HOTMA Horizons:
Navigating the New Landscape of LIHTC Regulations

Hello, everyone. We're gonna wait just a few moments before we start just to make sure that everyone has the opportunity to join. Go ahead and say hello in the chat if you'd like to. We'd like to know who you are and and maybe where you're joining us from or what company. We've got a hundred and seventy six people in so far now up to one eighty. So I'll go ahead and get started. Hello and welcome to today's webinar HOPMA Horizons Navigating the Landscape of LIHTC Regulations. My name is Chris Ann Geico and I am the senior VP of content strategy at Grace Hill And I am very excited to bring you this webinar as we have just wrapped up the last of our updates to our tax credit basics with the new HOPMA changes. So before we get started, just a few housekeeping items. Today's webinar is being recorded and will be shared with all registered attendees later this week. As an attendee, you will be in listen only mode. This will help any outside noise and just to ensure that everyone can hear, our speaker without any interruptions. But if you have any questions or you want to engage, there is a little Q and A box located down at the bottom of your screen. You can just click there and type your question and I'll have I'll be watching the chat. We also have, our wonderful Stephanie behind the scenes, that is monitoring the chat. So, very exciting. And if, Christine, you wanna move to the next slide. Just by attending our live event today, you are automatically entered into our getaway giveaway. So we will draw one grand prize winner. They will win a two thousand dollars Virgin Voyages cruise voucher, plus a thousand dollars in Visa gift cards just to help get you to the port. We will draw that winner on December twentieth and just in time for Christmas. So restrictions do apply. See our site for more details. So now for the good stuff. I'm going to tell you about our wonderful speaker that we have with us today, Christine Martin. She has been in the affordable housing industry for more than twenty three years, spending time with both private and public sector groups. She founded Bennett Martin Consulting in twenty eighteen. She helps multiple, as you can see after her name, multiple industry certifications in every aspect of affordable housing and constantly seeks out new information on this ever changing industry. Christine is a member of the National Association of Home Builders, HCCP Board of Governors, and the Homes on the Hill, Hilltop area of Columbus, Ohio advisory board. She enjoys speaking on all aspects of affordable housing at conferences, webinars, and in small groups. She has also written several articles for various affordable housing organizations. Christine has two bachelor of arts degrees from Otterbein University. Welcome today, Christine. Thank you very much. So alright. Here we are. HOPMA. So this, couple of things I'm going to go through are just a little bit of the history of HOPMA. This is where I usually say, if you're ever in Final Jeopardy, you hope that this will be the question and you will know the answer because of this. So HAMA actually stands for Housing Opportunity Through Modernization Act of twenty sixteen. It actually amends section three, eight, and sixteen of the US Housing Gap of nineteen thirty seven. The intention of it was to streamline administrative burdens between federal programs and private owners. The implementation of it has been delayed. So if you've been following along, let's look at the math. It was actually the act was in twenty sixteen. We are just about to turn the calendars over to twenty fifth or twenty I almost said twenty fifteen. Like, we're gonna time travel, although it does feel like time traveling sometimes. But we're about ready to go into twenty twenty five. Part of the delays are on the HUD side, and they will be the first to admit it. This has been a rather revolutionary set of changes between the methodology that we're gonna be talking about today, talking about income, assets, what all happens with with what we do on the tax credit program. But there are a lot of changes on the HUD side, and they not only had to change their software, but they had to change things like their model lease. They had to change their tracks guide, which is how their their whole side works. That's a whole separate subject that I will say let's be thankful we're not talking about that today. We're gonna be focusing on what we need to focus on. But I will say that some of these delays have carried over to the tax credit side and some haven't. So we'll be talking about that throughout the the next hour or so and what that means to us. So some of the things that have changed that affect us on the tax credit side, we have some new definitions to income and assets. We have new verification standards. We have new definitions of household members. And then we have this kind of new to us, if you will, annual adjustment factors. And we're gonna be talking about what those are, what they mean to us, when they go into effect, and what we need to do, and what we need to do kind of in this, I guess, settlement period, if you will, as we're getting used to and then fully implementing HOPMA as it goes along. So some income changes that have happened. They did a lot of clarifying. And when I I wanna stop here and will probably say again. HUD's main vehicle of telling us the rules and regulations that we follow that the IRS adopted early on in the days of the tax credit program are rooted in, first of all, in the twenty four CFR. They go into what we we talk about part five definitions of income. Traditionally, we have always gone to the HUD occupancy handbook, which is known as the HUD forty three fifty point three. For lack of a better term, I have always referred to it, but kind of as the HUD Bible when it comes to how do we look at income? How do we calculate income? How do we make sure that we have the right paperwork in it? And that's been used for the HUD programs. And then also carried over to the tax credit program. The last time they did an overhaul or did updates to that handbook per se was back in twenty thirteen. And they knew just after they even published it that there were changes. And so for years and years, HUD has said, we'll be publishing changes to the HUD forty three fifty point three soon. It got to be the point that my definition of soon was not HUD's definition of soon, and we have been kind of laying in wait for these changes. In the meantime, there have been several documents that have been published since then and actually amendments published in the twenty four CFR that affect what we do. We also have to now follow and will be following, and I'll talk about kind of the implementation of that with now the HOPWA changes. But bear in mind that if you go and you look at the HUD forty three fifty point three that is on the HUD website, this language that we're gonna talk about is not there. So we kind of have to be mindful that we are going to need to understand that we are going to look at the HUD forty three fifty point three, but also that these other documents and these memos that have been published since affect what we do. Now HUD will publish stuff. They've got a lot of stuff on their HUD Exchange website. Some of the things I'm gonna be talking about today is exactly where they are housed. They have put together on, HUD. It's actually, hud exchange dot info on their website. They've put a lot of helpful tools out there. So I would encourage you all to look for those. It's easy to find with a quick Google search. And I stop and say here, I'm not an employee of Google nor any of my family. We do not receive any proceeds from Google. It's just everybody seems to understand Google. But, anyway, some of the things that have happened now with what's been in HOPMA are some better definitions of things. Some of these things have now updated to where we are as