Compliance Information

A1. All projects are encouraged to start using HOTMA rules and forms now but must be fully in compliance with HOTMA rules, regulations, and forms by July 1, 2026. Please note currently the HOTMA implementation does not apply to projects with Section 8 project-based rental assistance.

A2. No, if you are verifying directly with a bank or other financial institution you will not need to use the Asset Self-Certification or the Asset Worksheet.

A3. Yes, if the applicant/tenant has no assets then that would need to be indicated on the Asset Self-Certification form.

A4. The Asset Worksheet may be used, although not required, by management staff as a tool to assist in calculating income from assets and how to display figures on the IFA required TIC form.

A5. Yes, all aspects of the applicant/tenant’s income must be collected.

A6. If the tenant has continued to live at the property at recertification, that section can either be left blank or the name of the project added to this section.

A7. Student Status Verification (which is sent to the institute of higher ed) would need to be completed when 1) Student status needs verification further than what is captured on the Student Status (Self-) Certification (for example, with LIHTC households, if one individual is attending school part-time and everyone else is a full-time student, student status must be verified with the school for the part-time student); and/or 2) if the household is receiving student assistance and does not have other documentation they can supply (printout from the school, etc.). 

Self-Certification of Student Financial Assistance is required for students of higher ed – it serves as a starting point to assess the different types of student assistance received and guide what documentation to obtain to verify the assistance. This Self-Certification also captures whether assistance like a scholarship from a local business or money from a parent that goes directly to the student, not the school, is received, which is not an option on the above Student Status Verification. This form captures this information as a first step and acts as a sort of checklist to guide what further documentation is needed to verify the assistance (printout from school, scholarship award letter from local business, gift-verification form, etc.).

A8. Yes, all sections of the TIC must be completed. Please review the TIC instructions on the IFA website for definitions of the different dates.

A9. LIHTC and HOME still have required language to be listed in each projects TSP as outlined in the IFA Compliance Manual. However, the new TSP and lease provisions released with HOTMA are only for Section 8 projects.

A10. As HOME and NHTF regulations still require two months of paystubs, IFA requires that for any project with HOME and NHTF units (including LIHTC projects layered with HOME or NHTF), two consecutive months of paystubs must be collected for ALL units, even LIHTC units. If a project is LIHTC-only, only two consecutive paystubs need to be collected.

A11. If unclear or close to the income limit, you may request more paystubs. Best practice is to use two consecutive paystubs closest to the certification effective date.

A11. Yes, like savings accounts, only the cash value of the current balance will be used.

A12. If the adult has answered ‘no’ on their application that is all the farther you need to go. No further verification is required.

A13. A car payment or cell phone bill paid on behalf of a tenant from someone outside the household is counted as income and can be verified using the Recurring Gift Verification (IFA Sample Form). 

For in-kind contributions such as personal items, clothing, toiletries, etc., the value is excluded from income if items are given by food banks or similar organizations.

A14. No, the cash value of real property counts and is included regardless of its value. It is not subject to any thresholds.