Project Completion and Close Out
HOME and LIHTC have slightly different project close-out requirements and procedures. These requirements do not generally conflict; therefore, for projects that have both HOME and LIHTC funding, the PJ and LIHTC project sponsor must comply with the requirements of both programs.
HOME Project Completion Requirements
When the project is fully leased, and presuming the construction close-out requirements (discussed in Chapter 3) have been satisfied, the PJ is required to ensure project completion steps are undertaken to start the affordability period.
Upon lease-up, PJs must require owners to report on rents and occupancy to enable the PJ to complete the Rental Set Up and Completion Form and enter information into IDIS.
Once the project completion data has been entered into IDIS and all the costs have been incurred, the PJ should mark the project as complete. The date associated with this project completion data is the date that the period of affordability begins for the HOME assistance. The PJ must contact the owner to notify it of the affordability period start and end dates. If possible, the PJ should also amend the HOME written agreement and deed restriction to include these dates. The date in IDIS may be altered to match the date on these legal documents.
PJs should note that not all units need to be occupied to enter completion data, and that completed units may be initially recorded in IDIS as vacant, but that the information regarding the first occupant must be entered into IDIS when available for the system to credit the unit as meeting HOME requirements. PJs should require their managers to report regularly until full occupancy of assisted units is achieved.
LIHTC Completion Requirements
Project completion under the LIHTC program is defined in terms of the placed in service date. The placed in service date is typically provided on a building by building basis when the first unit in an LIHTC building is certified as suitable for occupancy under state or local law.
Reconciling the Completion Dates under HOME and LIHTC
The completion date in IDIS and the placed in service date for the LIHTC program are different and the HOME period affordability could start either before or after the LIHTC-assisted buildings are considered placed in service.
From a practical standpoint this may have little operational impact on the project, as the requirements of the two programs run parallel during most of the affordability period. However, the property manager should be aware that the affordability/compliance periods may begin and terminate on different dates, even for projects where the period is the same for both programs (e.g., 15 years).
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This email is intended for general information purposes only and should not be construed as legal advice
or legal opinions on any specific facts or circumstances.