Travelogue | Housing Credit Connect 2023 | Day 3 - HOTMA and AIT

Post from our CEO from the Seattle Hotel hosting NCSHA's Housing Credit Connect conference.

"Hello, well, I'm on a break here at the Housing Credit Connect conference in Seattle. So I thought I'd take the time to just add our next session here of our travelogue. Now, I mentioned yesterday that there'll be four topics that I would be listening for, and two of them were covered yesterday. So I thought they would just share some of the interesting things that were said. Now, first of all, I
was on the panel on HOTMA, everything you need to know about in one hour! Obviously, it wasn't enough time to cover all the incredibly interesting things having to do with HOTMA, but I did get to share the story, the legend of the caveman who saw something new and died. So sometimes in compliance, we like things kind of being set, and we don't love changes. We need to realize once awhile that just because something changes, doesn't mean we're going to die. And so hopefully, we're all sort of a little better prepared for HOTMA and prepared to realize that that was just a start, right? But we're going to be further digging into HOTMA. In fact, we have a session tomorrow that I'm
participating in, and hopefully, I think that HOTMA will be a "hot" topic there. 

Next to the other second of the two that I was really looking for was the Average Income Test. And it was interesting because the majority of the room raised their hand when they asked if they had an Average Income Test property, or we're going to have one very soon. And then very few raised their hand when asked would you have them in the future. And it turns out that I believe that the
issue is no longer the federal rules. We've got those. We can live with those. It's about what state policies are going to be. That's what's going to determine whether the Average Income Test works. Now, it was kind of interesting, there's a couple of things that were said by the IRS that I think was insightful. First of all, they said that when they wrote the regulation they built in maximum flexibility, because they wanted this minimum set aside to work for properties, tenants, owners and state agencies. So by bringing that flexibility in to make it work, that was the IRS' intent, that we have any policies, we build to supplement the AIT mirror, the flexibility provided by the IRS. I thought that was very, very interesting. Then the discussion got into some policies in some states where you'd have to every time there's a raise in income, you'd have to recertify in the AIT property and then re-designate, which is nowhere spelled out in the rule. And the IRS' comment was a very simple one, "there's an Available Unit Rule built into the reg." Probably, that's what we should be using. So some interesting thoughts from the minds of the IRS that I hope states think carefully through as they come up with their AIT policy. Now, if they don't want it to be used and create policies that make it hard to use, I understand that. But honestly, the majority of states, I think, want it to work on a practical level. And I think the IRS provided some food for thought as we in many states are seeing these policies developed. Alright, so we've covered HOTMA, the AIT, and there might be more on HOTMA in tomorrow's session, but today I'm looking also for the second two things that we said that we would...or a second or four things that we said we would talk about, which would be the Violence Against Women Act, and NSPIRE. So some interesting things I've already heard. I know we'll be sharing on that. So have a good rest of your day, and we'll share more on tomorrow's travelogue."

- Scott Micael Dunn | CEO costello Compliance 

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