Compliance Monitoring
AHFA's compliance staff periodically inspects each development receiving HOME funds and/or Housing Credits to ensure that it is operating in compliance. Monitoring procedures may include mail-in audits, on-site visits and review of tenant incomes, rent records and living conditions.
Audits are scheduled at random throughout the year. AHFA audits its Housing Credit-funded developments every three years, and its HOME- or bond-financed developments every year.
AHFA charges $750 per unit for the project's compliance fee.
Property owners are responsible for maintaining compliance. AHFA may assist in this effort, but owners should consult their legal or tax counsel for guidance in maintaining compliance with the Internal Revenue Code and program regulations.
If you have any questions, please contact the Compliance Department.
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AHFA offers training by request for compliance staff of AHFA-financed multifamily housing developments. View previous training materials:
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The owner must notify AHFA prior to any change in management. The following documentation must be completed for the new management company and provided to AHFA for approval:
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Notify AHFA’s compliance department when Project damage occurs using AHFA’s Property Damage Notification form, submit a plan of corrective action, and notify AHFA’s compliance department when the damage has been repaired.
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AHFA's compliance manual is designed to aid owners and managers of multifamily projects which have received an allocation of Housing Credits and HOME funds from AHFA. These allocations are made pursuant to the rules and regulations established for the respective programs.
For the convenience of the owners, AHFA has combined the compliance procedures for each program into one manual. It should be noted that these are separate programs with differing compliance requirements. Owners should carefully note which regulations apply to their projects. If both of the aforementioned funding sources are combined, the more strict regulations will apply.
The procedures outlined in the manual are guidelines for helping owners ensure that assisted projects remain in compliance with the Internal Revenue Code (the “Code”), the HOME Investment Partnerships Program Final Rule (24 CFR Part 92) (the “HOME Rule”), the Regulatory Agreement, and other applicable regulations for the duration of the compliance period. This manual is not intended to be all-inclusive. Rather, owners should review the manual and accompanying regulatory information in the “Code” and “HOME Rule” with their legal or tax counsel to determine the applicability of said information to their projects.
Compliance with the requirements of the code, the HOME Rule, and other applicable regulations is the building owner’s responsibility. AHFA’s obligation to monitor the project for compliance with the requirements of the code, the HOME Rule and other applicable regulations does not make AHFA liable for an owner’s noncompliance.
The compliance period is established within the Declaration of Land Use Restrictive Covenants; specifying the use restrictions required under the Code, the HOME rule, and those certified by the owner during the allocation process.
The manual provides instructions on determining eligibility of families for occupancy, the maximum rents that can be charged, record-keeping procedures, occupancy rules, provisions for monitoring project files, and certifications.
All projects participating in one or both of the HOME and Low-Income Housing Tax Credit Programs are subject to compliance monitoring with rules and regulations of the Code, the HOME Rule and all other applicable regulations.
Questions regarding Housing Credit, HOME, and Bond compliance issues and procedures may be emailed to [email protected].
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The Manager of the Year award recognizes outstanding management staff at AHFA-funded multifamily housing developments. Nominees are evaluated on tenant relations, experience and education, the complex's curb appeal, and AHFA program compliance.
Site and property managers for any development financed with AHFA-administered HOME funds or Housing Credits are eligible.
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In 2000, the Internal Revenue Service (the “IRS”) released Technical Advice Memoranda (the “TAMs”) published by the National Office in connection with audits of tax credit projects. A Technical Advice Memorandum normally is issued by the National Office of the IRS upon request from a field office in connection with an audit of a taxpayer when the IRS agents need guidance on technical issues. Like a private letter ruling issued in response to a taxpayer request, a TAM pertains only to one taxpayer and is not considered definitive authority. Like a private letter ruling, however, a TAM also is a good indication of the IRS National Office’s position on technical issues, especially on issues where there is no other direct authority.
All of the TAMs address issues pertaining to the determination of the tax credit basis of the projects. However, they are not specifically concerned with technical issues under Section 42 of the Tax Code dealing with low-income housing tax credits. Instead they deal with matters relating to the inclusion in depreciable basis of the property of various fees and costs incurred by the owner of the property during its development and construction.
For additional information, download a letter of clarification from the U.S. Department of the Treasury, dated October 8, 2000.TAM - 200021509: Developer Fee Note Is Includable in Eligible Basis
TAM - 200043015: Bond Costs for Low-Income Housing Project Not Includable in Basis
TAM - 200043016: Construction Loan Costs for Low-Income Housing Not Includable in Basis
TAM - 200043017: Construction Loan Costs for Low-Income Housing Not Includable in Basis
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AHFA will review a random sample of household files and physically inspect a random sample of low-income units.
