The Average Income Minimum Set-Aside: Requirements & Best PracticesCourse Length:
1 hourCourse Description:
This course was created by A. J. Johnson, a nationally recognized leader in affordable housing compliance. A. J. is also the instructor for this course. This means you are not only being taught by an expert, but you also have the opportunity to easily interact with him. This is the perfect opportunity to get solid, accurate answers to your questions.
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The desk audit or, "pre-concurrence" service is one of the most popular services we offer. This is a straightforward process during which we review tenant or applicant files that are sent to us via secure upload to our server. We then provide a report to the client outlining any issues noted with the file and recommending corrections. We guarantee consistency in methodology and findings by having the same two people review all files and prepare the final report; those two people are a staff Compliance Consultant, and A. J. Johnson. The staff professional performs the detailed review of the file, noting discrepancies and recommending corrections. The report is then reviewed by Mr. Johnson, at which time final recommendations are made and credit risk is assessed.
This very affordable service provides our clients with a rapid way to meet the IRS requirement of demonstrating due diligence in the tenant approval process.
Section 42 procedural reviews examine all aspects of tax credit operations on a property, and will cover the following areas:
Confirmation of minimum set-aside
Examination of in service date relative to lease up deadlines
Review of special set asides
Examine Extended Use Agreement and ensure that requirements of the Agreement are met
If multiple financing programs are used, ensure that site complies with requirements of those programs
If there are mixed income buildings, analyze the applicable fraction requirements of the buildings
Examine Deep Rent Skewing requirements (if applicable)
Review the property for compliance with the accessibility and adaptability requirements of the Fair Housing Act of 1988 (if applicable)
Determine if non profit partner is materially participating (if applicable)
Examine issues relating to model units, employee units, and courtesy officer units
Review any optional fees charged to residents for appropriateness under Section 42
Determine if rent and utility allowance levels are appropriate
Ensure that correct income limits are being used on site
Analyze site policies relative to rental to Section 8 recipients
Analyze methodology for tracking units under the Next Available Unit rule
Determine how original resident files are being secured and whether copies of such files have been made for off site storage
Review of 15 resident files to determine if procedures are adequate to ensure that tenant qualification and documentation requirements are being met
An eligibility review is designed only to determine the eligibility of the residents. Basically, income and student status issues are reviewed and an opinion regarding the eligibility of each household is given. Each file is examined for eligibility (e.g., recertifications, file organization, document dating, etc. are not examined). This level of review is normally requested by investors concerned with resident eligibility issues.
This review includes all information listed under the asset management review section, plus a procedural review designed to determine if the site staff’s procedures are in conformance with the requirements of the Section 42 Program. The compliance portion of the review is limited to a confirmation of correct income and rental levels, and a review of five (5) resident files to determine if tenant qualification procedures are adequate.
This is the most comprehensive review we offer on a regular basis. It includes all elements of the asset management review and full procedural review.
A full tax credit compliance review will examine all elements of tax credit compliance, including a review of set-aside requirements, rent levels, utility allowance documentation, income limits, employee units, optional fees, file storage policies, available unit tracking compliance, and fair housing accessibility compliance. Resident files from each property will be reviewed for procedural compliance with the tenant certification and verification requirements of the Section 42 program. Each file is reviewed for the purpose of determining whether the property meets the compliance requirements of the Section 42 Program.
This is a very detailed audit of all resident files that basically examines every document in each file in order to make the most complete assessment possible regarding the status of the unit. This review is designed to identify both eligibility and compliance issues.
This training is designed primarily for new site managers and supervisory property managers, and is especially beneficial to those personnel who are relatively inexperienced in the tax credit program. It covers all aspects of credit relating to on site management, including the application process, income and eligibility verification requirements, requirements relating to tenant assets, and a full discussion of student issues. There are multiple problems designed to test the students retention of the course material.
Designed for more experienced managers, supervisory personnel, investment asset managers, and compliance specialists, this program expands on the information covered in the Basics of Tax Credit Site Management. A more in-depth discussion of income verification issues is included as well as a discussion of minimum set-aside requirements. The Available Unit Rule is covered in great detail, as are the requirements for units occupied by students. Attendees will also learn the requirements relating to setting rents at a tax credit property, and there is a full discussion of recertification requirements. This course contains some practice problems, but is more discussion oriented than the Basic course.
