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When determining an applicant's eligibility, tax credit managers often can be thrown by HUD Section 8 regulations for income and asset identification that seem to conflict with certain provisions in the tax credit regulations. Jo Ikelheimer, research & development consultant and compliance trainer for the National Center for Housing Management (NCHM), points out these discrepancies in her Tax Credit Specialist training course, as well as in her ongoing article series in the Compliance Corner blog on the NCHM Web site.
If you own or manage a tax credit site, there may have been times when you had trouble deciding whether to count an investment or retirement account as income or an asset. That's probably because of the inconsistencies that appear in HUD's Occupancy Handbook 4350.3, REV-1, CHG-2, explains affordable housing consultant Elizabeth Moreland, an expert in HUD rules.
For example, Chapter 5, Paragraph 5-6, Section O, page 5-16, which discusses withdrawal of cash or assets from an investment, seems to contradict other regulations contained in the same chapter.
The recently issued Change 2 to HUD Handbook 4350.3 does not address how you, as an owner or manager, calculate annual income by using year-to-date (YTD) income.
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