far as life in twenty twenty four. If you think about the HUD forty three fifty point three being last updated back in twenty thirteen, if you would have started talking about things like DoorDash and Grubhub and all of these gig economy things, those were not common if even known at that time. This is stuff that's evolved over the course of time. So the nice thing about the hot load guidance is that it's bringing in some of that and giving us some good guidance. And before, we were looking at the HUD forty three fifty point three and just trying to do the best that we could and make reasonable determinations of income or reasonable, definitions of what we were seeing. So in the HAMA, they have clarified, the difference between temporary or one time jobs. They talk about things like tax refunds or tax credit payments, economic stimulus payments, federal census, so employees of the federal census, certain gifts, non nonmonetary in kind donations, and then lump sum additions such as to assets such as lottery winnings. So let me back up just a bit. In the HUD four thousand three hundred and fifty point three, we will use to the term temporary or sporadic income. And I think a lot of folks struggled with what that meant. So the definitions in HOPWA give us a better time frame of that. There are some things that will be just one time jobs that there is nothing to count. I used to give the example, in classes before before Hotmail came out that, I used to do market research studies, and I would get paid fifty bucks to taste coffee and give my opinion on that. That wasn't income because there was no way to predict if it would ever happen again, what the amount was. It was just they were paying they were giving me fifty bucks for my opinion. There are also some other temporary jobs that are just going to be very finite in time and not gonna be counted as far as income. I still would encourage anyone if they're if they're not sure of something, go ahead and count it. Or if they are if they do feel that it truly is temporary or one time and they are, addressing something that was disclosed by an applicant or a resident, that they add a clarification record to the file indicating we're not counting this because it was a one time thing. This isn't going to occur again. HAMA goes on and talks about tax refunds or tax credit payments. So this is actually we're not gonna count your tax refund. That's not income. We're also when we talk about assets, we're going to make an exclusion of that, amount of that tax refund or a tax credit if it's been within that last twelve months. But we'll talk about assets a little bit later. I'll just use leave that out there as a teaser. Same thing with those economic stimulus payments. Now, maybe I'd say, thankfully, we have not been like we were in the years twenty twenty and twenty twenty one where we were receiving those, but it addresses those that that's not to be counted as income. It goes on and specifically talks about federal census employees. So as long as the person is, a temporary employee collecting data, the rule says no longer than six months, then we're not gonna count that as income. That that's just, in essence, kind of this temporary or one time job. It would only be, if the person was employed by the Census Bureau as a permanent or a part time employee, but not just for the knocking on doors, interviewing folks, and that sort of thing. We talk about certain gifts. So this is kind of where I've always tried to explain it as there are folks that rely on gift income, meaning that someone is paying a bill on their behalf and there's a pattern to it. I have an applicant right now that her ex husband pays all of her utility bills. That would be gift income. We would be counting that. Now what I what's not considered as gift income are those gifts that come for birthdays, Christmas, the what I call the I love you gifts. I saw this at the store. I thought of you, so I bought it for you. That's not gonna be considered as income. The, oh, gosh. You got all the a's on your on your on your report card. Have, you know, have this. That's not gonna be income. Now granted, if it's if it's someone under the age of eighteen, we wouldn't be counting income anyway. But if I think you all understand or hopefully understand what I'm getting at. The other thing that they made specific to the HATMA language was nonmonetary in kind donations. So that's a very meaty phrase there. This is talking about folks that have to rely on going to a food bank to get food, or they get they go to, one of the churches and they get a voucher for a mattress, or they get a voucher to go to the thrift store to buy clothes. That's not gonna be income, and we're not counting it. And HUD was very clear about that kind of finally. I think a lot of us already were practicing it, but it's nice to actually have it in writing from HUD. And, also, there was a lot of language about lump sum additions to assets, so lottery winnings. And we did in HUD before in the HUD forty three fifty point three, it does talk about lump sum additions. Now in that inference, it used to talk about, delays in payments. So if I applied for Social Security and I applied today, but I wasn't awarded for six months, and at that six month mark, they gave me a big lump sum back to the day that I applied, that was already we were already told that we're not counting that as income, that we would just be picking up the periodic income, the monthly amount, and casting that forward over a year's time. So some of that hasn't changed. Some of that has changed. And, we'll we'll be talking a little bit more about about some of these lump sum things just to get an idea of what what they're actually meaning these days. So couple of other language, and then we talked about, talked about gig economy gig economy a little bit, but they talk more about self employment. And I think this is a direct answer to the fact that we have so many folks that have either a primary job or a secondary job that relies on what we have typically now called gig income. So this could be your DoorDashers, your folks do Grubhub, drawing a blank at some of the other names. But every time it seems like every time you turn around, there's some new delivery service. The that would have just went out of my mind. Isn't that horrible? The Instacart. That's what I was trying sorry. Was trying to think of. So how we calculate those And what it did is emphasize that we look at net income, not gross. I think that there were a lot of folks that were having their applicants or their residents pull up some of those reports that come out of the apps that these folks use to track their their money and was counting that, not allowing for the fact that if I'm driving a car and delivering all over town for any of those services, I have expenses. So it talks about making accommodations for that. So asking them about this is what you this is what you grossed. What are your some of your expenses to try to get to a correct net? I think the challenge that we have, and I think this is something that we've kind of always had when we have folks that were self employed, is, I know when I was in property management, I always hoped they had been doing this business for more than a year so that we could look at a tax return because that I could I could rely on that. I could rely on that Schedule C and feel good about it. But we have a lot of folks that kind of jump in every once in a while and start these new things, whether they continue to do it or not, but they don't have a tax return. So what do we do at that point? So it gives us some guidance on that again that we are taking the best information that we can. So trying to find out what they what they are earning from these these gigs sort of jobs and then kind of guiding them to get to that net income. I will tell you that for a lot of my applicants over the years, that's been a little bit of a foreign concept. So