The following records and/or documentation will be reviewed and must be available on the scheduled review date:
File Review
AHFA DMS Authority Online System Tenant Data (updated monthly)
Rent Roll (Required information can be found in the AHFA Compliance Manual Tab Below.)
Income and Rent Set-Aside Report
Additional Property Reports (based of application selections)
Rental/Operating Subsidies
USDA Rural Development
HUD
Tenant Needs
Elderly
Bedroom Type
Disabled/Homeless
Public Housing Waiting List
Mobility Impairments
Sensory Impairments
Supportive Housing Needs Set-Aside
MRMI
Project Utility Allowance(s)
Total number of units receiving rental assistance.
Type(s) of rental assistance and which units are receiving the assistance (Section 8, HUD, Rural Development, Owner-Financed, Other)
Vacancy Report
Affirmative Fair Housing Marketing Plan and documentation to show how management is implementing the plan
Waiting List (if applicable to your property)
Properties with HOME Funds
MRMI
Disabled
Public Housing
Advertisements and contact letters (if applicable to your property)
Properties with HOME Funds
MRMI
Disabled
Public Housing
Tenant Services
Tenant household files, including initial files (the tenant household file order can be found in the AHFA Compliance Manual Tab Below)
The physical inspection of the project will include the following areas and is based on the National Standards for the Physical Inspection of Real Estate (NSPIRE).
NSPIRE Inspectable Areas
Unit
Inside
Outside
AHFA Inspectable Areas
Property Amenities
Unit Amenities
Required Amenities
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The following forms are used in conjunction with the low-income program:
Annual Owner’s Certification (AOC)
Income Verifications
Student Certifications
MRMI
Homeless
HOME Program
Housing Trust Fund Program
HOTMA
Effective January 1, 2025, the Imputed Income Limitation is $51,600
Effective January 1, 2026, the Imputed Income Limitation is $52,787
Effective January 1, 2025, the Passbook Savings Rate is 0.45%
Effective January 1, 2026, the Passbook Savings Rate is 0.40%
Bond Program
Rent Roll
Disability Certification
Set-Aside Report
Housing Credit Income Set-Aside Report (100% Low-Income Property)
Housing Credit Income Set-Aside Report (Mixed Income Property)
VAWA
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AHFA's HOME and Housing Credit programs are subject to income and rent controls designed to ensure the units remain affordable.
The U.S. Department of Housing & Urban Development determines these limits on an annual basis. Income limits are adjusted for household size and in certain unusually high- or low-cost housing areas. Maximum rents are set for each unit size, based upon 30 percent of the area's maximum allowable income for specified household sizes.
Income/Rent limits may increase or decrease from year to year and are not necessarily representative of market conditions.
HOME Investment Partnerships Program (HOME)
AHFA National Housing Trust Fund (HTF)
Low-Income Housing Tax Credits (LIHTC)
For Housing Credit Program Income/Rent Limits, visit:
2025 Non-Metropolitan Income/Rent Limits (for Housing Credit-only developments)
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February 2, 2026
Due date for the DMS Authority Online Management System tenant event data submission.
The required tenant data must be for all tenant events, including all move-in and move-out occurrences, income recertification, and unit transfers from January 1st to December 31st.
Once all the tenant events have been entered and finalized in the DMS Authority Online Management System, an email must be sent to [email protected] to inform the AHFA compliance department you have finished.
March 2, 2026
Due date for the Annual Owner Certification.
If your property received Housing Credits, Housing Trust Funds, or Bond financing (or in any funding combination) and you have received 8609s for your property, you need to use AHFA DMS to complete the Annual Owner Certification.
If your property only received HOME funds, you may use the Annual Owner Certification for HOME Only properties. You must submit a rent roll as of December 31st with the Annual Owner Certification.
If your property received Housing Credits, Housing Trust Funds, or Bond financing (or in any funding combination) and you have received 8609s for your property, you may use the Annual Owner Certification. You must submit a rent roll as of December 31st with the Annual Owner Certification.
May 1, 2026
Due date for Form 8609 Schedule A (8609-A forms) for all properties which received Housing Credits, Housing Credits with HOME funding or Housing Credits with Multifamily Bond financing and were still within the compliance period in 2023.
All 8609-A forms must be sent electronically by email, flash drive, thumb drive or memory stick. Schedule A forms submitted by paper will not be accepted. 8609-A forms sent by email must be sent to [email protected].
Due date for Financial Statements.
All financial statements must be sent electronically by email, flash drive, thumb drive or memory stick. Paper financial statements will not be accepted. Emailed financial statements must be sent to [email protected].
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The AHFA DMS Online Management System allows organizations working with AHFA to manage information about their funding awards.
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This schedule may change during the year.
AHFA provides a 15-day inspection notification.