On March 28, 2016, HUD published the 2016 income limits for HUD programs as well as for the Low-Income Housing Tax Credit and Tax-Exempt Bond programs. The limits for the LIHTC and Bond projects are published separately from the limits for HUD programs. HUD has indicated that the U.S. median income limit is lower this year than it was in 2015.
LIHTC and Bond properties use the Multifamily Tax Subsidy Project (MTSP) limits, and are held harmless from income limit (and therefore rent) reductions. These properties may use the highest income limits used for resident qualification and rent calculation purposes since the project has been in service. HUD program income limits are not held harmless.
Projects in service prior to 2009 may use the HERA Special Income Limits in areas where HUD has published such limits. Projects placed in service after 2008 may not use the HERA Special Limits.
Projects in rural areas that are not financed by tax-exempt bonds may use the higher of the MTSP limits or the National Non-Metropolitan Income Limits (NNMIL). According to HUD, the NNMIL have gone down from 2015 to 2016.
Owners of LIHTC projects may rely on the 2015 income limits for all purposes for 45 days after the effective date of the newly issued limits. This 45-day period ends on May 12, 2016.
The limits for HUD programs may be found at http://www.huduser.org/portal/datasets/il.html. The limits for LIHTC and Bond programs may be found at http://www.huduser.org/portal/datasets/mtsp.html.
Please feel free to contact me with any questions.
AJ