This full day training is intended for senior management staff, Property Managers, senior site staff, and others responsible for ensuring that overall management policies are established in a way that ensures long-term success for tax credit properties. This training covers complex issues such as eligible and qualified basis, applicable fraction, credit calculation (including first year calculation), placed in service issues, rehab projects, tax exempt bonds, projects with HOME funds, Available Unit Rule, employee units, mixed income properties, vacant unit rule, and dealing effectively with State Agencies. The session also includes a complete discussion of the types of fees that are prohibited on tax credit properties, and the result of charging inappropriate fees. The primary target audience for Advanced Credit Training are staff responsible for setting and carrying out management policies on site.
This 1/2 day course covers the important, but often overlooked, role that file management and documentation play in the success of tax credit properties. Detailed discussion of how to organize a file, the documents required for each file, setting up the “Property Notebook,” and acceptable forms of verification for all issues relating to eligibility are covered. The course also includes a full review of resident eligibility issues, with particular emphasis on the documentation of income.
This three hour course offers a complete discussion of the requirements of the Fair Housing Act of 1988, including detailed analysis of elements relating to each protected class. Examples of how to handle specific situations for each group are covered. Appropriate areas of Section 504 and ADA requirements are also covered, as are State specific fair housing requirements.
This is a half-day course that covers the basic requirements of the bond program, especially with regard to on site compliance. It is recommended primarily for senior management and development personnel, and is often combined with a discussion of Acquisition/rehabilitation issues on Section 42 properties.
This course outlines the basic requirements of the HOME Investment Partnership Program, with particular emphasis on combining HOME funds with the federal Low-Income Housing Tax Credit. The training provides an overview of HOME Program regulations, including rent rules, unit designations, income restrictions, and recertification requirements. The course concludes with a detailed discussion of combining HOME and tax credits, focusing on occupancy requirements and rents, tenant eligibility differences, handling over-income residents, and monitoring requirements.
Offered in both ½ day or full day options, the training focuses on the tenant eligibility and selection challenges of the Public Housing program. Beginning with a program overview, the session concentrates on income limits and rent payments, economic and social mix options, selection preferences, and waiting list requirements. A detailed discussion of assistance to non-citizens is included. In the full day session, training is provided in income verification and calculation requirements, including the handling of household assets. The course is primarily designed for those participating in the HUD Rental Assistance Demonstration (RAD) program.
This four-hour training is designed to provide an outline of effective marketing techniques for affordable housing properties, including HUD, Rural Development, and Low-Income Housing Tax Credit. It covers proven marketing strategies for affordable projects and provides tips in how to avoid non-compliance during the marketing of such properties. Issues covered include desired amenities, energy efficiency measures, and elements involved in a successful marketing program, as well as fair housing concerns in the development of a marketing program.
This full day course outlines the basic requirements of the Rural Development Section 515 Program. The training provides an overview of Section 515 Program regulations, including rent rules, resident eligibility, income restrictions, and recertification requirements. The session also includes a full discussion of Management Plan requirements, on-site maintenance plans, tenant allowances, assets, acceptable occupancy policies, tenant selection and unit assignment, and tenant grievance procedures.
This full day course outlines the basic requirements of the HUD Project-Based Section 8 Program, with particular emphasis on combining the Section 8 program with the federal Low-Income Housing Tax Credit. The training provides an overview of Section 8 Program regulations, including rent rules, resident eligibility, income restrictions, civil rights and nondiscrimination requirements, waiting list and tenant selection, occupancy and lease requirements, and recertification requirements. The session goes into detail with regard to the changes created by Change 4 of HUD Handbook 4350.3. The course includes a detailed discussion of combining Section 8 and tax credits, focusing on occupancy requirements and rents, tenant eligibility differences, handling over-income residents, and monitoring requirements. The training is designed primarily for those involved in the site management of Section 8 properties.
