Tax credit files carry higher stakes than most: a noncompliant file can put credits at risk. This checklist mirrors what state agency monitors test.
Move-in certification (the file's foundation)
- Initial certification completed and effective on or before move-in — late initial certs are among the most serious findings
- Income at or below the applicable limit for the set-aside, with third-party verification supporting every source
- HOTMA-aligned income and asset methodology — LIHTC follows Section 8 determination rules, so HOTMA flows through
- Household composition documented; all adults signed
Annual requirements
- Recertifications per your state's monitoring requirements and your property's set-aside structure (100% LIHTC properties may have streamlined recert rules — know which regime applies)
- Student status verified annually — full-time student households need a documented exception, every year
Rent compliance
- Gross rent (tenant rent + utility allowance) at or below the applicable limit for every month
- Current, documented utility allowance from an approved source
- No side charges pushing gross rent over the limit (mandatory fees count)
The layered-property trap
HUD + LIHTC properties must satisfy both programs' readings simultaneously — the stricter rule wins on each element. Files that pass MOR can still fail state monitoring, and vice versa.
Audit-proofing routine
Quarterly: pull a sample, test against this list, log errors, sweep systemically for any repeat. The state's sample will find whatever your sample would have.
Tax credit question mid-file? 59AI answers instantly with citations — $19.99/month.
FAQ
What happens if a file fails? The agency issues noncompliance (8823 exposure); uncorrected issues can jeopardize credits — which is why owners escalate file errors faster on LIHTC than any other program.
Do HOTMA changes apply to tax credit files? Yes — LIHTC income determinations follow HUD rules, so HOTMA's income/asset changes apply.
Train LIHTC compliance staff with 59AI's accredited courses.