if they've not filed taxes or they've not filed self employment taxes before, you may need to guide them to some of the documents provided by the IRS to help them understand. And it could be as simple as giving them a copy of the Schedule c form so that they can see some of the things that they can deduct to try to get to that net income. I wanna talk a little bit about some of the other stuff that was in HOPWA full time dependent students with employment earnings. Now that hasn't changed. So we still if we have someone who's over the age of eighteen and they are still a full time dependent, we are going to only count a certain amount of their employment income up to whatever HUD deems as that actually, it ties back to the dependent allowance for the HUD properties that have to do rent calculations. Now for as long as I can remember, and I am coming up on my twenty fifth anniversary of being in affordable housing, I should probably stop telling people that because they start doing math, but it's been four hundred eight dollars But I will give you a little bit of teaser of something we're talking about later as part of HOPMA. They have now said that they this amount is gonna be subject to an annual adjustment factor that they're going to take into consideration things like inflation. So that four eighty may adjust up. And if that adjusts up for the dependent deduction on the HUD side, that's also going to change the amount of income that we would charge or that we would count towards the household's income if that situation presented. So that's something to to stay tuned to. We'll talk more about that a little bit. Some income exclusions. So at this point, I put some language into HOPWA that talked about some things that we're not going to look at as far as income. So if someone is receiving insurance payments or settle settlements for personal or property losses, that's not gonna be Canada's income. This is new to us. So I think that we've always kind of looked at all of things and trying to catch everything possible that might be a circumstance with someone. But now this by design in HOPMA is not going to be counted as income. Amounts recovered in a civil action or settlement based on a claim of malpractice, negligence, or other breach of duty that resulted in a member of a family becoming disabled, that's not gonna be counted as income. To me, that's good news because I have a feeling that folks that are in situations like that, that money has changed significantly for them as far as their income, and then they may have increased expenses. So So I think that that's that's great, especially on the HUD side when you're using that to calculate income for their calculate their rent. So some other things. Oops. Veterans aid and attendant care. So payments that are related to aid and attendance for veterans under thirty eight USC fifteen twenty one. This is also covers home based care for disabled, family member. Those that's gonna be excluded as income. And then the other thing that has come up in conversation before, and I think that there were a lot of us that weren't sure how to calculate it. If we count it, if we didn't count it, how do we count it? And that's actually, replacement housing gap payments. So anyone that's subjected to the Uniform Relocation Act, if they are being displaced because of either it could be a rehab, it could be a sale, there could be lots of different things that are that are involved with that, where they are getting paid a certain amount of money to house other places. They may even be getting some other monies. If that was above and beyond, we used to have to count that. That is purposely now excluded. So, that that to me is another good thing. Especially if we've boosted people out of their home for a period of time, now we don't have to worry about counting extra income that's tied directly to that having to make them move for something. Financial aid. I would say of all the changes in HOPWA, this is probably the one that gives me the most heartburn. This is going to feel completely different. This is something that I hope that in a couple of years, you know, it'll be so, it'll be like back of our hand. So meaning that we know it. We don't even think about it. But they have changed the rules with financial aid, talked about, considering if there's assistance with the unit. So we have to determine if there's public housing involved or non section eight programs versus project based section eight. It impacts what we look at as far as financial aid. Until now, until HOPWA takes effect, we only counted it for folks that were receiving benefit of section eight, and then we just simply counted the amount of financial aid above the cost of tuition and mandatory fees. Easy. It's not as easy now, but, again, I think this in time, this will become very routine for us. So, but right now, I feel like it's almost like a flowchart. I will tell you I had flashbacks back to tenth grade geometry class, those if then statements. But I think, again, hopefully, with repetition, this will become something that we won't even think about. We will just do. Some of the best ways that I can kind of explain this is actually these are the examples that that HUD gave us. And it talks about, Roberto is a twenty two year old full time student without dependent children. And this, he is living in a, he is a participant in section eight. He is the head of household. He is not over the age of twenty three independent children. So with this now with the new financial aid rules, if you receive student financial assistance in excess of tuition, both from HEA and other sources that we're going to have to look at it differently. So HEA is the Higher Education Act, in case you haven't seen that acronym or are familiar with that acronym. So his total assistance received under four seventy nine b of HEA is twelve thousand dollars That's in the form of a federal Pell grant. And if you've worked with with college students that lots of folks have that federal Pell grant. In his case, other student financial aid is twenty five thousand dollars So the total student financial assistance, so if I add those two together, I get thirty seven thousand dollars Now we find out that his total tuition plus required fees and charges is twenty seven thousand dollars So we are going to subtract the total cost of tuition plus required fees and charges from the total amount of student financial aid assistance. So thirty seven thousand minuteus twenty seven thousand equals ten thousand. So this ten thousand dollars is going to be counted as income in this instance. I'm just gonna leave this up here for just a second so those of you who are gonna reading through can see it. Christine? Yes. We got a couple of questions come in the chat. Is it would you is it okay to ask them now just so we don't Sure. Know what we're talking about? So there's two different ones. There's one came through in the chat that said, what if at my property, we we do self certs? The only time this would be in effect is it move in and one year cert. Is that correct? She says the property is not HUD. Yes. So so there again, you're at move in, you're always gonna follow and I'm I'm glad you brought it up. I'm glad you forwarded the question you did because I wanna point out a couple of different things. So always at move in, you're gonna follow whatever whatever the regulations are. So when HOPWA takes effect, you're gonna follow all the HOPWA regulations, and and do all of your due diligence. Now you mentioned a one year research. So here's my little tip that, and this is taking us back. When the HERA was signed signed into effect back in two thousand and eight, what it says is that for purposes of the tax credit program, so on the federal standards, if the property was one hundred percent allocated to the tax credit program, meaning every single unit had to be tax credit qualified. It actually suspended the need to do income