HCCP HCCP Annual Certification Procedures 1 — Questions and Answers
Question 1: What is the primary purpose of the Annual Owner Certification (AOC) submitted to the state housing finance agency?
- To certify that the property remained in compliance with all LIHTC program requirements during the prior year (Correct answer)
- To apply for a new allocation of tax credits
- To request an extension of the compliance period
- To report changes in property ownership
Correct answer: To certify that the property remained in compliance with all LIHTC program requirements during the prior year
The Annual Owner Certification affirms to the state agency that the property complied with all applicable LIHTC requirements during the preceding calendar year.
Question 2: How frequently must LIHTC property owners recertify the income of existing tenants in units under the general public use rule?
- Annually, unless the state agency has adopted the available income-averaging recertification relief (Correct answer)
- Every two years for all tenants regardless of state agency rules
- Only at initial move-in and then at year 15
- Only when a tenant's income visibly changes
Correct answer: Annually, unless the state agency has adopted the available income-averaging recertification relief
Under standard LIHTC rules, tenants must be recertified annually, though some states have adopted relief provisions that modify recertification frequency for certain income-averaging projects.
Question 3: What information must be collected during a LIHTC tenant annual recertification?
- Current household income, household composition, and student status of all household members (Correct answer)
- Only the tenant's current employment status
- Credit score and rental payment history
- Original move-in application and background check
Correct answer: Current household income, household composition, and student status of all household members
Annual recertification must capture current household income, composition, and student status to verify continued eligibility under LIHTC income limits.
Question 4: Under IRS rules, what is the deadline for completing a tenant's annual recertification relative to their move-in anniversary date?
- The recertification must be completed by the anniversary of the tenant's move-in date each year (Correct answer)
- Within 90 days after the end of the calendar year
- Within 60 days before the lease renewal date
- By March 31 of each calendar year for all tenants
Correct answer: The recertification must be completed by the anniversary of the tenant's move-in date each year
LIHTC rules require that annual recertification be completed by the anniversary of each tenant's initial move-in date.
Question 5: Which IRS form is used to document the initial low-income unit certification for a LIHTC property?
- Form 8609-A (Correct answer)
- Form 8823
- Form 8586
- Form 1099-H
Correct answer: Form 8609-A
Form 8609-A (Annual Statement for Low-Income Housing Credit) is used by owners to report the initial certification and annual compliance status of each building.
Question 6: If a state housing finance agency does not receive an owner's Annual Owner Certification by the required deadline, what is the most likely consequence?
- The agency may treat the failure as noncompliance and file Form 8823 with the IRS (Correct answer)
- The property automatically loses all remaining tax credits
- The owner receives a 90-day automatic extension
- The tenants are notified and must self-certify
Correct answer: The agency may treat the failure as noncompliance and file Form 8823 with the IRS
Failure to submit the AOC on time is treated as noncompliance, which the state agency must report to the IRS on Form 8823.
What is the primary purpose of the Annual Owner Certification (AOC) submitted to the state housing finance agency?