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COVID-19: COMPLIANCE & CONSTRUCTION MONITORING

    COMPLIANCE & CONSTRUCTION MONITORING UPDATES RELATED TO COVID-19

    As circumstances from COVID-19 continue to evolve, LHC’s priority is ensuring the health and safety of our staff, customers, and partners while continuing to fulfill our mission of investing in affordable housing and economic development.

    Consistent with guidance issued by government and health officials, and to do our part to help prevent the virus from spreading, LHC is encouraging a culture of social distancing.

    Until further notice, LHC has asked our employees to work remotely and to restrict all business travel. Our organization has invested in technology that allows us to maintain business continuity despite these changes. While you may see us rescheduling meetings and trainings to occur as conference calls or webinars, our team remains committed to ensuring that we are accessible and responsive to your needs.

    While we adapt as appropriate to the changing environment, LHC remains steadfast in our commitment to our work. More information for our customers and partners is below.

    REGULATORY COMPLIANCE MONITORING

    For Multifamily & Single-Family Projects: Tax Credits, Tax-Exempt Bonds, CDBG, HOME, and NHTF. 

    • All physical inspections have been suspended until further notice.
    • Monitoring will be completed as desktop reviews.
    • Compliance Specialists will provide instructions for electronic file submission.

     

    ACTIVE CONSTRUCTION INSPECTIONS

    For Multifamily & Single-Family Projects: Tax Credits, Tax-Exempt Bonds, CDBG, HOME, and NHTF.

    • Inspections will continue as usual for vacant new construction and rehab projects.
    • On-site inspections are suspended until further notice for all non-vacant projects.
    • Virtual inspections may be utilized where feasible.

    IRS Audit Technique Guide

    HUD Guidance: Stimulus Payments 

    This guidance specifically pertains to Household Stimulus Payments and has been extracted from HUD's Q&A COVID-19 Multifamily Housing for Stakeholders.

    • Are household payments under the CARES Act reportable as tenant income?
      Household stimulus payments of up to $1,200 (which is technically an advance tax credit) and the temporary $600 per week federal enhancement to unemployment insurance provided by the CARES Act are not to be included in calculations of income. However, HUD notes that regular payments of unemployment insurance (issued by the state) are treated as income, as is customary under program rules.

    • Will impacted residents still have to complete annual recertification and interim certification for lost income?
      HUD statute and regulations require family income to be reviewed at least annually to determine the amount paid by the family for the assisted unit. Owners must continue to perform annual and interim recertifications, as requested by tenants, within the required timeframes and using current/anticipated data. Annual recertifications must not use previous year’s income to determine rent and assistance, except in instances when using streamlined income determinations.

      Considering the current COVID-19 emergency, there may be extenuating circumstances that impede owners and tenants from complying with interim and annual recertification requirements. When the use of traditional procedures is not possible, the extenuating circumstance instructions provided in this document, HUD Handbook 4350.3, REV-1, and the TRACS MAT Guide should be used.

      HUD considers the CDC’s recommendations for controlling the spread of the virus as well as shelter-in-place and similar orders as qualifying as an extenuating circumstance. It is recommended the owner begin, and if possible, complete, the recertification actions within 90 days of being advised of the extenuating circumstance. When an extenuating circumstance is present, there is no change to the tenant’s recertification anniversary date. The Total Tenant Payment/Tenant Rent and the assistance payment are effective retroactively to the recertification anniversary date.
     

    Point of Contact
    Todd Folse
    Compliance & Construction Administrator
    tfolse@lhc.la.gov

    Seuana Randall
    Housing Finance Supervisor
    srandall@lhc.la.gov

    Donna Burnett
    Housing Finance Specialist
    dburnette@lhc.la.gov