recertifications. You only did that initial initial certification and then you moved on. States, however, have always been given the, opportunity by the IRS to create a higher standard for things. So there are many states that said, you know, we're not good with just doing that initial and then just going off to a self cert. We want you to do an annual research. There are some states that never let anyone do the HERA guidance and adopt never having to do research. There are some states that said do one annual research, and then you can move to self certs. There are some states that, have where you do two years. And I think part of it is that they were concerned about fraud. They were concerned about people that presented at move in. And then, when they were their income was tested again, there were things that they disclosed that they hadn't disclosed when they moved in that may have made a different determination. So if you are doing a self certification, if it's after that you know, if you're following whether your state regulations are are are doing that, you're doing self certs. If you're just allowed to do self certs because you're a one hundred percent property in your state, so once you initially qualify, you never have to do a third party or a verified. It can all be self certified. Self certification is fine. I'm assuming that you're having them fill out some sort of an income and asset form, whether it's a state mandated form or it's something that your company has come up with and that you're doing a general calculation based off the information they've provided, and then they're signing off on that. So I hope that answers answers your question. But I do wanna point out the difference between federal regulations and then state regulations because that's actually gonna play into some of our HOPWA implementation as well, because the states can make some of their own decisions. And we have we as practitioners in whatever state have to abide by that state's set of rules and guidelines. Got it. And then here's one more. IHSS income received caring for a household member in the home. There has been some confusion as to when it is excluded. Is it a family member or a household member or both or either as long as they're in the same household? I hear family member and household member terms being used. Just wanna confirm that is it in fact both or if it is truly only a family member. So that is a great question, and I do believe I have I can read it right from the horse's mouth. So if you can bear with me for just a second. Because I think that there are some things that are just are new or we've we've we've debate. And I was joking yesterday with, someone that is also a compliance manager and how us compliance folks, we can debate for hours and days and weeks and months about things. So, bear with me for just a real quick second because I do wanna make sure that Okay. So state payments to allow individuals with disabilities to live at home. And this is founded in twenty four CFR, and I've I've five point six zero nine b nineteen. I probably didn't say that correct. There's probably someone out there that is very persnickety about that, and I do apologize. It says these payments must be made, by or authorized by a state Medicaid managed care system or other state agency. Include state Medicaid managed care system, other state agency, or authorized entity to a family member or family to enable a family member who has a disability to reside in the family's assisted unit. So it does say there that it is has to be a family member in order for that to be excluded. Thank you. Thanks for letting us pause for those questions. Sure. So any other questions before we move on to next nuance of the of student financial aid? Okay. Alright. Let me get into this example. So this is for, an example of student financial aid assistance in a non section eight programs. So Juan is a full time student. He received the following grants and scholarships to cover for college, federal Pell Grant, dollars twenty five thousand, university scholarship, dollars fifteen thousand, Rotary Club scholarship of three thousand. So in this instance, that total assistance received under the Higher Education Act, that's that Pell Grant, so twenty five thousand dollars The total other financial assistance received, dollars eighteen thousand. Dollars. So that's adding up the university scholarship and the Rotary Club. His actual covered costs, plus required fees and charges. So if I'm looking at that oops. I apologize. It's twenty eight thousand. I do apologize. I had flipped my my notes there. So step one, determine amount of actual covered costs. So twenty eight thousand dollars are are actual covered costs minus, so we're going to subtract out the total assistance received under the Higher Education Act. That equals three thousand dollars Determine the amount of student assistance to include an income, dollars eighteen thousand. So that's other student financial assistance received minus three thousand. That's that actual covered cost exceeding that, Higher Education Act assistance or the Pell Grant, that equals fifteen thousand. So we're gonna be counting his fifteen thousand dollars as income for him. Now, if that number had been a negative, then we wouldn't be counting any money for him. So we do still have to do the math. We still have to figure out if there's money that we do have to count. But you can see that there's some different different ways that we're doing it based on whether they are receiving section eight or they are in a non section eight program. So, again, I will be real honest with you. This is the one that I think gives me the most heartburn. But, again, I think with practice will come will come ease, and it will be something that soon that we won't even give another nod to. We will just keep working on it, and it will make it will all make sense. So okay. I do wanna change over and talk about assets. We have had some definitions that have been put into the guidance for us. We have some terms that may be new to us and some new implications. And then there's some other things about how we treat some things. There are some differences now. So, oops. Sorry about that. So real property. So real property, that that would be a house or that would be a piece of land. Personal property. So that's just about everything else that we have. So but here's the thing, is now HUD has said, okay. We have necessary personal property, and we have non necessary personal property. Here's another full disclosure. I will tell you when they first started talking about this and they talked about necessary personal property are things that I need to survive. So my clothes, my furniture in my apartment, my car that I used to get to work. Those are definitely necessary. Those are not going to be counted as assets. Examples of non necessary personal property, a checking account, a savings account. If I have luxury items, so if I have a, a speedboat, If I have a very expensive piece of jewelry, that is not something that is my wedding ring. So a wedding ring or something that has a religious or cultural significance would be considered necessary. Non necessary would be those those other than. I did joke with someone when they talked about non necessary and they talked about checking accounts and savings accounts. I could just imagine someone saying, well, I have this account so I can pay bills, so therefore it is necessary. I appreciate that comment, but that's not how we're looking at things in this inference. So we are still asking people about the assets they have. We are still foregoing some things that are what they consider necessary personal things. There are folks that may own things that are there for a job that they have. So it could be a printer. It could be, other assets that are tied to the business. And and we've talked before in the HUD forty three fifty point three that assets tied to a business. We're not looking at those. But, again, they did put that into the hot the guidance, I think, because of so many folks that are dealing with gig type jobs. So they want to be very specific for it. So when, when we look at assets, the questions that we ask, the forms, a lot of forms have already been updated by the states, that if when they have a required form, there are, groups like the National Council of State Housing Agencies known as NCSHA. They have put out a a version of a form. Oftentimes, their forms end up getting adopted by the various states to use, but they are going to be asking about those things that are non necessary personal property to see what we need to do as far as valuing them. So, and then we have some changes with things that we have traditionally looked at as far as an asset, and that has to do with trusts. I will say if you get a trust, I am probably gonna always refer you back to the guidance and go through to see what your situation means. But oftentimes, we are not looking at the money provided by the trust. We are looking or we're not looking at the principal rather. We may be looking at some of the income coming from the trust, but only in certain situations. So pardon me? We've got a few more questions. I I also wanna make sure we hit all your slides. Do we have time for a couple? Yeah. We do. We're good. Okay. So it looks like they there might be some need for additional examples of personal property versus necessary property. There was a specific question about whether an EBT was necessary or not. And then the other questions was for seniors who have IRAs that have over a hundred thousand in them, do they qualify for housing or would this amount put them over income? So that's a couple that you might be able to address. Okay. So those are two let's go let's go back to the first one because I I wanted you to repeat what they Yeah. There there were two that were somewhat related about necessary and non necessary. Right. The one was, is an EBT necessary or non necessary? And then the other question was give examples again of personal property and necessary personal property. I'm not getting EBT. So if if that's an acronym that somebody's used, if the the poster would would give some clarity on that so that I can address it properly. Okay. Got it. So the other thing the other thing about the IRA, one hundred thousand dollars. So I wanted one thing I'm gonna stop here is, if you look at some of the HOPWA guidance, for the HUD properties, there are some caps as far as assets. That does not come into the tax credit program at all. So we still have a situation with tax credits. Somebody could have a million dollars of assets, and they possibly might still income qualify. On the HUD side, so if I have to follow the HUD rules because I have project based section eight, I am going to have caps on assets, and I have to determine what I'm going to do for existing residents. And when HOPWA first came out, it was a cap at a hundred thousand dollars total assets. That also is one of those that's, subject due to that annual adjustment factor. So that does not that, that IRA does not come into our calculation. Now here's the other thing about retirement accounts. Retirement accounts, and this is one of the this is huge. So if they have if they have retirement accounts that are that are recognized by the IRS, if they are not taking routine payments or regular payments, it is not income. It is not considered an asset either. If they are taking routine payments, then we're gonna treat that as income. At this point, I would say, because somebody asked a question about an elderly property, I would always be mindful about those folks that are subjected to the required minimum distribution amount, which is you'll see the acronym RMD. So, that number was up adjusted during COVID to the age of seventy three. So if someone is over the age of seventy three and they have one of those retirement accounts, if they had not set up to take routine payments where we're looking at it as far as income, we may we we do have to calculate that RMD and that would be considered as income, and it's not an asset. I hope that I hope that brings some clarity or at least a little bit clears a little bit of the mud. Got it. So, Chrisann, did the person who put in EBT? Yeah. They said EBT is like food stamps. And then I also see I'm seeing a lot of things, a lot of other people responding. They said they said food stamps. They've said, SNAP benefits are placed on EBT cards. The EBT is for TANF. Okay. For TANF. Okay. So let's so thank thank you. I was because EBT has never been an asset. I think that's what was throwing me. I heard EBT, and I immediately thought about about, welfare benefits. So let me make the food stamps, not income, never have been, never will be. If they are receiving cash assistance, and that cash assistance is known by various names in different states, then that could be income. So TANF, which stands for temporary assistance for needy families, that is usually, a single head of household that has children where they are not receiving child support or they're not receiving the entire award of child support and they do have a TANF benefit, that is still income. So that's that has not that has not changed at all. So I hope that that that answers their question on that. Awesome. Thank you. Yep. And food stamps, somebody mentioned SNAP. So the SNAP program, that's food stamps. So, again, if if that's what not what I have found as I travel across the country that different states have different, names for their various programs. I was working in one state when I first heard SNAP and I could not for the life of me at first figure out what world SNAP benefits were until I did a little bit of digging. I do think our industry specializes in the amount of acronyms that we have. I I usually call it lingo bingo because we we throw them around, and sometimes we don't even know what they stand for. And sometimes we don't know what they are. So trying to get to actually what what the what the acronym actually is, then figure out if we actually it's something we actually need to be concerned about. So okay. So let me talk a little bit about trust. Now this is part of the in, both in income and, assets. So irrevocable trust or revocable trust outside of family or household control is excluded from the definition of family assets. So again, if we have someone with a trust, we need to understand, is it an irrevocable trust or is it a revocable trust that's within the family's control? So we need to understand that as to whether we're going to count it. A revocable trust or a trust under the control of a family or household, any distributions from the trust are excluded from income, except that actual income earned by the trust regard regardless of whether it is distributed shall be considered income to the family at the time it is received by the trust. So, again, I will tell you that in in my years of working with residents, I very rarely come come up against trust. I'm not sure what all of your experiences are, but I will say it's it's something that's unusual enough to me that if I were were presented with that situation, I'm gonna go back to the prevailing guidance. I'm not gonna rely on my memory. I'm going to go actually go back to the guidance and try to work myself through the steps to understand how I need to treat it and what I need to do with it. Whether there's income, whether it would be considered an asset, what I need to do. So and if I can't do that, then I'm going to seek higher guidance with that. But I will say, trusts have come up just and I don't I'm this is just, you know, very much of just, anecdotal, but I may have seen five trusts in twenty five years. So that's been my experience. Again, I don't know what your experience is, but it's something that, I am talking about it only because it is addressed in the HOPWA guidance, and it is something just