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Click here for print version of Compliance Coach Brochure
As you all
know, Tax Credit professionals have time to spare. The properties are
overstaffed and no one is ever stressed… Or wait, was that a dream I
had last night?
Must have
been! Who am I kidding? Tax Credit managers and compliance specialists
have one of the most stressful, thankless jobs there is. Anyone that has
been in one of these positions for more than a day knows this.
More importantly, YOU know this!
Tax Credit
management and compliance can be a very tricky business! The tenant
scenarios alone that you must deal with can easily trip you up and put you
in noncompliance, let alone rules like the Full-Time Student Rule, Unit
Transfer Rule, The Unit Vacancy Rule and The Available Unit Rule. There
are so many scenarios and so many factors that come into play.
The worst thing is…
One mistake
… one uncooperative tenant … one fraudulent applicant…
can cause you to lose THOUSANDS of dollars in Tax Credits! THOUSANDS!
Most of the Tax Credit questions you have are
not simple either. They don’t just pertain to a single rule. Rather they
are entangled with a long, drawn out resident scenarios. The
questions you have not only have to be answered on a compliance level, but
also have to be answered within keeping of local landlord tenant laws,
fair housing and they must have a practical application within the
realistic world of property management and resident relations. That is a
lot!
You know what
I mean, you get an applicant that comes in with 3 kids, 1 that is a
full-time student living away from home, and one that is a friend’s kid
that the applicant doesn’t have custody of, plus a boyfriend that you
aren’t sure is going to be living in the unit or appears to be hiding
information and you have to qualify them for a Tax Credit apartment.
Or you get a
person that comes in with a living will and a slew of stocks, bonds and
retirement accounts that go beyond the normal income & asset scenarios and
you have to verify and evaluate them and determine how they will affect
eligibility.
Or what about
the resident that won’t cooperate with the annual recertification process
and is stirring up trouble with the other residents convincing them not to
cooperate with the process as well causing you to be late with your annual
recertifications!
Fair housing
is a huge factor. Landlord/Tenant law has to be considered. And now we
have to deal with potential terrorism threats at our properties, mold
problems and insurance rates that are sky high!!
When you try
to get answers to your questions or guidance, what usually happens? The
deer-in-the-headlights factor! Right? That is if you can get a hold of
anyone to talk. Most of our questions need answering immediately or else
we run the risk of losing an otherwise great potential resident. Or we run
the risk of making a decision without proper guidance and end up creating
more work and potential noncompliance!
Sure, you
can call your State Agency, your investor, your accountant or your
attorney. But…
If you call your STATE AGENCY OR INVESTOR…
what happens? You call attention to yourself and your compliance problem.
You also are not ensured of getting a correct answer! Especially when the
question relates to an entangled resident scenario that encompasses
property management techniques, fair housing, landlord/tenant law as well
as Tax Credit compliance. Certainly you should ascertain your State
Agency’s and your investor’s opinions, but you can’t stop there as their
opinions are limited to their scope of expertise and you can’t be sure how
extensive that scope of expertise is. State Agency and investor personnel
are the first ones to tell you they are not experts in property management
and fair housing! They will answer the question as it pertains to
compliance and compliance alone! It may not have a sound basis in
realistic management techniques, meet fair housing laws or be legally
sound according to your local/landlord tenant law.
If you call your ATTORNEY OR ACCOUNTANT…
what happens? Well, you can expect to pay anywhere from $200 to $400 per
hour! Yikes!! That is just out of the question with your limited budgets.
Plus, most attorneys and accountants are not experts in BOTH Tax Credits
and property management. Again, you will most likely get a very
one-dimensional answer that doesn’t have any practicality in the real
world and often doesn’t encompass the all important fair housing issues.
 Hello, my name is
Elizabeth Moreland. I own and operate the Housing Credit College and
Elizabeth Moreland Consulting and through these companies I work hard to
make Tax Credit managers and compliance specialists compliance confident!
I once was a
property manager and a compliance specialist just like you. I remember the
frustrations, the fear of noncompliance and the constant nagging questions
… but mostly, I remember the LACK OF ANSWERS! First, it was difficult to
find anyone to ASK a question to. And then, if I was lucky enough to talk
to someone, it was nearly impossible to get a STRAIGHT ANSWER!
I’ll be
honest, the fear of noncompliance was running amok at my properties!
So I decided
to do something about it! I immersed myself in the Tax Credit Program, the
Code and anything I could get my hands on. I read, I studied … and then I
read and studied some more. Every chance I could get, I networked with
others in the business and gleamed as much information from them as was
humanly possible. I pestered my State Agencies. I called the IRS. I
chatted with the gurus of the day. It took a
lot of time. A lot of work. And a lot of perseverance.
To this day, I
use the same approach to keep myself in the know. I have accumulated an
incredible library of Tax Credit books, Code provisions, and articles on
the subject. I have accumulated a list of industry contacts that I can
call at a moments notice to chat with about difficult scenarios and I have
a working relationship with the majority of State Monitoring Agencies
across the country and with the IRS personnel administrating the Tax
Credit Program for Congress. It takes a lot
of time. A lot of work. And a lot of perseverance. But the
good news is…
Fear of
noncompliance no longer controls me! I can honestly say … I am compliance
confident!!
