HUD Wants Our Input!
One of the many
provisions the Housing and Economic Recovery Act of 2008 (HERA) brought
about was a requirement that State Monitoring Agencies collect and submit to
HUD certain demographic and economic information on households living in Tax
Credit units at least annually. The provision leaves the technical aspects
of collecting this data up to HUD but requires them to establish standards
and assist the State Agencies in submitting such information.
On March 30th,
HUD published a notice in the Federal Register seeking public feedback on
the standards, definitions, and procedures for collecting the required data
beyond the working group it formed last October.
One possible
approach for which they are seeking comment is to use 2 forms -- one
requesting data on Tax Credit properties indicating project-based subsidies
so that universally applicable project data need not be submitted separately
for each tenant and the other form requesting data on LIHTC tenants and
unit-specific characteristics. HUD wants comments on whether this would
minimize the burden on property managers and if not alternative suggestions.
Also HUD seeks
comments on whether they should use the form currently used to collect data
for their LIHTC Database to meet HERA's property characteristic
requirements. This form is currently used annually to collect data on Tax
Credit properties from State Monitoring Agencies who voluntarily submit the
information through a contractor.
And finally, HUD
is seeking comments on using NCSHA's Best Practices TIC for collecting the
tenant data needed. HUD believes this form, modified to include race,
ethnicity and disability status, would minimize the reporting burden but is
requesting feedback.
The comment
period is open until May 29, 2009 and there are 2 ways you can mail your
comments to:
Regulations
Division, Office of General Counsel
Department of
Housing & Urban Development
451 7th Street,
SW, Room 10276
Washington, DC
20410-0500
or through the Federal
eRulemaking Portal at
www.regulations.gov, but
HUD prefers the comments to be submitted using the website.
When submitting
comments, whether by mail or electronically, the docket number and title -- FR-5298-N-01 Low-Income Housing Tax Credit
(LIHTC) Tenant Data Collection; Advance Solicitation of Comment on Data
Collection Methodology -- must be referenced. HUD is not
accepting faxed comments. All public comments will be available for viewing
at the HUD office in DC by appointment or at the above mentioned website.
To use the Federal
eRulemaking Portal at
www.regulations.gov, simply enter LIHTC Tenant Data Collection into the
Search Document dialog box and press Go. Then click on the "Send a Comment or Submission"
which will bring up an electronic submission form for you to complete. You
can also view the actual notice by clicking on the "View this Document"
link.
And finally, the
notice states HUD anticipates it will publish its formal policy for data
collection this summer and data collection would begin as early as the first
or second quarter of 2010.
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