to, hey, pay attention to this if this circumstance does present to yourself. So, Chris Anne, any other questions before I Yeah. I'm kinda confused because people people are telling like, they're providing information to each other. I do somebody did pipe in and say somebody said you didn't answer the original question, but I'm not sure what question they were You know, I'm practicing to be a politician, don't you know? Let's see. We have, we have one about let's see. There's there's a lot coming in and we probably won't get to all of them, but we'll make sure that we email you. We can look at these after. Okay. It says the original oh, this is the person who said we didn't answer the original question. Cindy said the original question was personal property comma necessary property. So I guess did we get that clear for everyone? No. Because we ended up I'm sorry. Ended up getting distracted by distracted by another another All the questions. Yeah. Yeah. And it's it's hard. I think because this is this is new. This is something that, we've not talked about in this inference. I think in some ways, we've always practiced this. So, necessary personal property is an example of something that I need to live and to work. So examples of necessary personal property, would be clothing. It would be the the items that are in my apartment, my furniture. Even, I'm I would say, even if I had a huge, big ninety five thousand inch, I think I just made that up, TV, I'm not gonna look at that as that's just gonna be part of part of necessary personal property, and we're not going to put a value to it. So the car that they drive, the jewelry that they wear, and these are things that kind of everyday things. Now non necessary is there's kind of two categories of it. So we're still looking at things like checking accounts, savings accounts, life insurance policies, stocks, bonds, those sorts of things are still stuff that we're gonna value. That's non necessary. Now they also go on to say non necessary does include some luxury items. So if I own a if I own a speedboat or if I own a car. I have a a sixty seven Mustang Mustang Fastback GT that I have in storage, and I take it to car shows in the summer. That's something that has a value to it. That's gonna be valued as an asset. But the car that I drive, so my twenty fourteen RAV four that's out in the parking lot, that's not being considered as an asset. So, the other thing that they may may clear very clear with this personal property, necessary versus non necessary. Necessary personal property also covers things like jewelry that has religious or cultural significance. So if I wear a a fourteen karat gold cross or a fourteen karat gold star of David, if I wear a wedding ring that's been passed down through my family, that's that's not gonna be considered as an asset. Even though it could have it could be very, very expensive, That's still tied to I'm wearing it because it's my wedding ring, or I'm wearing it because it is something that has a cultural or religious tie. Now if I have a four carat diamond that I only wear to parties, and I can't imagine, but that's you know, I'm just trying to use this as an example, then that would be considered non necessary. Does that help the person who asked the question? Was it Sandy that asked? Or yes. Cindy. I I Or Cindy. Sorry. And we're at one fifty, and you have, what, two more slides? We have two more slides, and then we can we can talk about questions. The next couple of slides won't take a a a horrible amount of time. But Okay. One of the news new things to us. It talks about means tested verifications. So what HOPMA allows us to do is is identifying that so many folks are part of other programs that are also looking at their income. And so what what this provision does is saying that we are allowed to go to them if they've already tested someone's income. So this could be back to your your folks that have, get food stamps or SNAP benefits because they have tested their income to make sure that their income falls under their limits for their programs, that we would be allowed to use what information that they've done. Now, obviously, we'd have to put kind of a a real reality test to it. Has it been a recent determination of that income? But we are allowed to use stuff like that. In the documents, you'll even see, for HAVA, and you realize HOPWA is written primarily on the HUD program, but we adopt it because of the tax credit program following that part five. It says the tax credit program. So it's allowing us to kind of swap back and forth, if you will. And, again, going back to the whole idea for HOPWA was to reduce administrative burden, not only on property managers and owners, but also on our residents. So I know that I have folks that have felt like every time they turn around, someone's asking them to income qualify for something. So this new provision of this means tested verification, hopefully, will reduce some of that and allow us to streamline some of that. Now granted, there are probably some owners that will not wanna do that that they wanna do their own investors. They'll wanna do all of their own work or have the owner do all of their own work. That's fine. It's saying it's out there, and it can be used. So I think that this is gonna be a great thing in the future. I think it's great for not only for us because it reduces the amount of work that we have to do, but it also the benefit is for our residents and our applicants. Because I do feel and and, actually, someone said this at a conference, and it it made sense. They said they bought a car. They went online. They answered a couple of questions, and they had a car loan. But think about all the questions sometimes that we ask our residents and our applicants. And some of these folks that are low income, we actually put them through a higher level of standard. It's almost as if we're treating them as if they are lying or as if they are hiding things. So by being able to tap into this means tested, hopefully, that will kind of relax some of that. Not that we're not doing our due diligence, and I don't I don't mean, you know, relax on your due diligence, but I am saying, you know, let's be aware of the things that we're putting folks through and the questions that we're asking and how can we kind of hopefully make all of this kinda come together and and and be to all of our benefit. So the other thing that happened with this, is they talk about a hierarchy of verifications and some new standards. So HUD actually, when they updated the handbook back in twenty thirteen, they kind of introduced this whole idea of what they called upfront income verification. And upfront income verification first glance on the HUD side is something called EIV, which is the enter price income verification system. We don't use that for tax credits. We are not supposed to use that. In fact, we could get in trouble if we use that EIV. EIV is a proprietary agreement between HUD, health and human services, to and it was actually originally created because of, a question about fraud. And when they first implemented EIV, they did catch a lot of fraud. They were paying HUD was paying subsidies on people in two different locations, whether that was identity theft or we had people that decided to live part of the year in one part of the country and another part of the year in another part of country, or people just just trying to to get by. They found that they were paying subsidy on people that had passed away. So there were definite needs for that EIB system. It's now I will say that on the HUD side, it's it's a great convenience. There's a lot of stuff that they can use, which will simplify the verifications. However, we can't use that on the tax credit side. But we do have other things that are what are considered upfront income verifications. So now what it's saying is that we have, in essence, full permission to go to entities like the work number. Or, there