHTC, it means that the Multi-family Tax Subsidy Projects (MTSP) limits will not be published until then either, since they normally share an effective date with the HUD program limits. Also, for tax credit properties it means that the 45-day grace period extension that is given before the new income limits must be used will be pushed off until at least March of 2015 and possibly April, depending upon when the limits are published in February.
What will 2015 hold for us as an industry? Only time will tell. In the meantime I wish you and your loved ones a joyful holiday season filled with the things that make you the happiest. We’ll be back in January to kick off another exciting year of Housing Management Update!