HOT OFF THE PRESS

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HOT OFF THE PRESS
New 8823 Guide LIHTC Compliance Manual Fourth
Edition Post-15 Year Monitoring Plan
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The New 8823 Guide and How it Impacts Monitoring

• ?Allows for more asset management
• type functions from the state
• ?Allows for inspections prior to issuance of the
  8609(s)

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The New 8823 Guide

• ?Shortens the timeframe for the first inspection
• ?Changes how vacant units are counted for an
  inspection

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The New 8823 Guide

• ?All levels of deficiencies under UPCS standards
  are reportable
• ?Notification of Exigent and Non-Life Threatening
  Health and Safety issues

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The New 8823 Guide

• ?Addresses unborn children documentation
• ?Addresses TIC effective dates versus signature
  dates

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The New 8823 Guide

• ?Transfers from building to building
• ?Certifications needed for ac/rehab deals

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The New 8823 Guide

• ?Noncompliance found prior to state notification
  of inspection
• ?Imperfect documentation

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Comparison of State vs. Syndicator Monitoring

• ?The state isnt the only entity inspecting your
  property and auditing your files
• ?Syndicators role

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Syndicators Role - Basics

• ?Congress allocates credits to the states
• ?OHCS allocates credits to Oregon developments
• ?Syndicator purchases an interest

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Syndicators Role - Basics

• ?Investor or Syndicator?
• ?Responsibilities of Syndicator
• ?Ongoing monitoring of the asset

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Comparison of State vs. Syndicator Monitoring

• ?Physical inspections by the state and by
  syndicators
• ?File reviews by both

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State vs. Syndicator

• ?Why compliance is important to the syndicator
• ?Why the state is interested in ongoing compliance

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State vs. Syndicator

• ?Consequences when the state discovers
  noncompliance
• ?Consequences when your syndicator discovers
  noncompliance

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OHCS LIHTC CM

• ?Thats government code language
• ?The new manual will be on our website shortly

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LIHTC Compliance Manual

• ?Changes made as a result of the release of the
  new 8823 Guide
• ?Changes made due to OHCS policy changes

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LIHTC Compliance Manual

• ?Clarifications
• ?Examples

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The Post-15 Year Monitoring Plan

• ?Was approved by the Governor after opened for
  public comment
• ?Became a part of the new QAP

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Post-15 Year Monitoring

• ?What Post-15 Year means
• ?Highlights of the Plan

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Post-15 Year Monitoring

• ?Consequences for noncompliance in the Post-15
  Year Period

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Conclusion

• ?Contact your Compliance Officer at the state if
  you have questions
• ?Contact your syndicator if you have questions
  you dont want to direct to the state