"Finally, someone who can
translate IRS verbiage into English. Yahoo!”
Teri Hoerntlein, Comm. Manager, Southern Cal.
Housing, Rancho Cucamonga, CA
"Elizabeth Moreland is
completely Jiggy with Housing Credits."
Jon Brown, Programmer, Real Page, Inc., Dallas, TX
"The absolute industry leader! A
must for anyone in Sect 42 housing."
Kristin Saddoris, Dir. of Section 42 Development, Conlin Properties Inc.,
Des Moines, IA
"Elizabeth brings a passion to
the housing credit industry with a vast array of knowledge, practice,
application, hands-on experience, then sprinkles it with a sense of
humor." Donna Overstreet, General
Manager, Cypress Point, Casa Grande, AZ
"Tax credit property onsite
staff & managers deserve the knowledge Elizabeth shares. She definitely
delivers.” Barbara W. Soloway, Senior
Property Officer, Westbrook Housing Auth, Westbrook, ME
So what does this have to do with YOU??
What if I
told you that for LESS THAN $1.92 PER DAY…
þ
You could have me and my
knowledge on your team answering your compliance questions.
þ
You could fax or email me your
scariest, strangest or most confusing compliance scenario and I will you
my expertise and experience to help you resolve it!
þ
You'd have my GUARANTEE that you’d
actually get a response to your question in 48 hours or less!!
Sounds like
heaven on earth, right? A Tax Credit manager or compliance specialist’s
dream! Actual answers to your questions! Straight answers backed up by
solid research, years of experience and documented expertise! And all you
have to do is send in a faxed question or email your scenario and I will
respond to you within 48 hours or less GUARANTEED!
We call it our
Compliance Coach! A technical
support hotline for YOU to get the answers to your questions.
Whether you just want to run something by me or you have a problem that
you haven’t been able to get anyone to give you a straight answer on, with
the Compliance Coach, I AM ONLY FAX OR EMAIL AWAY and I won’t
charge you an arm & a leg!!
Click here to sign up today!
Click here for print version of Compliance Coach Brochure
"The Compliance Coach has
been an excellent resource for me in my responsibility for the compliance
monitoring of multiple projects and thousands of units. It's great
to have a third party consultant that is experienced in LIHTC compliance
and is so easily accessible." Cathy McCoy
Soakai, Compliance Specialist, Evergreene Management Group, SLC, UT
For a mere
$699 per year, you get:
-
One hour per month
FREE to discuss your compliance issues with the industry’s most
respected compliance expert --
Elizabeth Moreland! Fax me. Email me. You get 1 hour of our
time each and every month to discuss whatever issues or questions you
have. My Compliance Coach discussions averages 10 to 15 minutes
and I have never had a person use more than 1 hour of their free time
unless they requested we complete a special project for them. You pay
$699 per year. Period the end! (Unless of course you hire us for
additional projects, opinion letters or consulting.)
-
Access via our
TOLL-FREE telephone number, TOLL-FREE fax or e-mail!! I will
give you our toll-free fax number so you don’t have to spend extra money
making contact. It is on our dime. I will also give you a special email
address as I know that email is one of the most convenient and useful
tools to managers. I am serious when I say I will make myself available
to you!
-
A UNIQUE
perspective … state, national and most importantly REALISTIC!!
I personally have been working with this Program since 1989 and have
done everything from site management to compliance specialist to a
director of a large compliance department. I have also been a leading
industry trainer since 1995. My advice is proven and works in the real
world!
-
A GUARANTEED
response in 48 hours or less!!! Our office receives hundreds
of phone calls, countless emails and faxes. They are hard to get through
in a day. Plus, I travel a lot. But as a Compliance Coach
customer, I rank you as our most important. You get first priority! I
will give you an account number and all you have to do is reference it
so I know you get top priority. I then respond within 48 hours.
-
ONE affordable
price for your entire portfolio!!!!
You pay only once not for each property!
-
The SECURITY &
CONVENIENCE of assigning up to 3 key people at your company who can
use the Compliance Coach for the same price!!!!! Remember, I was
a manager once too. I’ve supervised site personnel. I understand that
you want to maintain control over who is able to contact your outside
consultants and to ensure that the information that is gained is given
to key people who have the ability to share with other sites so all your
entire staff learns from the answers given and you reduce repeat
questions.
All of that for less than
$1.92 per day!!!
So for only $699 per year …
PER YEAR NOT per month, per day or per hour...
PER YEAR… you can have the confidence to
know that I am there to help you answer your compliance questions and help
you resolve your difficult scenarios! For less than $59 per month, you can
have the guarantee that you will get a response to your email or fax
within 48 hours and for less than $1.92 per day I will answer your
question with sound, practical advice based on the latest rules,
interpretations and opinions held by our Industry.
Sound
information that is based on true Tax Credit compliance expertise, steeped
in reality and filled with proven management strategies! All for less than
$1.92 per day!!!