This ½ day course is one of our most requested by management companies. It features a detailed discussion of requirements related to the determination of asset value and income, and is applicable to all federal housing programs, including the low-income housing tax credit, tax-exempt bonds, Section 8, Section 515, HOME, and HOPE VI. Multiple types of assets are covered, both in terms of what constitutes an asset and how must they be verified. The course concludes with an extensive series of problems, designed to test the ability of the attendee to determine the value of an asset and calculate the income from that asset.
This course provides concentrated instruction over ½ day on the required methodology for calculating and verifying income. A comprehensive discussion of employment income is a major part of the training, along with military pay, pensions/social security, self-employment income and child support. A basic discussion of asset verification and calculation is included and the course concludes with multiple workshop problems. These problems test what the student has learned during the discussion phase of the training and serve to reinforce HUD required techniques for the determination of income.
This course provides concentrated instruction over a full day on the required methodology for calculating and verifying income and Assets and is applicable to all federal housing programs, including the low-income housing tax credit, tax-exempt bonds, Section 8, Section 515, HOME, and HOPE VI. A comprehensive discussion of employment income is a major part of the training, along with military pay, pensions/social security, self-employment income and child support. A full discussion of asset verification and calculation is included and the course concludes with multiple workshop problems. These problems test what the student has learned during the discussion phase of the training and serve to reinforce HUD required techniques for the determination of income from all sources.
The IRS published an update of the important Guide for Completing Form 8823, effective in January 2011. This full day course will cover all elements of the Guide, including definitions and examples of noncompliance, dealing with over-income households, understanding the risk of not recertifying tenants, traps relating to the use of common area, the General Public Use Rule, and a detailed review of new IRS positions relative to rents and fees. This training is designed for Housing Finance Agency personnel, senior management staff, compliance professionals and owners.
One of our most popular courses, this two-hour session is designed to assist site and property managers with improving their organizational and time management skills. The unique skills explained during this training will help management personnel defeat work overload, increase their effectiveness, take control of their time, and never again leave any job undone. Managers will learn how to make the best use of their time and resources and will learn a technique for follow up that is second to none. Training provided in this session can provide as big a benefit to the attendee’s personal life as it does for their ability to perform better on the job.
One of the most important skills any affordable housing manager can possess is the ability to interview applicants and residents and obtain the information required to determine eligibility – this is also one of the greatest weaknesses of most affordable housing managers. This training has been developed to address that weakness. This half-day session focuses on the interview process and provides concepts and tools that will aid managers as they conduct their interviews. Techniques apply to all interview settings including initial eligibility interviews, interim certifications and annual recertifications. The primary emphasis is on the initial eligibility interview since it is so critical to the housing process. The skills taught during this session will also assist managers in detecting fraud and in dealing with third parties when resolving discrepancies.
We also offer specialized training on sexual harassment and workplace diversity, managing properties with multiple programs, compliance traps with mixed income properties, AND a two hour training on the intricacies of acquisition/rehab projects. In addition, we are one of the few organizations approved to offer the Housing Credit Certified Professional (HCCP) © Review and Examination by the National Association of Homebuilders (NAHB). This is the most prestigious professional designation in the credit industry, and we are authorized to administer that exam in conjunction with our training. In addition to industry training, we provide a good deal of training for State Housing Finance Agencies, and we are the primary trainer for the Virginia Housing Development Authority (VHDA).
One of the most complex areas of the LIHTC program is the acquisition/rehab of existing properties. This training will assist managers, compliance staff, developers, and investors in their understanding of the various issues relating to these complex transactions. Placed in service issues will be explained, including the difference between the definition of placed in service for acquisition and rehab. There will be a detailed discussion of the requirements for tenant qualification on these projects, including an overview of the 120-day rule, safe-harbor rule, transferring residents, and Form 8609 elections.
The E-Book versions included with your purchase include .epub and .mobi. These also come with instruction for importing the file to your chosen device.
The online version of the Guide allows you to have quick and easy access on any device.
*A free AHRC account is required to access the online version of hte Guide.
