Compliance Information

A1. All LIHTC, HOME, and NHTF projects without Section 8 are encouraged to start using the HOTMA rules and forms. The HOTMA final rule compliance date for projects with Section 8 has been recently extended to January 1, 2026 by HUD. For that reason, IFA will not begin enforcing HOTMA until 2026 for all projects and will provide further guidance to an exact date as it becomes available.

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.Correct. IFA still requires 2 consecutive months of paystubs to be collected to calculate annual income

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.