"Thanks for your outstanding consulting
services. It's great to have an organization with your expertise to call
upon in our hour of need!!" Joan Taylor,
Property Administrator, Corcoran Jennison Management Company (Villages at
Marley Station), Glen Burnie, MD
Click here for print version (PDF) of Compliance Coach Brochure and
Sign-Up Form |
Questions… Questions…
Questions???
The most common start to any telephone call I
get goes something like this…
“Elizabeth, help!
I’ve got a question and can’t get anyone to give me a straight answer.
Can you help me?”
Sound familiar? It’s one of the biggest frustrations for site level
staff…
L
NO ONE TO TALK TO!
L
NO ONE TO GET ANSWERS FROM!!
L
NO ONE TO USE AS A SOUNDING BOARD AND TO HELP THEM WORK
OUT A CONVOLUTED APPLICANT SCENARIO!!!
Stop setting your site staff up to fail and
give them what they need most…
Answers!
Answers!!
Answers!!!
Here is just a sampling of some of the most
recent Tax Credit compliance questions we have gotten from our
Compliance Coach customers and most importantly, the answers they
needed!
Question: I
am unsure of the policy of the wait list. How detailed do I have to be and
what are the requirements? I am the manager of a property that has
been up and running for approximately 3 years, although I have only been here 6 months. The
current
wait list has approximately 5 times the applicants than the number of
apartments that I have. There must be a method to this madness, but
unfortunately, I have been unable to determine the “system” they were
using. Do you have any suggestions on how to proceed in the future?
Answer: Although the IRS does not impose any
wait list requirements, the owner may have agreed to requirements with
other entities. Review your Regulatory Agreement, funding and syndicator
agreements to determine if you have any wait list requirements. For
example, your owner may have agreed to give preference to households who
are on the Public Housing wait list. If a separate promise or agreement
was not entered into, you will need to create your own policy.
A good starting point is to create
a wait list application and agreement (you do not have to verify the
information on the application). The agreement should state how many
attempts you will make to contact the household and that the household
will be removed if you are unable to reach them or if they do not respond.
Wait lists should be updated regularly. Stay in contact with the
applicants to determine if any changes occurred that would make them an
unqualified household and to make sure they are still interested.
Retain the wait lists to show the attempts made and the ending result.
If used properly, wait lists can be useful in reducing vacancy and
expenses. You may also want to create a Wait List for each unit type you
have. For example, 2 BR/2 BA 60% Income Limit Units; 2 BR/2 BA 50% Income
Limit Units.
Question: We
are planning to
purge our former resident files, and need to know what we must keep. Our
files are very thick, and we have limited storage space. What must we keep
in order to prove the resident qualified the unit?
Answer: Unfortunately for the on-site team,
you must keep almost everything! When storing records of former residents,
you must retain the following documents: Application, Verification forms
(including clarifications), Tenant Income Certification, Lease and
addenda, and HUD/RD documents (if applicable). These documents must be
retained for each initial certification and recertification.
You are allowed to purge the files
of information that does not apply to eligibility, such as letters to
residents advising them that the rent is past due, or disturbance notices.
However, in addition to the documents listed above, it is suggested that
you retain a copy of the resident’s ledger, showing the date and amount of
each rental payment. If a resident paid an amount in excess of the
maximum allowable rent, documentation of the reason should remain in the
file. For example, a resident breaks a window in their apartment,
and must pay for the damage. If the payment for the damage was made with
the rental payment, then you must keep documentation that the payment was
not for rent. If management did not renew a resident’s lease,
documentation of the reasons for non-renewal should be maintained.
Also, retain documentation of the correction of any noncompliance issues
raised by the State Agency or other auditors. The best time to purge
your files is during the year-end audit.
Question: An
applicant who owned a home signed a Quit Claim Deed, which turned the
property over to his son about a year ago. Do I need to verify this?
If so, what information do I need to obtain?
Answer: A Quit Claim Deed is treated as an
asset disposed of for less than fair market value. The applicant needs to
provide you with a copy of the deed, and a statement of the market value
of the home. The difference between the actual amount paid for the home
and the fair market value will be considered an asset disposed of for less
than fair market value. Therefore, if the home has a fair market value of
$100,000 and the son only paid $1.00 for it, the disposed of asset is
$99,999. You will then treat the disposed of asset ($99,999, in this
example) as if the household still has the asset for the next two years.
This means this value will be placed in the asset income calculations
which will force the manager to calculate the imputed asset value.
I’ve
answered hundreds and hundreds of questions for site managers,
compliance specialists and other Tax Credit professionals via our
Compliance Coach service!
Some simple
in nature. Some very complex. I am not afraid to answer your question
and will always be sure to tell you when it is based on current
regulations, a common industry opinion and/or my own opinion.
I’ve worked
in the Tax Credit industry since the beginning. I am well aware of the
history, changes and current environment. I've been on site. I've been
in compliance. I've worked closely with State Agencies and investors
across the nation.
As a
Compliance Coach customer,
I will put all that to work for you!!
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