are several of those companies now that have popped up that are doing that have payroll information on applicants or residents, and it's saying that's that's fine. That's actually the first place that you wanna go for that. Now at this point, I will stop because there are a couple of states that will not allow you to use the work number. They have their reasons for that. So, again, even though I'm talking about the federal standards, you do have to be aware of what's in your state, where your property is located, and what their standards are. And if they have said, please don't use this, then don't use that. They are the ones that monitor compliance, so you do have to abide by by what they have said. But this also lets us, talk about web based stuff. So I know that there was a as we're moving forward with technology, we have folks have apps on their phone that can create reports. This is kind of, in essence, blessing this and saying this is fine. Instead of going directly to that third party and hoping that they will and waiting on them to give a third party verification, that these are considered third party. So when they can get and we'll talk a little bit about bank statements too with with some changes that are coming up with with checking accounts that I think is pretty cool. But but things like pay stubs. So this is this is going to be a lot easier. So we're gonna go to that upfront before we try to go to a third party. Third party is actually if you look on the slide down, it's third on the list now. So, we are also, you know, really gonna try to embrace anything that tenants can provide us. Obviously, we're gonna run them through a a litmus test. Is it legitimate? I, unfortunately, have seen some pay stubs that I think were actually created falsely, but still, under most circumstances, we're going to allow that, and that's gonna be just fine for the purposes that we need to do. Next one is is written or third party verification directly from the income source. So here's the big shift. It used to be that was the first thing. So we had to even though we knew that that employer was not gonna give you a third party verification, we still had to send a form to them and have them tell us, no. We won't give it to you. So we don't have to do that anymore. So that's great. We can we can save a lot of time and hopefully get folks qualified a lot easy a lot more easily than than before. Then you'll see down the line oral third party verification and then kind of the, if all else fails, self certification. So this would be something that the resident or the applicant would be telling us. That's gonna be last on the list. That's gonna be after we've tried to explore all the other options first. But, again, upfront income verification now is first and foremost how we're gonna go and then follow through that hierarchy. So one of the things that I did, and I don't have this on a slide, but I wanted to talk about what verifications are. So when HAVA goes into effect, what HAVA said is if someone is employed, no longer are we looking at four to six pay stubs, then we can rely on just two. And I realized somebody on the the webinar probably just passed out, so let's let them have a second to come to. Now it doesn't say that you have to only collect two. It just says that you can collect two. I will say in talking to people all over the country, I think most people are probably going to want a larger sample size than just two pay stubs, but that is in there. Here's the thing that I think is awesome. Hama says that if I have a checking account, I only need one bank statement. No longer will I have to do that six month average on a checking account. So some of the other things, that I know that we won't have time to get to that we may have to do a part two, but there are some things about how we calculate assets, how we calculate income from assets. Rules have changed as far as imputed assets. And so that is unfortunately, we're gonna have to save that for another time, but it definitely is something that is part of HOPMA. But I will say definitely, take a look at what's going on in your state. Take a look at what they're doing as far as when they're implementing HATMA. There are some states that implemented it back on January first of twenty twenty four. There are some states that will put it into effect January first of twenty twenty five. There are others that are now saying they're gonna delay until what HUD has said is their new implementation date of July first. So stay tuned to your state to understand when you need to fully implement if you're allowed to implement now, but with clarification records. So Okay. We are at time, but if you can stay, stay. I'm assuming that Christine's okay with that. If we I just wanna do a quick announcement on the next slide. Oh, sure. Yeah. So we have this is important to remember. Grace Hill offers, tax credit courses. So we have a the the information that we have shared over over the last few months is that we have been updating our tax credit basics to have the new information from the HATMA rules. And so those updates have all been done. And so now your teams have access to the most current information, to keep you in compliance. In order to ensure a smooth transition to these courses, if you don't have our elective series, you can contact your customer success manager to find out more about that and how to get that elective. If you already have it, there's a few things you need to do. There is a link to the list of the courses that are available, and I'm gonna, I'm gonna copy this real quick. I'm gonna give you also let me hop back over here. So if you scan that QR code in there, that will take you to the directory of the courses. And then I've also dropped in the chat a link to the course replacement guide. So these are for existing customers, existing Grace Hill customers who have these courses. If you are an admin and you're on this call, you're gonna want to unassign the related courses and the learning path assignments before the end of the year, generate completion records for all of the LIHTC courses to avoid error messages on the learner transcripts. And then you're going to look at the new courses and assign those if you haven't already done that and just complete all of that by the end of the year to avoid any interruptions. And the link to the course replacement guide is in the chat. And we've also emailed this out as well. But if you have any questions, you know, don't hesitate to reach out to your Customer Success Manager. Now we still have quite a few people on. And so I'm gonna try to take a few minutes to go back to, the chat and see what else we can pick up on this. And I don't know if let's see. There's quite a bit going on in here. Let's see. Do we talk about a car? Oh, somebody somebody's family, a resident. Their family gifted them a car that is valued at more than a hundred thousand dollars. Would this fall under an I love you gift? Wow. I don't think so. I mean, that's that's wow. That's a great question. I would actually probably have to go to HUD and ask them about that. I think that's a little bit extreme. I can't imagine somebody giving someone a hundred thousand dollar car. I wanna join that family. I well, I was just thinking that. I just I was I was Can I be a part of that family? Wow. Okay. So, yeah, that one sounds tricky too. I I am not and I will say this too. I have so much respect for all of you who work under in this vertical because you have to know so much more than I'm I'm property management person. I've worked in garden style communities and at market rate apartments for many years. But this is a lot of information. And so this is it's just I'm just continually impressed by all that you have to know. But to me, this does sound a little bit tricky as well as to whether or not that would be counted. Wow. I would definitely that that is definitely something that I would get, higher opinions. I