HUD Publishes Its Plans for Meeting
the HERA Data Collection Provision

Last March, HUD requested public comment on HERA's data collection provision which requires HUD to collect data on Tax Credit properties. On March 3, 2010, HUD released these comments and discussed their chosen methodology in  75 Federal Register 5298: Low-Income Housing Tax Credit (LIHTC) Tenant Data Collection: Responses to Advance Solicitation of Comment on Data Collection Methodology.

In this publication, HUD indicates they received approximately 25 comments from State Monitoring agencies, property managers, trade associations, research institutes and non-profit organizations and, after considering these comments, has chosen to meet this provision using a similar system as that which is based on the current TRACS system.

In general, this means HUD will collect the data specifically required by the statute, along with a minimal amount of additional information needed to assist in the data collection. As part of this process, HUD is designing forms for this data collection, however, the forms will not be required which means each State Monitoring Agency may create its own forms as long as the information contained on HUD's form is included on the state-specific form.

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