The Housing and Economic Recovery Act of 2008 included policy changes to Low-Income Housing Tax Credit programs. Those changes were recently implemented by the California Tax Allocation Committee and affect all LIHTC projects.
The Housing and Economic Recovery Act of 2008 requires demographic data to be collected on all residents of developments that were built using Low-Income Housing Tax Credits. The data must be submitted annually. Data must include tenants' income, age, ethnicity, race, and disability status. HUD issued a “Tenant Data Collection Form” in June, complete with instructions.
Effective January 1, 2011, all recipients of Low-Income Housing Tax Credits in California must use one of two forms to collect housing resident data, and that data must be submitted to the California Tax Allocation Committee. The first is a Tenant Income Certification form, and should only be used for new residents. Information regarding existing resident should be collected using the Supplemental Information Form for Existing Households.
Both forms, definitions of terms, and instructions can be downloaded from the California Tax Allocation Committee website. In addition, a Q & A regarding the new policy was attached to the Notification Memo, and can be viewed online. Questions should be directed to the California Tax Allocation Committee.
Because the data collection is required by the Housing and Economic Recovery Act, it applies to LIHTC developments in all 50 states. Developers who build in other states should contact the local Housing Authority regarding collection requirements and procedures. Questions can also be directed to HUD's Regional Administrators; contact information is available via HUD's web site.