would talk with folks at your state. I would talk to HUD about that. I it Part of me says, yes. Value it just to be on the safe side. And then again, it's at that point then, because if assets are over so now there's so I talked about there not being an asset cap saying you can't qualify for housing. There definitely is one of those on the HUD side, and it started out with Hotmail being a hundred thousand dollars. Now it's up over a hundred thousand because that's one of those things that is subject to the how the annual adjustment factors. One of the things that COPPA came out with was the amount that we can self certify assets, and that started out at fifty thousand. Now it's at fifty fifty one thousand sixty dollars, sixty dollars, I believe, is the the twenty twenty five amount. Now I'll stop here and say that that's what HUD says, and a lot of states are going for that because it's because it's part of a HOPMA and now the HUD guidance. There are some states that are saying that is not a good thing or not something to abide by because they are holding tight back to the IRS issuing years ago the ruling saying that folks could self certify if their assets were five thousand dollars or less and saying that's that that is going to stick and it would not, we would not be able to use the under well, I'm gonna call it fifty thousand just because fifty thousand rolls off the tongue a lot better than fifty one thousand six six hundred dollars. We haven't heard from the IRS on that. Sometimes we don't wanna ask the IRS questions because of the answers that we may receive from them. But there are some different things as far as, if we impute and if we don't. What's gone away is the imputing if their total assets are over x y z, saying imputing on the on the entire amount of assets. The only time we would ever be imputing on an asset is if their assets were over that now fifty one thousand mark, fifty one thousand sixty dollars mark, and it was an asset that we did not have an interest rate or a dividend. So wanna use that one hundred thousand dollar car, and I'd like to see that happen. But anyway, because that that car itself is not it's not an investment. It's not earning interest. We would be imputing at the current HUD passbook rate an annual amount for that based on the value of that vehicle. So it's it's a little bit more tricky. Again, I think once HUD finally says HOPMA is in full fledged, the all the software providers have been working on all the all the mechanics that they need to do to make their software work that will know when we have to do something or demand an answer for something. But until then, there are many states that are just, again, following they're following what we've always done. There are some states that have gone on with the HAVA stuff. So I would say, definitely, if you have questions about assets and whether is and especially now until at least July first when we are told that that is the effective date for HUD to fully implement HOTMA. In the meantime, go to your state, look for state guidance on things. If if not, then then seek higher higher information either, you know, from an industry expert, from someone in your company to figure out what you need to do. But, again, once the software companies are all waiting, and they're waiting for HUD to kind of finally wave that wand to say, hey. We're we're going for this before they can fully implement the changes that that that HUD is bringing. Got it. Well, there's something open in the question, but it's not a question. It's it just says, I think that people inherit assets. That's all it says. So I don't know if somebody thought they were maybe answering somebody else's question. And people do inherit assets. Yeah. So, so, you know, depending on where you are with your certification process, you may be addressing it. So if it's a brand new move in and that's something that they've already inherited, you're going to see that in in their story as far as the the information they disclose to you. If it's somebody that, already is a resident and they inherit assets, it may never even come up in conversation if I don't have to ever, you know, verify their income again, if I only have to rely on self certification. So but you are right. I mean, people do inherit things at different times. So Okay. We are we are past time. I will tell you that somebody somebody in the chat has said if they where do I find the HOPWA guidelines for further? So there's a couple of different things. And I will tell you, you can go to hud dot gov. But, I not being a person who has ever worked on a tax credit property in my life, I have taken the courses that Christine and the team at Grace Hill created, and I found them to be very easy to understand and follow. It's complicated information, but we have learning experts that partnered with Christine to create this material. So your best bet is to, sign up for this elective. If you're working for a company and you don't have this elective, reach out to the leaders at your company and and tell them you want these courses, because this is what's gonna keep you in compliance. And then your answer to the recording for the webinar, that will be sent out to all registrants later on this week. So you'll get those as well. And the the question about are they an additional cost, that's for the elective, I'm assuming. Yes. But it's not much more, and it's certainly worth it to have all of the knowledge right there at your hands, and to ensure that you know, everything. Do these courses count as CEC for CAM and CAPS? They do not. I apologize for that, but I hope that you found this valuable. Okay. Let's see what else. Are the changes to the compliance manual posted on the admin page? I don't know that I know what that means. I don't know if they're thinking about the, the policy manual that Grace Hill has. I'm not sure how to answer that question. Oh, the policy manual. The manual has been updated. It's the the updates are in there live with the new HOPMA, rules. This is based on the HOPMA changes. And Christine's next, her next step for us is to review that manual. We wanted to get these courses finished. And so she's gonna review it just to put her stamp of approval on it. And so we'll let you know once that takes place. So, so stay tuned. We're we're excited to be able to support everyone. And just like I said, if you have any other questions, reach out. I can make sure we get those over to Christine. And, thank you so much for for being with us today. And one thing one thing I'll say, if you attended this webinar and things are overwhelming, I have been there. I am there. It is big. This has changes. I joked with the team when we were redoing the tax credit coursework that it would if we had that men in black neuralyzer pen, it might be easier because we would all be starting, you know, fresh and new, and we wouldn't have to say, but this is how we did it. It it's it's something that it will become very familiar. It will, it will make sense. A lot of it does make sense. And if I keep going back, what what saves me is I keep going back. This whole idea is that this was supposed to be a savings or reduction in in in process, if you will, for us and also for our residents. And and I I am embracing it. I mean, it's just I wish it would go into effect tomorrow, but we are kind of, you know, kind of all in that holding pattern. So, again, I keep saying go back to your state, see when your state is implementing it, and then, you know, and and ask questions. I mean, that's that's how we all learn is by asking questions. We're not all given perfect knowledge ever. So Well, thank you so much, Christine. You are a wealth of knowledge. And, yes, you will be able to have the the video content because we will be emailing you the recording for the call. So everybody, thank you so much. Go on about. Have a great rest of your day and, have have a wonderful, holiday season. Thanks, everyone.