Mr. Johnson has been involved in the development and management of residential and commercial enterprises since 1976. Prior to creating his own consulting firm, Mr. Johnson served as Executive Vice President of Beacon Construction Co. of Newport News for 12 years. Before joining Beacon in August 1983, Mr. Johnson was with K-Mart Corporation, Portsmouth Redevelopment & Housing Authority, and Suffolk Redevelopment & Housing Authority.
While with the public housing agencies, Mr. Johnson was responsible for the implementation of a variety of federally funded programs, including public housing, Section 8 housing, housing rehabilitation (single family and multi-family), Community Development Block Grant (CDBG), Urban Development Action Grants (UDAG), Urban Homesteading, and was a Section 202 Housing Consultant.
In his position at Beacon, Mr. Johnson was responsible for all development work relating to new projects and for ensuring the long-term financial feasibility of all projects undertaken by Beacon.
Mr. Johnson coordinated the development of over 70 multi-family housing complexes utilizing federal, state, and conventional financing, of which more than 40 used the federal low-income housing tax credit.
Mr. Johnson is President of A.J. Johnson Consulting Services, Inc., a full service real estate consulting firm specializing in due diligence and asset management issues, with a particular emphasis on properties utilizing the Low Income Housing Tax Credit.
Mr. Johnson conducts numerous seminars on housing related issues, including the Low Income Housing Tax Credit Program, Fair Housing, Section 8, HOPE VI, Tax Exempt Bonds and the HOME Program, and is a nationally recognized speaker on many areas related to the real estate industry. He has also been invited to train on tax credit compliance by the numerous State Housing Finance Agencies, Boston Financial, JP Morgan, and SunTrust Bank and is responsible for tax credit compliance in a multi State area for AIG Global Partners. He has also been authorized to instruct in Fair Housing and Tax Credits by the Virginia and Delaware Real Estate Commissions. He is the author of A Professional Property Manager’s Guide to the Low-Income Housing Tax Credit, now in it’s 11th. edition, which is specifically written to assist site and property managers in maintaining tax credit compliance. Mr. Johnson also assists clients in the structuring of projects that utilize tax-exempt bonds, including bonds issued by states, municipalities, and qualified 501(c)(3) organizations or governmental units, HOPE VI funding, and HOME funds.
Mr. Johnson served as a technical advisor to Congressional staff during the drafting of both the Low-Income Housing Tax Credit Program and the Fair Housing Amendments Act of 1988.
Mr. Johnson provides training in asset management, Section 8, fair housing and tax credit issues for numerous housing finance agencies, including Virginia, North Carolina, Mississippi, Georgia, Wisconsin, New Hampshire, Maine, Vermont, and Florida. His company has performed asset management reviews on more than 5,000 properties containing approximately 460,000 units since January 1995, and Mr. Johnson is a contributing author to The Low Income Housing Tax Credit Advisor, as well as being a member of the Board of Advisors to The Tax Credit Housing Management Insider, a monthly tax credit compliance guide. Currently, Mr. Johnson is a training advisor to the Housing Credit Certification Board of the National Association of Homebuilder’s, which is responsible for implementing the requirements of a national certification examination for tax credit management personnel, and carries the designation of “Housing Credit Certified Professional” (HCCP). Mr. Johnson was also a member of the Task Force that developed the Housing Credit Certification Exam on behalf of NAHB, and is a NAHB recognized Section 42 Trainer.
Mr. Johnson is Past President of both the Council for Affordable and Rural Housing, and the Rural Rental Housing Association of Virginia. He is also past-President of Homebase of the Virginia Peninsula, the agency responsible for coordinating services to the homeless on the Virginia Peninsula.
Mr. Johnson holds the S.T.A.R. (Spectrum Training Award Recipient) designation for demonstrated expertise in the regulations and management principles of Rural Rental Housing and is a Housing Credit Certified Professional (HCCP©).
Mr. Johnson has a degree in Political Science from Old Dominion University in Norfolk, VA.
As the Vice President of A. J. Johnson Consulting Services, Inc., Betty is responsible for overall company administration. Financial management, company operations, and personnel are Betty’s primary responsibilities.
