Question

I am hoping that you can help us with a bit of clarification on the dates for the 6^th year, where self-certification of income is allowed for HOME and the NHTF. Does the year depend on the placement of the property or the date each person moves in? If it is not according to the date that a person moves in, could you please tell me what date to reference according to the LURA? Is it the date that the property was placed in service, or the date that the rent-up was 100%, for example?

Answer

Summary: The federal HOME/NHTF recert rule is based on each year of the HOME (or NHTF) period of affordability. See 24 CFR 92.252(g)(2)

The period of affordability is specifically defined in HOME rules and will be indicated in the HOME written agreement. We do not know how your specific agreements are structured, but you will look for the start and/or end of the period of affordability (possibly referred to as the affordability period in agreements before 2025).

The practical application is that every family in a project in a HOME unit who is recertified in years 6, 12, and 18 of the usual 20-year HOME period of affordability for the project will have income verified with third-party verification, like at move-in (with possible self-certification of assets for HOME, following the HOTMA asset verification rules). For other years' recertifications, income can be entirely self-certified. Your PJ may have a form for this if they have implemented the federal "every 6th year" rule.

In actual practice, our experience indicates that this is much easier than trying to track each family’s years at a property.

Note: The NHTF has a required 30-year period of affordability, so you can add years 24 and 30 for NHTF units.