Q & A | We Had Quit Following VAWA Rules. Is that Bad?
Mar 16, 2022Question from a Blog Reader
"Back when VAWA was no longer authorized (I think it was 2018 or 2019) my boss had us stop following VAWA requirements for our properties (which are mostly made up of a mix of HUD and tax credit buildings). He said VAWA no longer applied. I saw on your blog post tonight that VAWA has been reauthorized. When should we start applying VAWA again?"
Answer
Summary: As soon as possible! The basic VAWA rules and regulations never stopped applying.
As you point out, funds have not been officially authorized for a few years for VAWA programs that involve government financing. However, legal counsel tells us that the VAWA statute does not sunset or expire. Additionally, the HUD regulations were never withdrawn and state LIHTC agencies (and many state laws) continued to require VAWA compliance. To address your current VAWA noncompliance, we would recommend immediately reinstating your VAWA procedures. Especially in light of new penalties (equivalent to Fair Housing) installed for VAWA noncompliance that appear to apply with VAWA 2022, you will want to address this immediately.
There is a very good chance that the topic of this post is covered in an online on-demand course at Costello University.
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