Betty’s 35-year background in financial management and accounting are critical to day-to-day company operations. Prior to heading up the administrative operations of A. J. Johnson Consulting, Betty was an Assistant Internal Auditor with the Portsmouth Redevelopment & Housing Authority, Development Coordinator with the Suffolk Redevelopment & Housing Authority, and Office Manager with Beacon Construction Company in Newport News, VA.
Betty is a graduate of Virginia Commonwealth University with a degree in Business Administration.
Chris joined A. J. Johnson Consulting Services, Inc. in July 2006 after attending James Madison University. After an intensive three-month training period during which he worked at six different properties and received more than 50 hours of training, Chris began reviewing properties for clients in October 2006.
Chris has received the Spectrum Training Award Recipient (STAR) designation from Spectrum Enterprises for demonstrated excellence in the management requirements of the Rural Development Section 515 Program, and is a Housing Credit Certified Professional (HCCP©). Chris is responsible for the “Special Projects” section of our Company, and in that capacity, he handles property reviews that are extensive in nature or have unusual problems. He performs tax credit and Section 515 compliance reviews, as well as asset management reviews for various investor clients.
Chris designed and developed the AJJCS Client Dashboard & iOS and Android apps. He is responsible for maintaining these products as well as handling any additional IT needs the company has.
Teresa has been with us since May 1, 2008, and brings a great deal of diversified experience to the job. Teresa joined us after serving as Director of Property Management for a North Carolina management firm. In that position, Teresa supervised the operation of 1,700 units, was responsible for the hiring and training of regional managers and the lease up of new properties. She was also responsible for budget preparation and oversight.
Teresa has been involved in the multifamily business since 1991, when she began as an Assistant Manager at a property in Winston-Salem, NC. Since then, she has been a property manager (six years), the Director of Compliance for a major Virginia realty company (three years), a Regional Operations Specialist for a national development firm and a Regional Compliance Coordinator and Mentor for a Boston based development and management company.
With A. J. Johnson Consulting, Teresa performs asset management and compliance reviews on properties all over the United States. Her varied skills continue our tradition of offering the best consulting services possible to our clients. Teresa holds multiple industry credentials, including the Housing Credit Certified Professional (HCCP©), and the National Affordable Housing Professional – Executive (NAHP-E©) designation.
Jen joined the company on November 1, 2013. She brought extensive experience in customer service and finance from the hospitality industry when she joined the company in 2013 and that experience has proved invaluable in her understanding of tenant issues relative to our review of client files.
Jen is a Housing Credit Certified Professional (HCCP©) and has reviewed more than 15,000 tenant files since joining our company.
With A. J. Johnson Consulting, Jen performs on site asset management and compliance reviews on properties, and handles portfolio level desk reviews of tenant files for major syndicator and investor clients.
Linda Moss joined A.J. Johnson Consulting Services, Inc. as a Compliance Analyst on February 1, 2015.
Linda brings a wealth of experience with her that will provide an immediate benefit to our clients. She has been in the business of multifamily housing management since 1990, when she began her career as a manager of conventional apartment properties. She then moved into the tax credit field as the manager of a 266-unit LIHTC property in Richmond, VA, following that a short time later by becoming the Compliance Manager for a realty company.
From 1998 to 2005, Linda served as the Compliance Manager for two Richmond based companies, overseeing the compliance requirements for multiple properties in various locations.
In August 2005, Linda joined the Virginia Community Development Corporation (VCDC) and spent seven years as an Asset Management Portfolio Director with supervisory responsibilities on behalf of the equity firm for 40 properties. In 2012, Linda became the Compliance Management Director for VCDC and focused on monitoring compliance for approximately 60 projects. In addition to LIHTC compliance, she also monitored for HOME compliance, assisted developers with planning for acquisition/rehab projects, coordinated the contracting of tenant file reviews and conducted small group training for project sponsors.
Linda will be primarily responsible for desk reviews of Client files, but will also assist clients with portfolio oversight. The addition of Linda to our staff demonstrates our continued commitment to providing excellent service for our outstanding clients.