NLIHC and Partners Submit Comments on Proposed LIHTC Data Collection Forms

NLIHC, the Public and Assisted Housing Research Corporation (PAHRC), the National Housing Law Project (NHLP), and Regional Housing Legal Services (RHLS) submitted comments on April 11 to HUD responding to the department’s proposed changes to the Low Income Housing Tax Credit (LIHTC) tenant and property data-collection forms. These forms provide the data for HUD’s LIHTC Database and Understanding Whom LIHTC Serves reports. Without the data collected by these forms, no centralized database would exist on the location or characteristics of LIHTC properties, or the characteristics of tenants served by the program.

HUD’s proposed changes include new information-collection related to compliance monitoring, income targeting, re-syndication, affordability restrictions beyond the required 30-year minimum, Opportunity Zone funding, a new indicator for scattered-site properties, and the new income averaging option.

“NLIHC, PAHRC, NHLP, and RHLS strongly support the proposed revisions to HUD’s Low-Income Housing Tax Credit (LIHTC) Database Data Collection Form and the LIHTC Tenant Data Form,” the comments state. “Complete and accurate tenant and property data for LIHTC properties is critical to understanding the impact of the nation’s largest affordable housing production program, preserving existing tax credit housing, and ensuring accountability to both its tenants and U.S. taxpayers.”

NLIHC, PAHRC, NHLP, and RHLS also make recommendations for further improvement, including:

  • Collecting data on the exact duration of affordability restrictions lasting beyond the federally required minimum of 30 years.
  • Adding a question about whether the right to a Qualified Contract has been waived for a property and, if so, for how long.
  • Collecting the general partner names and improved monitoring of ownership changes over time.
  • Including data indicating whether a property participates in the Rental Assistance Demonstration or receives funding from the national Housing Trust Fund.

Read the full comments at: